Privacy Policy

1. Introduction

CSC Tech ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website csc-tech.lu (the "Site"), in compliance with:

• Regulation (EU) 2016/679 — General Data Protection Regulation (GDPR)
• Luxembourg Law of 1 August 2018 on the organisation of the CNPD

2. Data Controller

3. Information We Collect

We may collect the following categories of personal data:

• Automatically collected data: IP address, browser type and version, operating system, referring URLs, pages visited, access times, and device information, collected through server logs.
• Voluntarily provided data: Name, email address, company name, phone number, and any other information you provide when contacting us via email or other communication channels. The contact form on the Sense App page only opens your email client with a pre-filled message: the website does not receive or store what you type until you send that email.
• Cookies and similar technologies: None. See Section 8.

4. Purpose and Legal Basis for Processing

In accordance with Article 6 of the GDPR, we process your personal data for the following purposes:

5. Data Sharing and International Transfers

We do not sell, rent, or trade your personal data. We may share your data with:

• Service providers: Trusted third parties who assist us in operating the Site (hosting, email), subject to data processing agreements compliant with Article 28 GDPR.
• Legal requirements: When required by law, regulation, or legal process.

If personal data is transferred outside the European Economic Area (EEA), we ensure adequate safeguards are in place in accordance with Chapter V of the GDPR, including Standard Contractual Clauses (SCCs) approved by the European Commission.

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Specific retention periods:

• Contact enquiries: up to 12 months after last communication
• Server logs: up to 30 days
• Legal obligations: as required by Luxembourg and EU law

When data is no longer needed, it is securely deleted or anonymised.

7. Your Rights

Under the GDPR (Articles 15–22), you have the following rights:

• Right of access (Art. 15 GDPR): Obtain confirmation and a copy of the personal data we hold about you.
• Right to rectification (Art. 16 GDPR): Request correction of inaccurate or incomplete data.
• Right to erasure (Art. 17 GDPR): Request deletion of your personal data under certain conditions.
• Right to restrict processing (Art. 18 GDPR): Request limitation of processing in certain circumstances.
• Right to data portability (Art. 20 GDPR): Receive your data in a structured, commonly used, machine-readable format.
• Right to object (Art. 21 GDPR): Object to processing based on legitimate interests or direct marketing.
• Right not to be subject to automated decisions (Art. 22 GDPR): Not be subject to decisions based solely on automated processing, including profiling.

Voluntary provision and DPO: Providing personal data is voluntary. We have not appointed a Data Protection Officer.

How to exercise your rights: Send your request to [email protected]. We will respond within one month in accordance with Article 12(3) GDPR.

Right to lodge a complaint: You have the right to lodge a complaint with:

• Commission nationale pour la protection des données (CNPD) — Luxembourg: cnpd.public.lu, 15 boulevard du Jazz, L-4370 Belvaux

8. Cookies Policy

In accordance with the Luxembourg Loi du 30 mai 2005 relative à la protection de la vie privée dans le secteur des communications électroniques and the EU ePrivacy Directive (2002/58/EC), we inform you that this website does not use cookies or similar tracking technologies.

Should this change, we will request your prior consent before any non-essential cookie is set and update this policy.

9. Security Measures

In accordance with Article 32 of the GDPR, we implement appropriate technical and organisational measures to protect your personal data, including:

• SSL/TLS encryption for all data in transit
• Access controls and authentication mechanisms
• Regular security reviews
• Data minimization practices

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or applicable legislation. Any changes will be posted on this page with an updated revision date. Where changes are material, we will take reasonable steps to notify users.

11. Contact

For any questions about this Privacy Policy or to exercise your data protection rights:

Email: [email protected]
Address: 136, Rue Principale, L-5366 Munsbach, Luxembourg