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Chapter I. Introduction and general information
About us
We, Key Job 65, avenue de la Gare, 1611-Luxembourg, use and store personal data as part of our activities. If you have questions about how we use your data, please get in touch with our data protection delegate:
Key Job SA
Attn.: Data Protection Delegate
65, av de la Gare
1611-Luxembourg
Luxembourg
If you contact us, we will store and process the information provided by you in order to process your request and any follow-up to said request. We are authorized to use this data in this context by the law (article 6(1b) of Regulation (UE) 2016/679). We will delete these information as soon as your request is processed.
Our guiding principles
We take to heart the protection of your information. Your data will be processed with care and in accordance to the applicable data protection regulations. We have taken technical and organizational measures to make sure that all the data we process is safe against risks associated with the process of personal data. Our partners are also committed to these terms.
Chapter II. Our services
What rights do we have to process your data?
We respect your privacy. Hence, we will only process your data when we are allowed to do so. It goes without saying that you can also authorize us to process your data by consenting to data processing on our web site. In other cases, we will process your data because the law allows us to do so. For instance, if you order a service from us, we are authorized to process your data in order to fulfill that order. This also applies when you contact us by phone or email, or when a training manager registers a training for an attendee. In case of complaint, please refer to the last section of this Data Protection page, where you will find your rights.
The next section will cover which authorizations we use and when we use them. You will find more information on how your data is collected, processed and used by our services (type, field of application and object of this data processing) in this section.
You should also know:
Users less than 18 years old can only provide us with their information with the consent of the parents or legal guardian.
Data processing required by our activity
How and when do we process your data (names, addresses, phone number, etc.)?
Customer account creation
Any client or potential client can ask our customer service to have a customer account created. We systematically create an account when an order is placed. The customer is then informed of the account creation and of the data used to do so.
The information we save when creating a customer account are the following:
- Company name
- Registered Business name
- Company address
- Intra-Community VAT number
- Company phone number
- Contact persons names
- Contact persons phone numbers
- Contact persons email addresses
- Billing information
We process your personal data in order to provide customized services in accordance to our contract obligations, or in order to sign a contract with you (article 6(1b) of Regulation (UE) 2016/679). We store customer data until the customers delete their account. Customers with the appropriate authorization can delete their account by contacting our data protection delegate (contact information at the end of this document). We will of course correct any erroneous information on your demand.
The recipients of this data are the accounting and sales department at Key Job.
You have rights in relation to the data in our possession, please refer to Chapter IV User rights for more information.
Registration to a training in our premises
A new customer account is created (if you did not have one) whenever you register to a training in our premises. Additional information about the attendees and the registering person will be collected.
Personal data we collect during the registration process are the following:
- Company name
- Name of the attendee
- Name of the registering person (contact person)
- Phone number of the contact person
- Email address of the contact person
- Billing information
The recipients of these data are the sales, billing and, for the company and attendees' names, the Key Job trainer.
You have rights in relation to the data in our possession, please refer to Chapter IV User rights for more information.
Training in your premises
A new customer account is created (if you did not have one) whenever you place an order for a training in your premises. Additional information about the attendees and the registering person will be collected.
Personal data we collect during the order process are the following:
- Company name
- Address where the training will take place
- Name of the registering person (contact person)
- Phone number of the contact person
- Email address of the contact person
- Name of the person who will receive the trainer (reception person)
- Phone number of the reception person
- Email address of the reception person
- Billing information
The recipients of these data are the sales, billing and, for the company and attendees’ names and the training location, the Key Job trainer.
You have rights in relation to the data in our possession, please refer to Chapter IV User rights for more information.
Coaching, development or consulting
A new customer account is created (if you did not have one) whenever you place an order for a coaching, consulting services or a development. Additional information about the recipient to these services and the registering person will be collected.
Personal data we collect during the order process are the following:
- Company name
- Name of the registering person (contact person)
- Phone number of the contact person
- Email address of the contact person
- Name of the person(s) receiving the service
- Billing information
If these services are to happen in your premises, the following information will also be collected:
- Address of the location where the service will be delivered
- Name of the person who will receive the trainer (reception person)
- Phone number of the reception person
- Email address of the reception person
The recipients of these data are the sales, billing and the consultant or project manager responsible for the service.
You have rights in relation to the data in our possession, please refer to Chapter IV User rights for more information.
Customer satisfaction survey (Evaluation form)
At the end of any given training, attendees are asked to fill in an evaluation form about the training they just participated in. This form lets Key Job rigorously monitor the services we provide and to prevent or, if applicable, mitigate any problem or non-compliance.
The following data are collected when attendees fill in their evaluation form:
- Name of the attendee
- Email address of the attendee
- Name of the attendee’s company
The recipients of these data are the sales, billing and the Key Job trainers. The collected data is stored for 3 years in case of protest or litigation. After these three years, these data are anonymized to be used to statistical ends only (articles 5(1) and 89(1) of Regulation (EU) 2016/679)
You have rights in relation to the data in our possession, please refer to Chapter IV User rights for more information.
Attendance lists and training certificates
During each training, attendees sign an attendance list (one per company).
Data collected in this list are the following:
- Name of the attendee
- Signature of the attendee
- Date and name of the training
- Company name
These data are provided by Key Job to the company ordering the training.
Key Job stores this information for three years, in order to be able to provide training certificates to attendees. The certificates are sent to the attendee asking for them, to their representative or the company they worked for at the time of the training. Key Job does not store the certificates.
Special events attendance
We use data you provide us when you register to special events in order to plan said special events and follow up on them. The data we collect to that end depends on the registration form for said event.
If the event is organized in a private space and if, during the event, photos and videos are captured by Key Job, Key Job will not publish any video or photo without the written consent of any recognizable party in the media.
Attendees can ask to receive information about the data we store about them. You have rights in relation to the data in our possession, please refer to Chapter IV User rights for more information.
We process your data in order to fulfill contract obligations related to your registration to these special events (article 6(1b) of Regulation (EU) 2016/679) and to follow up on said events. This information is deleted once it is not required for planning or follow up.
Image right release
If an event or training is organized in a private space and if, during the event, photos and videos are captured by Key Job, Key Job will not publish any video or photo without the written consent of any recognizable party in the media
The data we collect to that end depends on the release form.
Chapter III. Our web site and newsletters
What kind of data do we always collect on our web site?
You can consult all public parts of our web site www.keyjob.lu without revealing your identity. We systematically collect each use of our web site in order to fix malfunctions and clarify security issues. You will find more information on the data logging in the “How do we process your data” section.
What rights do we have to process your data?
We respect your privacy. Hence, we will only process your data when authorized to do so. It goes without saying that you can also authorize us to process your data by consenting to data processing on our web site. In other cases, we will process your data because the law allows us to do so. For instance, if you order a service from us on our web site, we are authorized to process your data in order to fulfill that order. This also applies when you use other services on our web site that require us to process your data, such as asking for contact by email or phone, or registering to our newsletter. We are also authorized to process your data when we have a legitimate interest to do so. For example, we use connection information in order to ensure that our web site functions properly. In any case, we will inform you if your data is being processed. Your data is always processed with your interests in mind. In case you would want to file a complaint, you will find your data privacy rights at the end of this data protection document.
The next section specifies which authorizations we are using and when. You will find more information about the way we process and use your data on our web site (including type, field of application and the object of the process) in said section.
You also should know:
Users less than 18 years old can only provide us with their information with the consent of the parents or legal guardian.
Our web site may contain links to other web sites. We have no influence on how your data is processed on these other sites. Please take note of all data protection information available at those sites.
Data processing on our web site
How do we process your data (logs, cookies, tracking, etc.)?
Connection data (logs, cookies, tracking, etc.)
Due to technical reasons, every time your web browser connects to our web site, it automatically sends information to our web server (connection data). We save some of these information in log files, notably:
- Connection date
- Connection time
- Source link URL
- Consulted files
- Data volume transferred
- Browser type and version
- Operating system
- IP address
Connection data do not contain private data. We only inspect connection data in order to solve issues with our web site or to clarify security incidents. We store this connection data for an unknown span of time.
We sometimes need to collect private information in addition to connection data in order to solve issues, or keep proofs in case of a security breach. In those cases, we have a legitimate interest to do so (article 6(1f) of Regulation (EU) 2016/679), which is to keep our network and information safe and to resist incidents that would compromise availability, integrity and confidentiality of private data. We delete those data as soon as the incident is solved or the security breach cleared, or if the initial objective of the process does not exist anymore because of other factors. In case of a security breach, we will transmit the connection data to the authorities in charge of the investigation, within the applicable limits.
We always keep connection data separate from the other data collected on our web site.
Creating a contact by email request on our website
You can ask us to contact you by email on our website. We collect and treat the following information as part of the application process:
Required Information:
- First and last name
- Company
- Email Address
- A message you want to send us
Optional information:
- Phone number
- Function
We treat your personal data in order to ensure personalized services, in fulfilment of our contractual obligations or for the purpose of concluding a contract with you (article 6 (1b) of (EU) Regulation 2016/679). We store data from registered users for one month in the database linked to our website.
You have rights in relation to the data in our possession, please refer to Chapter IV User rights for more information.
Creating a phone contact request on our website
You can ask us to call you back on our website. We collect and treat the following information as part of the application process:
Required Information:
- First and last name
- Phone number
- Your time preferences for a phone call
- A message you want to send us
Optional information:
We treat your personal data in order to ensure personalized services, in fulfilment of our contractual obligations or for the purpose of concluding a contract with you (article 6 (1b) of (EU) Regulation 2016/679). We store data from registered users for one month in the database linked to our website.
You have rights to the data in our possession, please refer to Chapter IV User rights for more information.
Creating a training registration request on our website
You can also use our web site to register yourself, or a collaborator, to one of our trainings. We collect and process the following data, whenever a registration request is filled in:
Required information for the training attendee:
- First and last names
- Session for which the subscription is requested
Required information for the registering person:
- First and last names
- Phone number
- Company name
- Company address
Optional information for the registering person:
- Function
- Department
- Intra-Community VAT number
- Postal Code
- City
- Country
- Comment
When you request a registration, we use your information in order to process your demand. We then process your data in order to fulfill our contractual obligations related to your request (article 6(1b) of Regulation (UE) 2016/679). We store the information about your subscription requests for one month on our website. In case the registration is confirmed, your data is transferred to services in charge of the performance of the service and the billing process.
You have rights to the data in our possession, please refer to Chapter IV User rights for more information.
Newsletter
Our web site offers the possibility to subscribe to our newsletter. We use a double-consent process in order to check if the owner of the email address has actually subscribed to the newsletter.
The subscription to the newsletter is effective only if the owner of the email address has expressly confirmed the activation of the newsletter by clicking on the link in the confirmation e-mail. We record the execution of each stage of the double-consent process for evidence purposes.
If you subscribe to our newsletter and consequently agree for it to be sent to you, your information will be exclusively used to deliver that newsletter. We are authorized to process your data in that context with your consent (article 6(1a) of Regulation (EU) 2016/679). You can withdraw that consent at any time. You will find a link to do so at the end of every newsletter. We will remove your subscription from our database.
Cookies
We use cookies on our web site. Cookies are small text files stored on your device when you go to our web site. These cookies are returned to us every time you connect to our site. This allows us, for instance, to recognize you or to facilitate navigation on our site thanks to the data stored therein.
Cookies cannot be used to execute programs or transfer viruses on a computer. Cookies can only be read by the issuing server.
You can also view our web site without cookies. Web browsers often have cookies enabled. If you wish to not use cookies, you have to disable cookies in your web browser’s settings. The help features of your web browser will show you how to enable / disable cookies. Please note that some of our site’s features may not function correctly when cookies are disabled/deleted. Cookies that may be required for our site to function properly are listed below. Moreover, disabling cookies will only affect the web browser they were disabled in. Disabling/deleting cookies must be repeated for every web browser you use.
Cookies we use for certain functions, without private information:
- Cookies storing user preferences (eg site language or search preferences)
- Cookies used to improve audio/video quality
Cookies used for some functions, that include private data:
- Cookies used to store temporarily user input (for instance cart content, form content)
- Cookies used to identify/authenticate the user type (visitor, webmaster…)
We process these data on basis of our legitimate interest (article 6(1f) of Regulation (EU) 2016/679), which allows us to identify or authenticate users of our web site in order to guarantee data privacy for all of these users. This data is stored until the cookie expires or you delete it.
Any other use of private data using cookies is described in the corresponding sections.
Web Analytics using anonymized user profiles
We use Web Analytics tools for different purposes on our website. You will find information on the Web analytics tools we use thereinafter, including a description of the data processing, the purposes of such processing, and how you can prevent the Web analytics tool to collect and process your data. Please note that the installation of refusal cookies can only prevent data collection and processing by the Web Analytics tools to a certain extent. You can find more information about this in the cookies section.
Social media content sharing
Our Web site mentions our last Facebook 'post', as well as buttons that provide access to social networks. All the social networks buttons are integrated using simple hyperlinks instead of the social plugins developed by providers of social networks. This measure helps ensure that your data is not automatically transferred to the social media servers when you visit our Web site. In addition, when you share the content of our Web site, we transmit to the social media only the information which is necessary for the content sharing. We do not transfer any personal data in this context.
At the same time, you will also find simple links to our Web sites on social networks. If you click on a link to a social network on our Web site, or if you connect to your social network account in order to share the content of our Web site, your data is processed by the provider of the social network in question. If you want to get information about the purpose and the scope of the data collection, any processing and any use by the provider of the social network, as well as setting options and your privacy protection rights, please refer to the Data Protection information provided by the supplier.
Localize our premises with Google Maps
One of the features of our web site lets you view the location of our offices. We use Google Maps to display this map. Google Maps is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. You will find information about how Google processes private data via the following link: http://www.google.fr/intl/en/policies/privacy/
When do we transmit your data?
We work with service providers in order to operate our web site. We have selected these providers with care and have reached an agreement regarding data privacy with each of them in order to guarantee the security of your information.
The service providers we use to operate our web site are the following:
- Web hosting service provider
- Development service provider
We communicate your data to other recipients only when this is required to execute a contract with you, when we or these recipients have a legitimate interest in this disclosure or when you authorize us to do so. These recipients include service providers or other Key Job entities, most notably Key Job Belgium. Moreover, your data can be communicated to other recipients if we are obliged to do so because of legal dispositions, enforceable justice or administrative decisions.
The other possible recipients of your data are the following:
- Training, coaching, consulting and development service providers subcontracting for Key Job
- Debt collector service providers
Chapter IV. User rights
Your rights
If you want to file a complaint, you will have a glimpse at your rights below. To claim your rights, please contact the person listed at the end of this document.
Your right to be informed about your data
We will provide you, on demand, with information in our possession on private data about you.
Your right to correct and complete your data
We will correct erroneous information about you, if you inform us. We will complete incomplete data if you inform us, if these data are required for the ends of the data processing.
Your right to delete your data
We will delete your private data, when asked. Some data will only be deleted after a retention time – for instance legal, or because we need this data to fulfil a contract with you.
Your right to block your data
In some circumstances (as written in the law), we will block your data on your demand. Processing blocked data is very restricted by the law.
Your right to remove consent
You can remove the right you gave us to process your data at any time, with no retroactive effect. We will stop processing your data, as long as there is no imperious and legitimate reason to process them later, this will not affect the previous processing.
Your right to oppose the processing of your private data
You can oppose to the processing of your data at any moment, with no retroactive effect, if we process your data based on our legitimate interests (article 6(1f) of Regulation (EU) 2016/679). In case of opposition, we will stop processing your data, as long as there is no imperious and legitimate reason for later processing. Marketing is never an imperious and legitimate reason.
Your right to data portability
At your request, we can provide with a machine-readable file in a structured format that contains all your data.
Your right to appeal to a data protection authority
You can file a recourse about data protection to a data protection authority. To do so, please contact the data protection authority in charge of your country or the data protection authority in Luxembourg: https://cnpd.public.lu/en.html .
Your person of contact for any question about data protection
If you have questions about data protection or to exercise your rights, please contact our data protection delegate:
Key Job SA
Attn. Data Protection Delegate
65, av de la Gare
1611-Luxembourg
Luxembourg
Last update to this document
Valid from: 25/05/2018