This data protection declaration applies to all our future and current co-contractors, external service providers, visitors to our website and any other third party dealing with and whose personal data is processed by AZAP S.àr.l. (hereinafter “the Data Subject” or “the Data Subjects”).

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing the directive 95/46/EC, hereinafter “GDPR”, we wish to inform Data Subjects about the processing of their personal data.

AZAP S.àr.l. has its head office at 12, rue du Commerce L-3616 Kayl.

In compliance with the GDPR, AZAP S.àr.l. is the controller of personal data.

The legal basis

The legal basis for the processing of the personal data of the Data Subjects is, on the one hand, the proper execution of our contractual or even pre-contractual relationship with the Data Subjects and, on the other hand, the processing is necessary in order to respond to the legitimate interests pursued by AZAP S .àr.l.. For certain processing operations, several legal bases may apply.

Another legal basis for processing personal data of Data Subjects for specific purposes may be consent. Consent can be withdrawn at any time. However, if the processing is simultaneously based on another legal basis, the withdrawal of consent will in principle have no impact on the processing by AZAP S.àr.l. (or at least not on the entire treatment).

Finally, legal obligations applicable to AZAP S.àr.l. may constitute another legal basis justifying the processing of personal data of Data Subjects.

Personal data possibly collected and processed

• First and last name

• Trade name

• Postal and electronic address

• Telephone number

Collection of personal data

Personal data will be collected, for example, when first contacting the Data Subjects, when they fill out forms or by communicating for example by telephone or e-mail with us and otherwise within the framework of the contractual relationship. that they have with AZAP S.àr.l..

The purpose and processing / use of personal data

AZAP S.àr.l. collects personal data primarily in order to be able to perfectly execute its contractual obligations towards its co-contractors, or even external service providers.

Consequently, AZAP S.àr.l. will store personal data, among other things, in electronic form and only for professional use. Personal data may be stored or transferred to any other workplace of AZAP S.àr.l., to a subcontractor or other co-contractor of AZAP S.àr.l., as well as to any administration or public authority. when legal obligations etc. applying to AZAP S.àr.l. require such a transfer, respectively when the transfer is consistent with the purpose of the processing for which the data was provided to/collected by AZAP S.àr.l..

The data collected will be kept for a period not exceeding that necessary to achieve the purposes for which they were collected, without prejudice to the rights of AZAP S.àr.l. to retain certain data for a longer period due to legal/regulatory obligations applying to AZAP S.àr.l., respectively due to exceptional situations which would justify longer retention (legal proceedings, etc.).

AZAP S.àr.l. also collects personal data from interested members. When the interested candidate member is subsequently accepted, personal data will be retained for at least the duration of the relationship and without prejudice to the paragraph above. In the event of refusal, the personal data of interested candidate members are deleted without delay, unless contraindicated by the interested candidate member.

Who will be in contact with the personal data of Data Subjects?

Depending on the data concerned, the people occupying the following positions will intervene on personal data: AZAP S.àr.l. 12, rue du Commerce L-3616 Kayl

Rights:

Data Subjects may assert the following rights:

• the right to be duly informed about the use and processing of personal data in accordance with the GDPR;

• the right to access personal data in accordance with the GDPR;

• the right to rectify personal data, the right to demand erasure of personal data, the right to object to the processing of personal data provided that the contra

laws and legal obligations applicable to AZAP S.àr.l. are not in conflict with any such request;

• the right to obtain in particular situations specified in the GDPR, restriction of processing so that personal data can only be processed with the consent of the Data Subject (without prejudice to our right to store the data in accordance with the GDPR data protection law). The execution of this right has no impact on previous processing;

• the right of the Data Subject to receive in particular situations specified in the GDPR, all personal data which concerns him and which has been provided by him to AZAP S.àr.l. and to transfer this data to another data controller (right to data portability). AZAP S.àr.l. reserves the right to charge fees for such a transfer, particularly in the event of frequent requests and/or in the event of a request deemed excessive in terms of the volume of data to be transferred. The Data Subject must inform AZAP S.àr.l. in writing in good time before the end of the relationship, if she intends to make use of this right. Failing this, AZAP S.àr.l. cannot be held responsible for the erasure of personal data;

• the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with the National Commission for Data Protection (CNPD) if the Data Subject considers that he or she is the victim of a violation in the processing of their personal data;

Website

AZAP S.àr.l. is the controller of personal data collected through its website (the “Site”).

To browse the Site, the visitor does not need to disclose personal data concerning him or her.

During each visit to the Site, certain technical data (the “Technical Data”) are automatically recorded in a specific file on the Site’s server. Technical Data may include, without this list being exhaustive, the IP address, Internet service provider, operating system and type of browser used by the visitor, date and time of access to the Site , the page(s) visited, the volume of data transferred. AZAP S.àr.l. analyzes Technical Data for statistical purposes as well as for the management and improvement of the Site. The Technical Data collected will under no circumstances be used by AZAP S.àr.l. to carry out profiling of visitors to the Site, so that the anonymity of each visitor is safeguarded. The Technical Data will not be transmitted to third parties.

Furthermore, the Cookie Policy of AZAP S.àr.l., as published on the Site, applies to the processing of personal data collected via cookies.

Modification of this Statement

AZAP S.àr.l. reserves the right to modify this statement at any time and for any reason. In order to be informed how AZAP S.àr.l. protects the personal data of Data Subjects, we recommend periodically consulting this declaration on the AZAP S.àr.l website. : www.azap.lu

Contact details:

Any questions and requests relating to personal data should be addressed to our contact person: info@azap.lu