Information notice on the protection of personal data
The protection of your personal data is a key priority for the E2M S.à r.l. law firm. (hereinafter "E2M"). This notice explains the purpose of data processing and how we use your personal data. We invite you to carefully read the following.
1. Data Controller
In accordance with the applicable regulations, E2M is responsible for the processing of data concerning you and which we collect. As such, we are responsible for the way in which this data is processed, transmitted and stored.
2. Categories of processing
E2M is already your legal counsel or is intended to become your legal counsel to assist you or, where appropriate, to provide legal services for your benefit or that of third parties. In order to carry out our mission of legal advice, we are required to collect some of your personal data.
Depending on the type of intended purpose, the categories of processed data are as follows:
- personal identification data (surname, first name, address(es), telephone number, date of birth, gender, nationality, identity document or other administrative identifiers, signature…);
- electronic identification data in case of access granted to E2M applications (IP address, e-mail address,...);
- financial data (account number, income);
- data relating to civil or professional status (marital status, family composition, profession, etc.);
- data relating to property (housing, vehicles, etc.);
- data relating to ongoing disputes;
In some cases, we also deal with "special categories of data" within the meaning of European regulations, such as those concerning health, offences or convictions.
In any case, E2M ensures that only adequate and relevant data is collected, processed and kept for the declared purposes.
No legal provision obliges you to provide us with the personal data we request but, if you do not provide us with such data, we may be unable to provide the services you request, to offer you services that may be of interest to you, to adapt our offers to your needs.
3. Collection and use of personal data
We collect and use the personal data that you provide to us or that we receive from your counsel or legal representative for the purposes mentioned below.
We collect and process your personal data exclusively for the following purposes:
- assessment of the legal situation,
- management of the business relationship with you or business partners, via the Internet and social networks, including the promotion of our insurance products,
- the transmission of information relating to your situation,
- For each of the purposes listed above, the collection and processing of data is :
- carried out in accordance with the regulations on the protection of personal data, including European Regulation (EU) 2016/679 of 27 April 2016,
- legally founded :
- either on the fact that the processing is necessary for the performance of a contract to which you are a party or for the performance of pre-contractual measures taken at your request;
- or that the processing is necessary for the fulfilment of a legal obligation to which we are subject;
- or upon your consent;
- a legitimate interest recognized by us (prevention of fraud, assessment of a legal situation).
If you send us data concerning your legal situation on your own initiative or at our request, this means that you expressly consent to their processing within the limits and in accordance with the terms and conditions specified in this notice.
4. Who has access to your personal data?
We will ensure that your personal data is processed in a way that is compatible with the purposes stated above.
This data is shared with some of our departments within the strict framework of the missions entrusted to them. Within the limited framework of the aforementioned purposes and insofar as necessary, we also share your personal data with your intermediary, the banking institution, auditors, accountants, experts, legal advisors and with the competent Luxembourg or foreign administrations.
5. Processing locations for personal data
Your data is processed at E2M. For reasons of security and backup of your data, they are also transferred to an approved Digitalisation and Conservation Service Provider located in Luxembourg, which is also in charge of their backup. For these transfers, E2M has put in place very binding agreements in compliance with European Regulations, which are a concrete expression of our commitment to adequately protect the processing of your personal data.
6. What are your rights with regard to your personal data?
Where permitted by the applicable regulations, you have the right to :
- to access the data we store about you,
- to have it rectified if it is inaccurate or incomplete,
- to have them erased in certain circumstances such as, for example, when they are no longer necessary for the purpose for which they were collected and processed and if we have not already done so in application of our data retention policy,,
- to obtain the limitation of processing in certain circumstances, such as limiting the use of data whose accuracy you dispute during the period when we need to verify it ,
- to file a complaint with the competent data protection authority in your country and/or the Grand Duchy of Luxembourg (Commission Nationale pour la Protection des Données - CNPD),
- to object to the processing if such processing is based solely on the pursuit of our legitimate interests,
- to the portability of your personal data, i.e., the right to receive the personal data you have provided us with in a structured, commonly used and readable format or to have them forwarded directly to another data controller,
- to withdraw your consent to the processing of your data at any time, without this compromising the lawfulness of the processing based on the consent given prior to such withdrawal and save where the processing is based on a legal basis other than the sole consent.
To exercise these rights, you need only follow the procedure mentioned in point 9 below.
7. Objection to the data processing?
If permitted by applicable law, and in particular if the processing is solely justified by the pursuit of our legitimate interests, you have the right to object to the processing of your personal data or to prohibit us from processing them (including for direct marketing purposes). Once you have informed us of this request, we will no longer process your personal data, unless we are permitted to do so by law.
You can exercise this right in the same way as for your other rights by following the contact procedure mentioned in point 9 below.
8. How long will personal data be kept?
We will retain your personal data for as long as it is necessary for the fulfilment of the above-mentioned purposes or as long as required by law. The storage period for contractual data ends at the end of the statutory limitation period following the closure of your file with the law firm.
9. Exercising your rights
You may address your questions concerning the processing of your personal data and exercise your rights mentioned above to the Data Protection Officer (DPO) either by e-mail to firstname.lastname@example.org or by post to: E2M S.à r.l., 2, rue du Fort Rheinsheim, L-2419 Luxembourg, Grand Duchy of Luxembourg. We will reply to you personally. A copy of both sides of your valid identity document must also be sent to us.
Any complaint concerning the processing of your personal data may be sent to the postal and e-mail addresses mentioned above or to the data protection authority, namely for Luxembourg Commission Nationale pour la Protection des Données (CNPD), 1, Avenue du Rock'n'Roll, L-4361 Esch-sur-Alzette, Grand-Duchy of Luxembourg (www.cnpd.lu).
10. Update of this notice
In order to comply with the regulations in force, E2M undertakes to update this notice whenever necessary. The latest version is systematically put online on our website.
After having read the information notice on data protection mentioned above, which is also available on the website www.e2m.lu.