Privacy statement
In order to ensure that you are clearly informed about the processing of your personal data and that your data protection rights are respected, we have put in place a privacy policy that complies with the General Data Protection Regulation [EU Regulation 2016/679] as well as with all relevant European and Luxembourg laws for NR Docusafe (Up2you).
Our privacy principles
As your privacy is important, we will only process your data in accordance with the following principles:
- We will only use your personal data in a fair and trustworthy manner.
- You have a right to be clearly informed about how we use your personal data. We will always be transparent with you about what data we collect and how we use it.
- If you have any concerns about how we use your personal data, we will help you understand our processing.
- We will take all reasonable steps to protect your information from misuse and to keep it secure.
- We comply with all applicable data protection regulations and cooperate with the Luxembourg Data Protection Authority (CNPD)..
- Collection and use of your data
Personal data is data that can be used to directly or indirectly identify or contact an individual.
When you contact us, by email or telephone, we collect your personal information in order to provide you with the services you have requested or to respond to your enquiries. Unless the information is required to fulfill a contract between you and us or a legal obligation, you are free to provide us with the personal information we request and we undertake to collect only the minimum required to process your request or provide you with the requested service.
If you no longer wish us to process your data, you may withdraw your consent at any time without inconvenience by contacting the controller at info@up2you.lu.
What personal information do we collect
When you contact us by telephone, e-mail or when you see one of our staff members directly, we collect your name, address, e-mail and telephone number, as well as any information you may wish to give us during this communication.
How we use your personal data
The personal information we collect allows us to provide the services you request from our platform as well as information related to these services, such as billing, medical records, to manage your complaints and requests for information, and to provide you with any information you may require.
With your consent, this information allows us to send you a newsletter about our company, its activities, special events, or to provide you with special offers.
Disclosure to third parties
Your personal data will not be disclosed to third parties unless you have expressly given your consent, or we are obliged to disclose it for example due to a court order or legal obligation.
In the event of a sale, merger or dissolution of our company, we may share your information with the new legal entity where the purposes for which it is to be processed remain the same and in any event you will be informed in good time.
Protection of your data
We take reasonable steps to protect your personal information at all times.
Where your personal data is stored, we use limited access computer systems housed in facilities that employ physical security measures. Where necessary, data will be stored in encrypted form, including where we use third party storage. In addition, we have strict measures in place to segregate access to your data to limit the risk of disclosure or corruption.
Our organisation works with other companies, such as email and SMS providers, automatic information distribution services, cloud service providers, and specialist IT services. The selection of a third party follows a comprehensive selection process. In this selection process, each service provider is carefully selected on the basis of its technical and organisational competence in data protection. A contract for the processing of personal data will only be concluded if it complies with the identified security requirements, including the specific requirements of European and national regulations for the implemented services.
Integrity and retention of personal data
We make it easy for you to keep your personal information accurate, complete and up-to-date. We retain it to provide you with the services you have requested or after we have noted any inactivity on your part for a period of 5 years, unless we need to retain it for legitimate legal reasons.
To protect this data from accidental or malicious destruction, when we remove it from our services, we may not immediately delete the remaining copies from our servers or backup systems. Complete destruction will occur after a full backup cycle.
Our commitment to your privacy
Access to your personal data is restricted to prevent unauthorised access, modification or misuse, and is only permitted to our employees or partners who need it for their work, and always under a confidentiality agreement.
Specific use of your data
Cookies and related technologies
Our websites use technologies such as "cookies" and other web tools to help us improve your experience and our services. These technologies allow us to better understand user behaviour and tell us which pages of our websites are visited most often or which features our users like. If these technologies are optional, we will ask for your consent to implement them. Although some of these technologies are necessary for communication or to provide our core services to you and as such do not explicitly require your consent, we will inform you of their use.
Most browsers are set to automatically accept cookies. In general, you can prevent cookies from being stored on your hard drive by selecting "Do not accept cookies" in your browser settings. You can also configure your browser to ask for permission before storing cookies. Finally, you can delete previously set cookies at any time. However, if you set your privacy settings as such, you may not be able to use the full functionality of our website.
Google analytics
Our website Google Analytics. This service allows analysis of access to the websites of Google Inc. ("Google") and allows us to improve our web presence. The information collected by means of a cookie (IP address, access time, access duration) is transmitted to Google's servers in the USA and stored there. The evaluation of their activities on our website is transmitted to us in the form of reports or can be viewed on a protected site. Google may also transfer the information collected to third parties if required to do so by law or if third parties process the data on Google's behalf. However, in order to prevent Google from having any direct personal connection with you, we use the "anonymous" function. This means that IP addresses are only processed in short form and cannot be used to locate you or to create an individual profile.
By using our website, you consent to the processing of data about you by Google in the manner described above. If you wish to limit this processing, you can use certain browser extensions to deactivate and control Google Analytics tracking.
Marketing and advertising
In addition to providing our services, we also use your personal data to communicate with you about our marketing offers or promotions and to recommend other services that may be of interest to you.
If you do not wish to receive any further information or newsletters from us by e-mail, you can opt out at any time by contacting us.
Your questions and privacy rights
Your rights
You have the right to:
- Receive a structured copy of your personal data that we process.
- Ask us to correct, update or delete your personal data from our records.
- Report any misuse of your personal data to us.
- Withdraw your consent to the processing of personal data in whole or in part.
For all of the above, simply log in or send us an email to info@up2you.lu clearly stating the nature of your request so that we can respond as soon as possible.
Your questions about your rights
If you have any questions or concerns about our privacy statement or data processing, or if you believe that your personal data has not been processed in accordance with the law, please contact us at info@up2you.lu.
Where your question is of a more substantive nature, you may be asked for more information. If you are not satisfied with the response you receive, you can address your complaint to the national personal data protection authority CNPD ww.cnpd.lu or databreach@cnpd.lu .