Privacy Policy & Cookie Policy

Processing of personal data 

In the course of its activities, Kitsune Advisory S.à r.l. is required to process certain personal data of its employees, customers and partners; it ensures to the best of its ability the protection of such data by means of secure processing thereof, in compliance with the laws and regulations in force, including Regulation (EU) 2016/679 of 27 April 2016 on the protection with regard to the processing of personal data and on the free movement of such data of natural persons (hereinafter the "EU Regulation").

In accordance with Article 5 of the European Regulation, Kitsune Advisory S.à r.l. respects the following fundamental principles: 

Lawfulness  

When processing personal data, Kitsune Advisory S.à r.l. uses one of the following four legal bases:   

• The consent of the data subject  

• Performance of a contract;  

• Compliance with a legally established obligation;  

• The pursuit of legitimate interests.  

Where consent is the legal basis for processing, Kitsune Advisory S.à r.l. guarantees that it is:  

• Specific: processing is for a single purpose, and this purpose is precisely defined;  

• Unambiguous: consent is a clear, voluntary act;   

• Free: the person concerned must have the choice and must not suffer any negative consequences in the event of refusal;  

• Informed: when consent is obtained, the person concerned is informed of the contact details of the data controller, the purpose of the processing, the personal data that will be collected and otherwise processed, and the right to withdraw consent at any time.  

Loyalty  

Kitsune Advisory S.à r.l. processes personal data in such a way as to ensure the greatest possible transparency towards the persons concerned; Kitsune Advisory S.à r.l. does not process personal data without the knowledge of its employees, visitors, customers, suppliers or any other person who may have communicated personal data to it. In this way, Kitsune Advisory S.à r.l. ensures that the information it processes is handled fairly, in accordance with the applicable legislation and the reasonable expectations of the persons concerned.  

Transparency  

Kitsune Advisory S.à r.l. provides a certain amount of information to data subjects. This information is provided in clear, simple and easily accessible terms, regardless of the communication medium.  

Whether it collects personal data directly from data subjects or from third parties, Kitsune Advisory S.à r.l. provides data subjects with the information required by law.  

Purpose limitation  

Personal data processed by Kitsune Advisory S.à r.l. is used for specific, explicit and legitimate purposes in relation to the processing activities carried out.   

Data minimization  

Personal data communicated to and processed by Kitsune Advisory S.à r.l. is that which is strictly necessary for the performance of its activities: only information that is relevant, adequate and not excessive in relation to the purposes pursued in connection with the processing concerned is processed. Kitsune Advisory S.à r.l. assesses this principle on a case-by-case basis, in order to ensure that the processing of personal data is proportionate.  

Limits on data retention  

The retention periods for personal data collected and processed by Kitsune Advisory S.à r.l. are determined on a case-by-case basis, depending on the type of personal data, the purpose of the processing and legal requirements.  

Once the retention period has been reached, personal data is securely deleted to prevent its recovery. Where data is stored on analog media (or other tools or applications), it is also destroyed in such a way as to preserve its confidentiality. 

Within the scope of its activities, Kitsune Advisory S.à r.l. guarantees the minimized collection of the personal data of data subjects in order to strictly meet its obligations.  

Data accuracy  

Kitsune Advisory S.à r.l. takes great care to ensure the accuracy of the data collected and stored as part of its processing activities. Where necessary, it is updated. To this end, any data subject may submit a request for rectification of his or her personal data to Kitsune Advisory S.à r.l.; the request must be accompanied by proof of identity.  

The purpose of this privacy policy is to inform data subjects about the main ways in which their personal data is processed.

Some definitions of terms used in the personal data protection policy 

"Personal data" means any information which directly or indirectly identifies or renders identifiable a natural person;

"Data subject" means the natural person whose personal data are collected and otherwise processed by Kitsune Advisory S.à r.l., or a processor;

"Processing" means any operation or set of operations performed upon personal data, by means of automated processes on an electronic medium or manually on paper, such as collecting, recording, organising, structuring, storing, adapting or modifying, retrieving, consulting, using, communicating by transmission or disseminating such data;

"Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing operation;

"Processor" means the natural or legal person, public authority, department or other body which processes personal data on behalf of the controller;

"Websites" means the website of Kitsune Advisory S.à r.l. whose URL address is: www.kitsuneadvisory.lu

Kitsune Advisory S.à r.l. is responsible for the processing operations set out in this policy; for more information about the company, please consult the legal information published at the bottom of the website.

1. What processing operations are carried out by Kitsune Advisory S.à r.l.? On what legal grounds? What personal data is processed? 

You are a professional customer, partner or supplier of Kitsune Advisory S.à r.l.

Some processing operations are carried out via the Kitsune Advisory S.à r.l. website, while others are carried out directly by Kitsune Advisory S.à r.l.