Privacy Policy

1. Introduction

IEE collects data to operate effectively and provide you (any Data Subject in relation with IEE) with the best products and services. This is why, at IEE we are highly committed to safeguarding your privacy. We have developed a Privacy Policy that covers how we may collect, use, share, protect and keep information about you as well as the rights to which you are entitled in this respect, in accordance with the Data Protection Law.
Please take a moment to familiarize yourself with our privacy practices.


Link to definitions

“Binding Corporate Rules”: internal codes of conduct implemented within the entities of the IEE group allowing entities of the IEE group, located in the European Economic Area or in a country covered by an adequacy decision issued by the European Commission, to transfer Personal Data to other entities within the IEE group, located outside the EEA or in a country not covered by an adequacy decision issued by the European Commission. Those Binding Corporate Rules contain privacy principles, tools of effectiveness (audit, training, etc.) and elements proving that the rules are binding. They are approved by the Luxembourg data protection supervisory authority (the “CNPD”). 

“Data Protection Law”: Regulation (EU) 2016/679 of 27 April 2016 and any applicable national data protection legislation.

“Client”: any recipient of our products or services, who may be an individual person or an employee, director, officer or representative of a company or intermediary client at IEE.

“Data Subject”: any identified or identifiable natural person. 

“IEE”, “we” or “us”: IEE International Electronics & Engineering S.A., having its central administration at ZAE Weiergewan, 11, rue Edmond Reuter, L-5326 Contern, with registered office at 12 rue Pierre Richardot, L6468 Echternach, Grand-Duchy of Luxembourg, or any of its subsidiaries or affiliates, details of which can be found on www.iee.lu. Together these are referred to as “IEE Group”.

“(IEE) Products and Services”: the products and services that we offer to our Clients, including through our related support.

“Personal Data”: any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, IEE (or its representatives or service providers). In addition to factual information such as name or address, it could include an expression of opinion.

“You”: each Data Subject to whom this notice is addressed, who may be a Client or prospective Client of ours, a visitor to the IEE website, an employee, director, officer or representative of another organization with which we have a business relationship, or any other Data Subject whom we may be in relation with.



2. What information we collect

To provide its Products and Services, IEE needs to collect and process certain information about you*. In this respect, the IEE entity determining the purposes and means for the processing of your Personal Data will act as data controller of your Personal Data. The Personal Data we collect depends on the context of your interactions with IEE, the choices you make including the Products and Services which are provided to you.

It is to be noted that you have choices about the Personal Data we collect. When you are asked to provide Personal Data, you may decline. If you choose not to provide Personal Data that is necessary to provide the Product or Service, we may not be able to deliver the Product or Service.

3. Categories of Personal Data processed

*The Personal Data we collect and process may include the following, but is not limited to:

  • Identification data: we collect Personal Data about you such as your first and last name, email address, postal address, phone number, and other similar contact data, date and place of birth, gender, country, and preferred language; 
  • Business contact information: we collect Personal Data about you such as job function, job title, department, organization name, size and location, and whether or not you are acting on behalf of a client;
  • Financial information: we collect your financial information, such as financial account information, if needed to make payment or fulfil contractual obligations or for related purposes;
  • Contractual information: any information provided by you allowing IEE to perform its contractual duties.
  • Testing information: any information provided by you enabling IEE to perform necessary tests in the context of IEE Products and Services development.

Further to the categories of Personal Data mentioned above, IEE guarantees that, except to the limited extent that may be necessary in the context of employment and in the context of performing a contract, notably related to the use of test persons in our Products and Services designing phase, we neither request nor collect special categories of Personal Data (i.e., personal information specifying criminal offences/convictions, medical or health conditions, biometric or genetic data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual).

Further information about the Personal Data processed in the context of applications for a position at IEE may be found in the HR section.

4. How we collect data

This Privacy Policy applies to Personal Data, which is information that IEE collects from you and other third parties that specifically identifies you as an individual. IEE may collect your Personal Data in various manners. *

5. Ways of collecting data

Information that we automatically collect when you use our Website: when you use our Website, we automatically collect, through Cookies, the following information: 

  • Recalling if you visited the Website before. If you are a first-time user, you might see different content compared to a regular user.
  • Remembering your preferences and settings, including marketing preferences
  • Remembering your specific preferences, such as if you filled in a survey, so you are not asked to do it again.
  • Gathering anonymous statistics about users (only high-level information like country, repeated visits…).

Personal Data that we collect when you do business with IEE and/or when you enter into a contractual relationship with IEE: we may collect and process your Personal Data when you conduct business and/or enter into a contract with us (identification and contact details). 

Personal Data we obtain from other sources: we also may periodically obtain both personal and non-personal information about you from IEE’s subsidiaries, affiliates, business partners or other third-party sources where they are legally permitted to share such information with us, and add it to the information we already hold about you, such as, but not limited to:

  • Updated business address information; 
  • Identification data;
  • Financial information;
  • Contractual information;
  • Testing information.

Personal Data that we collect when you apply online for employment: please refer to the HR section.

6. Purposes for collection, use and processing of Personal Data

For processing to be lawful under the Data Protection Law, a lawful basis needs to be identified before processing Personal Data.

We use or may use your Personal Data for the following purposes (or as otherwise described at the point of collection) in line with the lawful basis provided under the Data Protection Law:

  • To provide you with the Product or Service you have requested; 
    • Processing is necessary for the performance of a contract with the Data Subject and/or for the legitimate interests of IEE.
  • To provide you with information, access to resources or other Products or Services that you have requested from us on behalf of your organization;
    • Processing is necessary for the performance of a contract with the Data Subject and/or for the legitimate interests of IEE.
  • To send you client service-related communications (marketing); 
    • Processing is necessary for the purposes of the legitimate interests pursued by IEE.
  • To deal with communications that you send to IEE and responding to your queries, requests and complaints; 
    • Processing is necessary for the performance of a contract to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into a contract; and/or
    • Processing is necessary for compliance with a legal obligation; and/or
    • Processing is necessary to achieve the legitimate interests of IEE. 
  • To fulfil our legal obligations namely in respect to our social, accounting and corporate obligations
    • Processing is necessary for compliance with a legal obligation.
  • To manage the infrastructure and business operations of IEE and to comply with internal policies and procedures; 
    • Processing is necessary for the purposes of the legitimate interests pursued by IEE or by a third party.
  • To comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities. 
    • Processing is necessary for compliance with a legal obligation.

In certain cases, we may also collect your explicit consent and rely upon such consent as a lawful basis for processing, for instance when we process special categories of Personal Data. 

We may contact you by mail, telephone, fax, video conference, email or other electronic messaging service to notify you about special events, new features or other information that may be of interest to you in accordance with your interaction with IEE. Where required by applicable law, your prior consent will be obtained before sending you direct marketing and you may object or opt out of receiving marketing messages from IEE. 

IEE does not in any way sell, lease or rent your Personal Data to third parties.

7. Disclosure of your Personal Data

Service providers: we may disclose/transfer your Personal Data to third parties that we refer to as service providers solely to the extent necessary to enable such service providers to provide products or services to IEE and to assist us in providing Products or Services to you. IEE’s policy is to maintain contracts with all third parties with whom we disclose/transfer Personal Data that restrict their access, use and disclosure of Personal Data. Service providers must, in fact, abide by our data privacy and security requirements and are not allowed to use Personal Data they receive from us for any other purpose.

Third parties: we may disclose/transfer your Personal Data to third parties such as administration and public authorities, banking institutions, and to professional advisors and auditors of IEE. 

Affiliates/branches/subsidiaries: we may disclose/transfer your Personal Data, as provided in our General Terms & Conditions, to other companies under common ownership or control with IEE who will process your Personal Data in a manner consistent with this Privacy Policy.

Safety, security and compliance with law: we will access, transfer, disclose and preserve Personal Data to comply with applicable law or respond to subpoenas, court orders or other valid legal process, for reasons relating to national security, to defend against legal claims, to protect the rights and safety of IEE, IEE’s clients, employees or others. This may involve the sharing of your Personal Data with law enforcement, government agencies, courts and other organizations.

The above recipients may process your Personal Data as data processors, i.e., under our instructions. They may also process your Personal Data as independent data controllers, i.e. for their own legal obligations. In the latter case, they bear all responsibility in terms of data protection.

Consent: we may share your Personal Data in other ways and for new purposes if you have asked us to do so and have consented to such sharing.

IEE shares your Personal Data as necessary to provide any Product and/or Service you have requested or authorized.

IEE may also share your Personal Data with your consent namely for the following purposes:

  • Recruitment;
  • Testing.

Recipients may be located in and outside the European Economic Area. Your Personal Data will not be transferred to any country outside the European Economic Area which does not ensure an adequate level of protection unless you gave us prior authorization to do so or specific measures (such as adequate contractual arrangements) have been taken by us in order to ensure that the requirements of the Data Protection Law have been fulfilled.

Where Personal Data is transferred/disclosed to IEE’s affiliates/branches/subsidiaries located outside the EEA, such transfer is based on specific measures, specifically Binding Corporate Rules.

8. Your rights and how to exercise them

IEE seeks to ensure that you are able to exercise your rights at any time. IEE will address any request within the limits of its technical and organizational means and to the fullest extent required under the Data Protection Law.

These include:

  • Right to access your Personal Data: should you want to review the Personal Data we hold, collect and process about you, please let us know by using the contact information provided in the section “HOW TO CONTACT US” of this policy. 
  • Right to rectification: should the Personal Data we hold, collect and process about you be inaccurate or incomplete, you have the right to update such Personal Data at any time by contacting us by using the contact information provided in the section “HOW TO CONTACT US” of this policy. 
  • Right to erasure: if at any time you decide you do not want us to retain any Personal Data we collected from you, you may request we delete your Personal Data by contacting us by using the contact information provided in the section “HOW TO CONTACT US” of this policy. We will take reasonable measures to comply with your request in accordance with applicable laws. 
  • Right to restriction of processing: should you wish to exercise this right (i.e. the right to obtain that, under certain circumstances, the processing of your Personal Data should be restricted to storage of such Personal Data unless your consent has been obtained), please contact us by using the contact information provided in the section “HOW TO CONTACT US” of this policy. 
  • Right to object: should you wish to exercise this right (i.e. the right to object, on grounds relating to your particular situation, to the processing of your Personal Data, unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or that we need to process the Personal Data for the establishment, exercise or defense of legal claims), please contact us by using the contact information provided in the section “HOW TO CONTACT US” of this policy. We will consider your objection and we will comply with it unless we have a compelling legitimate ground as permitted by applicable law. This right may always be exercised in the case of direct marketing. 
  • Right to data portability: you have the right to have your Personal Data transmitted directly from us to another data controller only when you have asked us to do so and have consented to such sharing, and when technically feasible. Should you wish to exercise this right, please contact us by using the contact information provided in the section “HOW TO CONTACT US” of this policy.
  • Right to lodge a complaint with the supervisory authority:  you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”) or with the data protection supervisory authority competent in your EU Member State of residence, where you believe that your Personal Data is being processed in a way that does not comply with the Data Protection Laws.

9. How we protect your Personal Data

IEE acknowledges your trust and is committed to protecting the Personal Data you provide to us. We endeavour to protect Personal Data by using adequate security measures (maintained and improved over time in line with legal and technological improvements) and by putting in place contractual limitations on the use of the Personal Data, as the case may be.

10. Notification of Personal Data breach

IEE will notify you of any Personal Data breach by IEE, its processors, or any other third-parties acting on IEE’s behalf without undue delay, only where the Personal Data breach is likely to result in a high risk to your rights and freedoms.

11. Retention period of Personal Data

IEE will only retain your Personal Data:

  • For as long as it is necessary for the purpose or purposes for which its processing was intended;
  • For the duration of our contractual relationship with you or the organization that you represent;
  • For as long as required or permitted by law.

12. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy from time to time to reflect changes in the Data Protection Law, our data collection and used practices, and to ensure it is accurate, complete and up-to-date. You are advised to check this Privacy Policy from time to time.

13. How to contact us

If you have any questions or concerns about our use of your Personal Data or regarding our Privacy Policy, you may contact us by sending an email to  

HR 

Personal Data that we collect when you apply online for employment: you may submit Personal Data to be considered for employment at IEE. Such information includes, amongst others, your name, your address, your phone number, your email address, experience, education, job skills and other information contained on your curriculum vitae (CV) and/or your cover letter. IEE uses such Personal Data solely for consideration of your candidacy for employment, to communicate with you and to generate related correspondence, including offer letters and employment contracts. Such data may also be used, subject to applicable local laws, to conduct necessary background checks for compliance and other employment related purposes (including the assessment of your profile in view of the conclusion of a potential employment contract, to the extent permitted by applicable laws and regulations). Finally, IEE only retains such Personal Data for as long as necessary to address your employment application and any questions that may arise regarding your application’s processing. 
 

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