The purpose of this Privacy Notice is to inform you of the processing of your personal data (as defined in the regulation 2016/679 on the protection of natural persons with respect to the processing of personal data and on the free movement of such data (the” Regulation” or “GDPR”) and your rights in that respect.
We process your personal data in compliance with any data protection law applicable in Luxembourg and in particular the law of 2 August 2002, as modified, and any subsequent legislation, and as from 25 May 2018, the Regulation (together the “Data Protection Legislation”).
The reference to “we” or “us” or “our” in this Privacy Notice, refer to 1535° Creative Hub.
1. Legal information
The Privacy Notice is provided to you by 1535° Creative Hub as data controller with respect to the personal data collected through the Website.
1535° Creative Hub Differdange
115, rue Emile Mark
Grand Duchy of Luxembourg
The user may exercise the rights set out in section 7 by written request to be sent to: firstname.lastname@example.org (the “Contact Email”).
2. What data do we process?
As user of the Website, you are informed that 1535° Creative Hub collects and processes personal data, such as your IP address (or any device ID) and email and other personal data that you would provide to us by sending us an email;
(the “Disclosed Personal Data”).
When a user contacts 1535° Creative Hub, the Personal Data is collected directly through the email belonging to 1535° Creative Hub. Moreover, 1535° Creative Hub can also collect Personal Data by using social media networks such as Instagram or Facebook or other public online.
(Disclosed Personal Data and Collected Personal Data shall be referred herein as “Personal Data”)
To the extent possible, please ensure when sending a request to our Contact Email not to include any personal data that is not absolutely necessary for the management of or dealing with your request addressed to us via the Website. Please be particularly careful not to include sensitive personal data (e.g. related to political opinion, religious or philosophical convictions, trade union membership, etc.) about you or other related persons in the content or attachment of your request. Where information of another natural person is included in a correspondence send to us, we assume that the user processes that personal data lawfully and has informed and received consent from the concerned person that his/her personal data would be shared with 1535° Creative Hub and has provided a copy of the present Privacy Notice to such concerned person.
If you deliberately include such sensitive personal data or personal data that would not be necessary for managing your request in the content or attachment of your email, you acknowledge and consent that 1535° Creative Hub may have to process such type of data when reviewing and dealing with your request and that such data may be stored by 1535° Creative Hub.
3. We process your Personal Data lawfully
1535° Creative Hub will only process your Personal Data for purposes related to the management of your request sent to us via our Contact Email.
The legal grounds for such processing of your Personal Data depend on the nature of the request.
Thus the grounds for such processing of your Personal Data are that such processing are (combined or separately as applicable):
- necessary for the performance of pre-contractual measures when entering into discussions with any user, and/or,
- necessary for satisfying 1535° Creative Hub’s legitimate interests such as seeking maximum efficiency (including administrative, internal analysis, organisational and technical measures and IT efficiency and security) of a continuous functioning of the Website.
To the extent Personal Data is directly provided in your contact email we consider that you have consented (or obtained consent from a concerned data subject) to provide us with such Personal Data for the purpose of managing and following up on your request.
4. We share your Personal Data to the relevant recipients
Your Personal Data will be accessible to:
- The authorised staff of 1535° Creative Hub,
- 1535° Creative Hub’s IT infrastructure, Ville de Differdange’s IT infrastructure,
- The authorised staff of our hosting partner Infomaniak, located in Switzerland. Infomaniak agrees with the terms of the RGPD of 25th May 2018 and has a ISO 27001 certification. Logs collected by Infomaniak are stored up to 11 days.
- The authorised staff of our web agency Explose Sàrl located in Luxembourg
5. Your Personal Data is transferred
Customary Personal Data means your name, family name, title, email address, company name.
6. How is your Personal Data retained?
All Personal Data related to the user shall not be retained longer than the time required for satisfying the aforementioned purposes, subject to the legal periods of limitation and to the situations where the applicable laws authorise or require that the Personal Data be retained for a certain period of time after the termination of a relationship.
For the performance of pre-contractual steps when entering into discussions with you, based on our offer of services or for managing a job application, your Personal Data is processed only for the duration of time which is needed by 1535° Creative Hub to manage such request and during our subsequent potential contractual relationship that may derive from your initial request as the case may be.
Where no contractual relationship derives from such initial request:
The processing and storage of your Personal Data can last up to a three-year period starting from their collection by 1535° Creative Hub or from the last contact with you (as the case may be);
In any case, you remain entitled to unsubscribe (opt-out) at any time to the reception of the newsletters and/or other marketing communications.
Where the user has otherwise entered into a relation with 1535° Creative Hub, the data protection provisions relating to that relationship shall apply in addition to the present terms applying in your capacity as user of the Website.
7. Your rights and how to exercise your rights
Subject to the conditions of the Data Protection Legislation, the user may request from 1535° Creative Hub any of the following:
- (a) right to access his/her Personal Data (i.e the right to obtain from 1535° Creative Hub confirmation as to whether or not personal data concerning the user is processed, and, where that is the case, access to the personal data and relevant information in that regard),
- (b) rectification of his/her Personal Data (i.e the right to obtain from 1535° Creative Hub without undue delay the rectification of inaccurate personal data concerning the user (subject to providing satisfactory evidence to that effect) and taking into account the purposes of the processing, the right to have incomplete personal data completed),
- (c) erasure of his/her Personal Data,
- (d) restriction of the processing of his/her Personal Data (i.e the marking of stored personal data with the aim of limiting their processing in the future),
- (e) right to object to the processing of the Personal Data (i.e the right to object, on grounds relating to the user’s particular situation, at any time to processing of personal data concerning him or her which is based on satisfying the legitimate interests pursued by 1535° Creative Hub. Should this right be exercised, 1535° Creative Hub shall no longer process the Personal Data unless 1535° Creative Hub demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the user or for the establishment, exercise or defence of legal claims),
- (f), where relevant, as from May 25th 2018, right to request the portability of his/her Personal Data (i.e the user is allowed to receive personal data concerning him or her which he or she has provided to 1535° Creative Hub in a structured, commonly used, machine-readable format, and to transmit it to another controller).
Moreover, to the extent processing happens on the basis of the consent, you have the right to withdraw your consent at any time. Such withdrawal will impact the services that 1535° Creative Hub shall be able to provide.
The user can exercise the above-mentioned rights by contacting: email@example.com
The user also has the right to lodge a complaint or a notice of an alleged infringement to the GDPR with a supervisory authority, in particular in the Member State of his/her habitual residence, place of work (the supervisory authority is the “Commission Nationale pour la Protection des Données” in Luxembourg).