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.
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.
*The Personal Data we collect and process may include the following, but is not limited to:
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.
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. *
Information that we automatically collect when you use our Website: when you use our Website, we automatically collect, through Cookies, the following information:
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:
Personal Data that we collect when you apply online for employment: please refer to the HR section.
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:
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.
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:
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.
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:
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.
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.
IEE will only retain your Personal Data:
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.
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.