Privacy Policy

1. Foreword

EDISYS SA attaches great importance to respecting and protecting your privacy and your data. Established in the Grand Duchy of Luxembourg since 2008, we are committed to providing services of the very highest quality, which entails the rigorous protection of the personal data you entrust to us.

This policy explains how we collect, process and protect your personal data when you browse our website immatriculation.eu, use our contact forms or apply online for a job within our group.

This policy applies to our immatriculation.eu website as well as to our professional social media profiles. It complies with the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016, the "GDPR") and with the Luxembourg Law of 1 August 2018 on the protection of natural persons with regard to the processing of personal data.

2. Data controller

The controller of your personal data is:

EDISYS SA (LBO Automobile division)
SA with a share capital of 40.000,00 €
Registered office: 2, Rue Edmond Reuter, L-5326 Contern (Grand Duchy of Luxembourg)
Luxembourg Trade and Companies Register: B139924
Business licence: 00140724/1
VAT: LU 227 183 55
Contact: contact form
Telephone: +352 661 754 747

3. Our commitment

We have put in place an internal data protection programme which includes:

• The purpose limitation principle: we never use your personal data in a context other than the one for which you entrusted it to us. Under no circumstances is your information sold or merely passed on to a third party for commercial purposes.
• The appointment of a data officer responsible for the protection of the data of our clients, providers and prospects, reachable via our contact form.
• The implementation of appropriate technical and organisational measures giving practical effect to data protection principles (encryption, access control, backups, logging, staff awareness).

The immatriculation.eu website and the group's social media are operated exclusively by EDISYS SA or one of the group companies acting on its behalf.

4. Data collected

Information you provide directly

When you fill in a contact form, apply for a job or write to us, you provide certain information directly: surname, first name, email, telephone, company, message, and possibly attachments (CV, copy of identity document, supporting documents).

Important note: mandatory fields are marked with an asterisk in our forms. Please do not submit any content that is not expressly requested by the form or by our team (for example, do not send us identity documents of third parties who are not concerned by your request).

Information collected indirectly

When you browse our site, certain information is collected automatically for the proper technical functioning of the site, for improving your experience or for statistical analysis:

• Technical connection information (IP address, browser type, operating system, page visited, date and time of the visit).
• Country/city determined by approximate geolocation based on the IP address.
• On-site navigation data (pages viewed, duration of consultation, browsing path).
• Data from media platforms and social networks when you follow our official pages or interact with our posts (only the personal information you have designated as public on those networks).

Note regarding minors

Our website does not specifically target minors. Nevertheless, should we inadvertently collect information relating to a minor, the legal representative of the minor concerned may exercise the minor's rights in their name and on their behalf at any time, by contacting us via our contact form.

5. Why we collect your data

If you are an existing or potential client of our group, we may use your personal data to:

• allow you to browse our website;
• respond to your requests for information about our services (contact forms, quotation requests, appointment bookings);
• produce anonymised traffic statistics to improve the quality of our site;
• keep you informed of our latest work (new services, new registrations, legislative developments that may concern you) — only if you have consented to receive such communications;
• better understand your professional interests and offer you a relevant browsing experience;
• process your unsolicited application or response to a job offer.

6. Legal basis for processing

The processing of your personal data is based on one of the following legal grounds, as the case may be:

• The performance of the contract concluded with you, or of a contract with a group company acting on our behalf, or of pre-contractual measures you have requested (quotation, request for information).
• Compliance with the legal and regulatory obligations to which we are subject (in particular the combating of money laundering and terrorist financing, and Luxembourg accounting and tax obligations).
• Our legitimate interest in promoting our services, in providing you with quality commercial follow-up over the long term and in improving the user experience of our site.
• Your consent where this is required (in particular for commercial communications and certain non-essential cookies).

7. Who may have access to your data

Within the group

Your personal data is accessible only to a limited number of people who need to be aware of it in the course of their duties:

• If you are a current client or a prospect, only the staff of the commercial and operational teams handling your file have access to your information.
• If you are a job applicant, your information remains strictly confidential and is destroyed if your profile does not match the position or if the position is not filled.

Outside the group

Your personal data is not disclosed to external third parties, except:

• To the member companies of the LBO group acting on behalf of EDISYS SA, on the basis of your prior agreement given by signing a contract.
• To the providers and suppliers who carry out our services (for example: the registration of your vehicle, the technical inspection, taking out an insurance contract, the notary in charge of a deed). These third parties act as processors and are bound by confidentiality undertakings.
• To authorised authorities who request it in accordance with the laws and regulations in force (tax, judicial and supervisory authorities, CSSF, CNPD, etc.).
• To our technical providers strictly within the framework of the performance of their services: hosting (OVH SAS, 2 rue Kellermann, 59100 Roubaix, France), professional email, data backup. These providers are subject to strict contractual confidentiality and security obligations.

8. Data retention period

In accordance with our Luxembourg legal obligations, in particular in the context of the combating of money laundering and terrorist financing (amended Law of 12 November 2004 and the transposition of successive European directives), we retain the personal data of our clients for a period of 10 years from the end of the contractual relationship.

Cookies placed by EDISYS SA are retained for a maximum of thirteen months from the date they are placed, except for cookies strictly necessary for the operation of the site.

For other processing, we comply with the retention periods imposed by the laws and regulations in force. If your data is no longer necessary for the provision of our services or if you ask to stop receiving our communications, your data will be irreversibly deleted or anonymised in accordance with our internal policy and the applicable regulations.

9. Your rights

In accordance with the GDPR and the Luxembourg Law of 1 August 2018, you have the following rights over your personal data:

• Right of access and information: you have the right to be informed in a concise, transparent and intelligible manner of the way your data is processed, to obtain confirmation as to whether data concerning you is being processed, to access it and to obtain a copy.
• Right to rectification: you have the right to obtain the rectification of inaccurate data, and to request that incomplete data be completed.
• Right to erasure ("right to be forgotten"): in certain cases, you have the right to obtain the erasure of your data.
• Right to restriction of processing: in certain cases, you have the right to obtain a restriction of the processing of your data.
• Right to portability: you have the right to receive the data you have provided to us in a structured, commonly used and machine-readable format, and to transmit it to another controller. This right applies only to processing based on your consent or on the performance of a contract, and carried out by automated means.
• Right to object: you have the right to object to the processing of your data where it is based on our legitimate interest. We may, however, invoke compelling legitimate grounds requiring the continuation of the processing. You also have the right, at any time and without having to give reasons, to object to the processing of your data for direct marketing purposes.

10. How to exercise these rights

To exercise the rights mentioned above, contact us:

• via our contact form;
• by post to: EDISYS SA, 2, Rue Edmond Reuter, L-5326 Contern.

Please provide the information necessary to process your request: surname, first name, and any information enabling us to confirm your identity (so as to prevent a third party from exercising your rights in your place). We undertake to respond to you within one month of receiving your request, save in cases of particular complexity.

11. Unsubscribing from commercial communications

You may unsubscribe from our commercial communications at any time:

• by clicking the "Unsubscribe" link at the bottom of each newsletter;
• via our contact form with the subject "Unsubscribe".

12. Right to lodge a complaint with the CNPD

If you consider that your rights are not being respected, you have the right to lodge a complaint with the competent supervisory authority:

National Commission for Data Protection (CNPD)
15, boulevard du Jazz
L-4370 Belvaux, Grand Duchy of Luxembourg
cnpd.public.lu

13. Use of cookies

Cookies are small information files that a website may place on your device (computer, tablet, smartphone) through your browser. They are then stored and may be read again during your subsequent visits.

We may use cookies for the following purposes:

• Strictly necessary cookies: essential to the operation of the site (remembering your language choice, securing your browsing). They do not require your consent.
• Audience measurement cookies: allow us to produce anonymised traffic statistics and to improve the relevance of the site. They require your prior consent when placed by third parties.
• Personalisation cookies: allow the site to be adapted to your preferences (user interface, suggested content).

We may also collect your IP address in an abbreviated, non-identifying form for audience measurement purposes.

You may at any time refuse or disable non-essential cookies by configuring the privacy settings of your browser. Please note, however, that restricting cookies may affect your user experience and prevent you from making full use of certain features of the site.

14. Managing cookies by browser

To configure your browser to manage or disable cookies, follow the corresponding instructions:

• Mozilla Firefox: Menu ☰ → "Settings" → "Privacy & Security" → "Cookies and Site Data" section. Official documentation: support.mozilla.org
• Google Chrome: Menu ⋮ → "Settings" → "Privacy and security" → "Third-party cookies". Official documentation: support.google.com/chrome
• Microsoft Edge: Menu ··· → "Settings" → "Cookies and site permissions" → "Manage and delete cookies and site data".
• Safari (macOS / iOS): "Settings" → "Safari" → "Privacy & Security". Official documentation: support.apple.com
• Brave / Opera / other Chromium-based browsers: the procedure is similar to that of Chrome (settings menu → Privacy).

15. Amendments to this policy

EDISYS SA reserves the right to amend this data protection policy at any time, in particular to take account of legislative, regulatory or technical developments. Amendments are published by being posted on this page. We invite you to consult this policy regularly in order to be aware of any changes.

This policy is also available alongside our legal notice.

16. Contact us

For any question relating to this data protection policy or to exercise your rights, contact us:

EDISYS SA (LBO Automobile division)
2, Rue Edmond Reuter, L-5326 Contern
Contact: contact form
Telephone: +352 661 754 747