Updated: April 2024
FundsDLT deals with and processes your Personal Data (as defined in point 1 below) with due care, in confidence and in accordance with the requirements of the General Data Protection Regulation.
- Data Protection – Key definitions and principles
- GDPR: the General Data Protection Regulation (EU) 2016/679 is an EU regulation on personal data protection and privacy. GDPR achieves the uniformity in the data protection rules applicable to all individuals within the European Union.
- Personal Data: any information related to an identified individual or that may allow to directly or indirectly identify an individual (e.g. name, phone number, job title). Personal Data does not include any information or data related to legal entities.
- Processing: any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means (e.g. collection, recording, organization, storage, consultation).
- Data controller: the person or entity that determines the purpose and means of the processing of the Personal Data.
- Scope of Policy
The present Data Protection Web Policy (the “Policy”) does not apply to any processing of your Personal Data by FundsDLT when you are a client, a commercial counterparty, a provider or supplier, an employee or any person with who FundsDLT has established or is in the process of setting up any contractual, legal or commercial relationship.
The Policy explains how and why FundsDLT collects and uses your Personal Data (contact details) when:
- You use FundsDLT’s website (the “Website”) or any functionalities or contact form available on the Website; and
- You request the sending of communications or invitations from FundsDLT.
- You have freely provided your personal data to FundsDLT by contacting us (e.g. by means of emails or telephone) or by giving your information to a FundsDLT employee.
- You wish to apply to a job at FundsDLT and you have read and understood the section 3.5 of this privacy notice on personal data processing for job application at FundsDLT.
In all cases, FundsDLT acts as data controller.
- Processing of your Personal Data
3.1 Use of the Website
When you use the Website or any functionality of it, FundsDLT collects and processes your Personal Data as follows:
- Collection of your Personal Data: Your Personal Data are collected through cookies (text files which are stored on your computer by your browser), through the information received from your browser, and/ or when you log in to dedicated or personalized pages of the Website.
- Personal Data collected by FundsDLT: FundsDLT will collect your IP address, the pages of the Website you visit, the duration and time of your visit as well as in some cases, your name, address, phone number and/or email address.
- Processing of your Personal Data: FundsDLT will process your Personal Data for:
- Obtaining statistical data about the use and access volume of the Website so as to improve the quality and efficiency of FundsDLT’s services and create a better experience by enhancing functionalities,
- Manage and operate the Website, and
- Make your access to dedicated webpages faster and easier.
Any further use of your Personal Data, out of that context, will require another specific consent.
3.2 Sending of requests to FundsDLT by means of the contact form
- Collection of your Personal Data: FundsDLT will collect your Personal Data when you complete the contact form.
- Personal Data collected by FundsDLT: FundsDLT will collect the data you provide when completing the contact form that is to say your name, first name, job title, email address, the name of your company, your phone number(s as well as the contact of your request. You do not have any obligation to provide whole of the above information and may decide, at your own discretion, to disclose only part of the requested information.
- Processing of your Personal Data: FundsDLT will process your Personal Data for the sole purpose of handling your request and provide you with an appropriate answer. Such answer may be, when appropriate, an offer or solicitation to subscribe to services supplied by FundsDLT.
Any further use of your Personal Data, out of that context, will require another specific consent.
3.3 External communications and invitations
When you request the sending of communications and/ or invitations by FundsDLT, FundsDLT collects and processes your Personal Data as follows:
- Collection of your Personal Data: FundsDLT will collect your Personal Data when you complete the subscription/ request form for receiving communications and/ or invitations from FundsDLT (according to your preferences).
- Personal Data collected by FundsDLT: FundsDLT will solely collect the data you provide when completing the subscription/ request form that is to say your name, first name, job title, email address, the name of your company and in some cases your phone number(s). You do not have any obligation to provide whole of the above information and may decide, at your own discretion, to disclose only part of the requested information.
- Processing of your Personal Data: FundsDLT will process your Personal Data for the sole purpose of sending you communications and/ or invitations (according to your preferences).
Any further use of your Personal Data, out of that context, will require another specific consent.
3.4 Freely provided personal data by prospects
- Collection of your Personal Data:The personal data that may be contained in the information you have freely provided to FundsDLT (either digitally, by means of email or telephone and/or physically, by means of business card or letter exchange, for example) are collected by FundsDLT based on Article 6 (1) (a) of the GDPR.
- Processing of your Personal Data: FundsDLT will process your Personal Data for the sole purpose of contacting you as a prospect. This personal data is processed in a professional context and for legitimate reasons. The scope of personal data involved in such case should be limited to your name and last name and professional contact details (e.g. nominative professional email address, professional phone number).
- Any additional personal data included in the information you have freely provided is not necessary for FundsDLT to contact you.
3.5 Personal data processing for job applications throughout the recruitment process
In connection with your application, we will collect, use, and store* the following categories of personal data about you:
- The data you have provided to us in your curriculum vitae (CV) and in your cover letter.
- The data you have provided on our application form, including name, title, home/term address, telephone number, personal email address, date of birth, gender, employment history, qualifications, nationality, social media accounts, profession, professional memberships, educational achievements, diplomas, transcripts, languages, computer skills, national service completion (if applicable), identification number and any data you may be providing us during interviews.
- Any personal data provided to us about you by your referees (if applicable).
How your personal data will be processed
We will process the personal data we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
Legal basis for processing:
It is in our legitimate interests to process your personal data to assess whether you are a suitable candidate for the role.
If you fail to provide personal data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application further.
How sensitive personal data may be processed
We will only process your sensitive personal data if you choose to disclose it and in so far as we are permitted by Law. For example, and only if you choose to disclose it, we may process data about your disability status (i.e., health data) to consider whether we need to provide appropriate adjustments during the recruitment process.
Information about your ethnicity, religious beliefs, sexual orientation, and political opinion which may be contained in the documents you provide us is NOT required. As such, we advise you NOT to provide such information unless you deem it necessary.
Automated decision making
Your data will not be subject to automated decision-making.
Data sharing
We will only share your personal data within our organization and with our service providers for the sole purpose of assessing your application.
Your personal data may be shared internally with managers, HR and recruitment teams, and authorized employees.
Our staff, service providers and company branches are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also disclose your personal information with competent authorities if you consent, where we are required to do so by law and in connection with criminal or regulatory investigations.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees who have a business need-to-know. They are subject to a duty of confidentiality.
Data retention
If we decide not to proceed with your recruitment, we shall retain your personal data for a maximum period of 1 year after the decision has been communicated to you. We retain your personal data during this period in case a similar role becomes vacant for which you could be a fitting candidate. After this period, we will securely destroy your personal data in accordance with our data retention policy.
Rights of access, correction, erasure, and restriction
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing i
- Request the transfer of your personal data to another party.
During the recruitment process, you can manage your personal data by logging into the online application system.
Contact
If you have any questions about this privacy notice or how we handle your personal data, please contact us at privacy@fundsdlt.net. You have the right to make a complaint at any time to the Commission Nationale pour la Protection des Données (the “CNPD”), the Luxembourg supervisory authority for data protection issues.
- Storage of your Personal Data
FundsDLT takes reasonable and appropriate technical and organizational security measures in order to:
- Store your Personal Data in secure databases or systems with restricted access,
- Protect your Personal Data against loss, accidental or intentional misuse, alteration, destruction and access by unauthorized persons.
FundsDLT will notify you without undue delay in the event FundsDLT becomes aware of any unauthorized or improper use, access or disclosure of the Personal Data, which is likely to result in a high risk to your rights and freedoms.
Please kindly note that some of the databases or systems used by FundsDLT for mailing services and storage systems may be hosted and/or maintained by third party service providers located inside or outside of the European Union. Your Personal Data will only be disclosed to such service suppliers if FundsDLT has deemed, in its reasonable opinion, that such service providers offer appropriate guarantees with regard to confidentiality, security and protection of your Personal Data.
FundsDLT also reserves the right to disclose Personal Data to any court, judicial or administrative authority when required or legally compelled to do so.
- Retention Period
FundsDLT will retain your Personal Data in accordance with the legal retention periods applicable in Luxembourg or where required for FundsDLT to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.
Your Personal Data will be deleted when:
- It is no longer reasonably required for the purpose the Personal Data were initially collected for,
- You withdraw your consent (where applicable); or
- FundsDLT is not legally required or otherwise permitted to continue storing your Personal Data.
- Your right to access, correct and request the deletion of your Personal Data
You have the right to access, modify, correct and/ or request the deletion of your Personal Data at any time as well as to restrict or oppose to the use of your Personal Data for the purposes mentioned above including:
- For communications and invitation sent by FundsDLT: You may withdraw your consent to receive communications or invitations at any time by sending an email to privacy@fundsdlt.net In that case, FundsDLT will immediately cease to send you communications and invitations.
- For the use of the Website: you may have, at any time, the option to either accept or refuse cookies on the Website by changing the settings of your browser. However, if you choose to refuse cookies, you may not be able to access and use certain portions of the Website. You may also encounter difficulties or restrictions when accessing whole or part of the Website for which FundsDLT disclaims any liability or responsibility of any kind.
If any of the Personal Data that you have provided to FundsDLT changes or becomes no longer up-to-date, you should send an email to privacy@fundsdlt.net. FundsDLT will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provided.
- Amendment to the Policy
The Policy may be amended, replaced or supplemented at any time and without prior or further notice by FundsDLT. You are therefore advised to review it from time to time for any possible changes.
- Contact
Please feel free to send any queries or requests related to the processing of your Personal Data by FundsDLT, in the context described above, to privacy@fundsdlt.net
