Welcome to planck Security and our website at www.planck.security. We are committed to protecting your Personal Data and to providing clear and transparent disclosures about the types of information we collect and how we use it.
We would like to ask you to read this policy along with our Cookie Policy and if you are a user of our services, please also refer to our Data Processing Agreement.
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Luxembourg's Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”), and only as described in this Privacy Policy.
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.
"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Responsible for data processing is planck Security SA of 24 Rue Léon Kauffman, 1853 Luxembourg (“planck Security”, “we”, “us” or “our”). We act as the data controller and ask you to direct all questions about your Personal Data directly to us using our Contact Form.
In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data:
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us.
You can recognise an encrypted connection if the address line of your browser contains a "https://" instead of a "http://" and also has a lock symbol. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.
Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
We do not sell your Personal Data.
Unless specifically required when using our services and consent is obtained for that particular service, we do not process special category data.
We are present on social media on the basis of our legitimate interest. If you contact us (or connect with us) via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.
We may transfer your Personal Data to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your Personal Data may be transferred to so called third countries. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists (in particular Luxembourg's commercial and tax law for up to 10 years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services for example with our web host or with our logistic partners to deliver your order, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; as required by law or regulation; if planck Security (or a part of planck Security) is sold to or merged with another company; or proceedings at home or abroad or to fulfill our legitimate interests.
We also collect data on every access to our platform. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing platform.
We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.
We may obtain data about you from third-party sources, such as our marketing partners, social networks, and other third parties. We may use this data to better analyses your user behavior to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud.
Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
We may ask you for Personal Data when you:
Categories of Personal Data we collect may include your name, email address, and IP addresses. We may also collect demographic data such your interests, and preferences.
In order to provide you with a more consistent and personalized user experience in your interactions with planck Security, data collected through one source may also be linked to other data collected by planck Security through other sources. This may include data that helps us identify you when you access our website through several different devices.
In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and Contract.
We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our accounting and tax obligations. Your data will not be used by us for automated decision making or profiling, nor will it be shared with third parties. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations.
The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.
We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
Under the DPA and GDPR, you can exercise the following rights:
If you have any questions, please contact us.
If you believe that the information, we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.
You can withdraw consents you have given at any time by contacting us.
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Luxembourg is: Commission Nationale pour le Protection des Données, 15 Boulevard du Jazz L-4370 Esch-sur-Alzette, www.cnpd.lu
This Privacy Policy was last updated on Wednesday, 29 March 2023 and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.
