This Data Privacy Policy serves exclusively the purpose of meeting our duty to provide information under data protection law. This Data Privacy Policy provides you with detailed information about the following points:

– Who we are and how you can contact us;
– Which categories of personal data we process, the sources from which we obtain data, our purposes in processing personal data and the legal basis on which we do so;
– The recipients to whom we send personal data;
– How long we store personal data;
– The rights you have concerning the processing of your personal data.

1. DATA CONTROLLER AND CONTACT DETAILS

Who we are and how you can contact us:

EFS Holding S.A.

19, Rue de Bitbourg
L-1273 Luxembourg
Tel.: +32 479 74 56 25
Fax: +35 227 44 93 80

E-mail: info@elbe-financial.com

Internet: www.elbe-financial.com

2. DATA CATEGORIES AND PURPOSE

Which data categories we process and for what purpose

2.1 Legal basis
The EU General Data Protection Regulation has been created to give a legal right to the protection of your personal data. We process your data exclusively on the basis of the statutory provisions.

2.2 The data we process and the sources from which we obtain them.
We process personal data disclosed to us in connection with our business activities by employees, job applicants, customers, owners of our products, distributors, suppliers, prospective customers with an interest in our products and our company details, as well as other business associates; such data are address and contact details (including phone numbers and email addresses) and job-related data (e.g. the specialism in which you work): name, address, email address, phone number, fax number, job title and workplace. We do not process sensitive (“special”) data categories, with the exception of data of employees in EFS Holding S.A. and job applicants.

2.3 Our purposes in processing personal data
We process personal data for the following purposes:

– Business relations with our customers and suppliers
– Registration of our products
– to send information to our shareholders
– to send information to prospective customers interested in EFS Holding S.A.
– to meet official and legal requirements
– to receive information via our contact forms
– for Human Resource purposes
– to select job applicants

3. ELECTRONIC COMMUNICATION RECIPIENTS

Recipients to whom we send personal data

When we have received data for the purpose of processing, we never send those data to third parties without obtaining the express consent of the data subject or without expressly announcing such data transfer.

3.1 Data transfer to external processors
We only send data to external processors if we have concluded with them an agreement that meets the legal requirements for contracts with processors. We only send personal data to processors outside the European Union if there is a guarantee that their level of data protection is appropriate.

4. RETENTION PERIOD

How long we store personal data

We erase personal data as required by the legal basis on which we conduct data processing. If we store your data on the basis of your consent, we erase them after the retention periods communicated to you or as requested by you.

5. RIGHTS OF DATA SUBJECTS

Rights to which you are entitled. As a data subject affected by data processing, you are entitled to the following rights under data protection law:

– Right to information: On request, we will provide you with free information about the extent, origin and recipient(s) of stored data and the purpose of storage. Please scroll down to find the requests of information form. If requests for information are excessively frequent (i.e. more than twice a year), we reserve the right to charge an expense reimbursement fee.

– Right to rectification: If incorrect information is stored despite our efforts to maintain accurate and up-to-date data, we will correct it at your request.

– Erasure: Under certain conditions you are entitled to erasure, for example if you have presented an objection or if data have been collected unlawfully. If there are grounds for erasure (i.e. if there are no statutory duties or overriding interests against erasure), we will affect the requested erasure without undue delay.

– Restriction: If there are justified reasons for erasure, you may also use those reasons to request a restriction of data processing instead;
in such a case the relevant data must continue to be stored (e.g. for the preservation of evidence), but must not be used in any other way.

– Objection/revocation: You have a right to object against data processing conducted by us if you have a legitimate interest, and if data processing is conducted for direct marketing purposes. Your right to object is absolute in its effect. Any consent you have given may be revoked in writing at any time and free of charge.

– Data portability: If, after giving us your data, you want to transmit them to a different data controller, we will send them to you in an electronically portable format.

– Right to lodge a complaint with the data protection authority:
Please also note that you have a right to lodge a complaint with the data protection authority: You are entitled to complain to a supervisory authority, in particular in the member state of your place of residence, your workplace or the place of the suspected violation, if you believe that the processing of your personal data has breached GDPR. However, you are also welcome to contact us directly at any time.

6. CONTACT FORM

Your details, including personal data communicated through our contact forms, are sent to us via our own mail server for the purpose of answering your enquiries and are then processed and stored by us. Your data are only used for the purpose specified on the form and are erased no later than 6 months after the conclusion of processing.

7. NOTE ON SECURITY

We endeavor to take all possible technical and organizational measures to store your personal data in such a way that they cannot be accessed by third parties. When communicating by email, complete data security cannot be guaranteed, and we therefore recommend that you send confidential information by surface mail.

8. CHANGES TO THIS DATA PRIVACY POLICY

We may review this Data Privacy Policy from time to time, if appropriate. The use of your data is always subject to the relevant up-to-date version, which can be called up at www.elbe-financial.com/privacypolicy.
We will communicate changes to this Data Privacy Policy via www.elbe-financial.com/privacypolicy or, if we have a business relationship with you, by email to an email address associated with your account.

We will be pleased to help if you have any questions on this Data Privacy Policy or on any of the points raised above. Feel free to contact us in writing at any time, using the following surface mail address:

EFS Holding S.A.

19, Rue de Bitbourg
L-1273 Luxembourg
Tel.: +32 479 74 56 25
Fax: +35 227 44 93 80
E-mail: info@elbe-financial.com
Internet: www.elbe-financial.com

You can also submit your request verbally to our Data Protection Department at the aforementioned address. We will do our best to meet your request without undue delay.