Data protection

Introduction

POST Luxembourg and POST Telecom (hereinafter referred to jointly or separately as “POST”) take your privacy very seriously and are aware of how important it is to you.

POST will make every effort to enable you to use the services offered by post.lu in full confidence, notably by processing your personal data transparently, in strict observance of the applicable data protection laws and regulations and according to your personal preferences.

Data controller for your personal data

The personal data that www.post.lu gathers concerning you is subject to automated processing by:
POST Luxembourg
Address: 20 rue de Reims, L-2417 Luxembourg

You can contact the POST Data Protection Officer (DPO):
- at the following e-mail address: privacy@post.lu
- or by post at this address: POST Luxembourg – DPO, 20 rue de Reims, L-2417 Luxembourg

When is your personal data collected?

When you use www.post.lu, POST may collect your personal data in different places and at different times when:
- you browse post.lu pages;
- you subscribe to our services (newsletter, RSS feed, notifications, etc.);
- you contact us (“Contact” section);
- you apply for a job (“Work@post” section);
- you complete an order form (mobile or landline + Internet + TV section);
- you take part in a survey or an online game.

POST will only collect information that is strictly necessary to provide the services you want to use.

Purpose of gathering your personal data (“Purpose”).

The personal data that post.lu collects concerning you is processed by computer for the following purposes:
- to provide you with the services or information you request;
- to manage your commercial relationship with POST;
- to draw up visitor statistics and analytics while you browse the pages and sections of your choice, in order to understand how users interact with our website and to improve the quality of the services we offer;
- to inform you about products, events, services and offers provided by POST and its partners if you are subscribed to these information flows (newsletter, RSS feed, etc.);
- to tailor operation of the site to your own preferences;
- to offer you personalised, targeted content (products and services) based on your own preferences, your interests, and the pages you have already viewed;
- to send you advertisements or commercial messages if you have agreed to this;
- to ensure secure access to your personal data and detect any attempted intrusions;
- to offer you the opportunity to take part in competitions and lotteries.

We may legally process your personal data for each of the above purposes:
- if this is necessary for the performance of a contract between POST and you, or for the performance of precontractual measures taken at your request;
- if this is necessary in order for POST to meet its legal obligations;
- if you have consented to the processing;
- if POST has an acknowledged legitimate interest (fraud prevention, data and infrastructure security, etc.).

POST will ensure that your personal data is processed in a way that is wholly compatible with the purposes listed above. In the event that your data is processed at a later date for a purpose other than the above, all the necessary information will be sent to you beforehand. You will then have the option of objecting to this use of your data.

Type of personal data collected

Vos « données personnelles » font référence à toutes les informations vous concernant en tant que personne physique et qui permettent de vous identifier, directement ou indirectement.

Your “personal data” means all information relating to you as a natural person and which can be used to identify you, directly or indirectly.

The personal data that POST may collect while you browse on www.post.lu is:

- basic identification, such as first and last names, your date and place of birth, your postal address, your e-mail address, your phone numbers, etc.;
- personal data such as your marital status, how many people live in your property, your lifestyle and habits, hobbies, etc.;
- bank details, such as your account number, IBAN, the bank details of your beneficiaries, identifying data on your means of payment, etc.;
- professional information (data usually entered in a CV when you apply for a job);
- technical connection and browsing data, such as your device and IP address, the date and time of your visit, the pages visited, your browser details (type, language, etc.) and your device details (type, resolution, etc.), cookies, etc.;
- geographical location data (geolocation);
- advertising data, such as your interests, opinions, comments, notes and messages published via the website's forums and community and social media functions;
- behavioural data, such as your purchase history.

Some of the information gathered is necessary to achieve the objectives stated above, other information is optional. You will always be notified of the compulsory or optional nature of the information when it is collected. If you do not complete certain obligatory fields, this may affect POST’s ability to provide you with the product or service in question, or to guarantee the expected quality of experience.

Recipients of your personal data

Your personal data is collected by post.lu exclusively for use by POST. However, it may be passed on to:
- subcontractor companies used by POST in the context of delivering services; for example, website hosting and operation, sending newsletters, managing, processing and paying for online purchases, etc.
- commercial partners, on condition that you have agreed to receive offers from them.

Finally, POST may be required to pass on your personal data to a third party on the request of the judicial authorities or any other administrative body authorised by law.

This data will not be sent to any third party.

POST will also ensure that any transmission of your personal data to authorised third parties does not include any transfer to a third party located outside the European Union.

Retention times for your personal data

Your personal data that is collected and processed by POST will only be retained for a period of time that is strictly necessary for the purposes of the intended processing or to comply with a legal obligation imposed by the applicable legislation. Therefore, POST will retain data as follows:
- a maximum of three years from the end of the commercial relationship for data used for commercial prospection, marketing campaigns and/or promotions of offers from POST and its partners
- a maximum of 10 years from the end of the commercial relationship for data relating to contractual matters (contracts, guarantees, complaints, collections & disputes, etc.) or accounting matters (invoices, order forms, delivery slips, etc.)

Protection of your personal data

POST implements appropriate and reasonable security measures for the risks posed by the processing, in order to protect your personal data from destruction, loss, modification, disclosure or unauthorised access and any other form of illegal processing.

All POST employees and subcontractors who have access to your personal data as part of their job are bound by strict professional confidentiality. They only have access to the data that they require in order to perform their work and they regularly undergo awareness-raising and training regarding the compliance and security rules applicable to your personal data.

Your rights

When POST uses your personal data, you may, at any time and within the limits set out by law, exercise the following rights:
- to access your personal data (know what data has been collected and processed and obtain a copy), request that this data be rectified if it is inaccurate or incomplete, and deleted if it is obsolete;
- to object to your data being processed for a legitimate reason (including for the purposes of commercial prospection);
- if the required conditions are met, to request restrictions on the processing of your data, or that it be definitively deleted (right to be forgotten);
- to ask to receive a copy of the personal data that you supplied to POST in a structured format (portability), except where this right infringes on the rights and freedoms of third parties;
- to ask not to be subject to a decision based exclusively on automated processing, including profiling, where this decision produces legal ramifications for you or affects you in a similarly significant way. You may also ask for further details about the rationale behind this automated processing, so as to be able to challenge it and ask for it to be reviewed by an actual person.
- withdraw your consent at any time for all processing based on said consent.

You may exercise any of these rights free of charge by contacting us:
- by e-mail at the following address: privacy@post.lu
- or by post at: POST Luxembourg – DPO, 20 rue de Reims, L-2417 Luxembourg

To enable us to carry out your request and to avoid identity theft, please enclose a copy of both sides of a valid form of identity along with your request.

POST will respond within one month of receipt of your duly completed request.

You may also lodge a complaint with the National Commission for Data Protection (CNPD), via its website: www.cnpd.lu

The use of cookies

What is a “cookie”?

A “cookie” is a small file usually made up of letters and numbers, sent by the web server and saved on your device (PC, tablet or smartphone) via the web browser that you are using (Google Chrome, Mozilla Firefox, Microsoft Internet Explorer, Apple Safari, Opera, etc.).

Some “cookies” are sent directly by the website you visit. Others, known as “third party cookies” are sent by this website’s partners (social networks, advertising companies, etc.).

What do cookies do?

Most cookies store technical information about the way you use a website (language settings, screen size and resolution, connecting time, pages visited, your IP address, etc.) to enable the website to “recognise” your device.

They are generally necessary for the website to work correctly (saving your session,your shopping basket, your favourites, etc.), but they are also used to analyse your browsing behaviour on the website, to optimise your experience and present you with personalised content such as articles, offers, search suggestions or targeted advertising to match your preferences if you so wish.

We would like to draw your attention to the fact that sharing your device with other people is liable to affect the personalised nature of the cookies we use, and therefore their effectiveness with regard to your personal preferences.

How does POST use “cookies”?

Our website uses different types of cookies to improve its personalised operation by interacting with your user profile. Our website uses four types of cookies:

Cookies that are strictly necessary to use the service

These enable the main functions of the website to be used, such as saving your device display preferences (language, display settings) depending on the graphics card, the device type and the viewing or reading software that you are using (type of web browser), and applying these preferences in subsequent visits.

They also enable us to link together the various pages viewed in order to provide a smoother browsing experience.

Finally, they enable us to manage your user session after you have identify yourself, as well as the contents of your shopping basket, where applicable.

Website tracking and statistics cookies

These enable us to compile statistics and visitor and user counts for the various pages and sections of the website (number of visits, page views, your route through the site, the links you have clicked on, your return frequency, etc.). This information helps us to:
- perform studies to adapt the content of the website to your needs;
- detect malfunctions and improve our quality of service.

Social networking cookies

To improve the interactivity of our website, we use services offered by third party websites. These services use cookies when you interact with them. These notably include:
- videos shown on the website (YouTube, DailyMotion, etc.).

Advertising and commercial cookies

These are likely to be placed on your device to identify your preferences, your areas of interest and any products you have viewed or purchased on our website, in order to personalise the adverts that you are shown: these will be dynamically displayed in designated advertising space on the website, either by POST or by its commercial partners.

How can I manage my preferences for cookies?

Our website will not save or read any cookie on your device until you have granted your consent, through our “cookies manager

When you visit our website homepage, you will be notified of the use of cookies by a dedicated information banner. You will then be asked to agree to all of the cookies integrated into the pages that you visitbeing saved on your device, or to personalise your preferences for saving cookies.

Cookies that are strictly necessary to use the service

These cookies do not require your consent for their use, but you can always choose not to accept these cookies on your device and delete them using the configuration settings of your web browser. However, this risks your user experience being seriously degraded and some functions of the website may even no longer be accessible.

Other categories of cookies (website tracking, social networks, advertising, etc.)

You can block these categories of cookies from being saved and read on your device by our website at any time by changing your preferences on our “cookies manager

For more information on configuring cookies on the most commonly used web browsers, please read the instructions for your browser.

How long does POST store “cookies” for?

The maximum time cookies managed by us on this website are stored is 13 months.