Who we are

This Privacy and Cookie Policy (the “Policy”) explains how SDO Atlas S.à r.l., a private limited liability company (société à responsabilité limitée) (“SDO Atlas”, “we”, “our” or “us”), with registered office at 92, Rue de Strasbourg, L-2560 Luxembourg, registered with the Luxembourg Trade and Companies Register (RCS) under number B308617, processes personal data as controller in connection with its website and business activities.

Contact: info@sdoatlas.com

This Policy is provided for information purposes only and does not form part of any contract.

Personal data we process

Depending on our interactions with you, we may process:

• identification and contact details (such as name, company, job title, email address, telephone number and business address)
• business and transaction information (such as communications, onboarding information, contract, billing and payment details); and
• technical information (such as IP address, browser and device information, website usage data and cookie data).

We generally obtain personal data directly from you, from the organisation you represent, or from publicly available sources. We do not request special categories of personal data and ask that you do not send us such data unless we specifically request it.

Purposes and legal bases

We process personal data for the following purposes, on the following legal bases under the General Data Protection Regulation (GDPR):

• responding to inquiries and managing business relationships – our legitimate interests (Art. 6(1)(f) GDPR);
• preparing, entering into and performing contracts, including invoicing – contractual necessity (Art. 6(1)(b) GDPR) or, where the contract is with the organisation you represent, our legitimate interests;
• complying with legal and regulatory obligations, including accounting and tax requirements – legal obligation (Art. 6(1)(c) GDPR);
• operating and securing our website, preventing fraud and establishing, exercising or defending legal claims – our legitimate interests (Art. 6(1)(f) GDPR); and
• where applicable, website analytics and other non-essential cookies – your consent (Art. 6(1)(a) GDPR).

Where personal data is required for a contract or by law and is not provided, we may be unable to enter into or continue a business relationship.

We do not carry out automated decision-making, including profiling, that produces legal or similarly significant effects concerning you.

Recipients

We do not sell personal data. Where necessary for the purposes above, personal data may be shared with:

• service providers acting on our behalf (such as IT, hosting, email and analytics providers);
• professional advisers, including lawyers, accountants and auditors;
• banks and payment service providers;
• counterparties involved in a contemplated or ongoing engagement;
• courts, regulators and other public authorities where required by law or to protect our rights; and
• a potential acquirer or successor in the event of a reorganisation or transfer of our business.

International transfers

Some recipients may be located outside the European Economic Area, including in the United States. Such transfers take place only on the basis of an adequacy decision of the European Commission (including the EU-U.S. Data Privacy Framework) or appropriate safeguards such as the European Commission’s Standard Contractual Clauses. Information on the relevant safeguards is available on request.

Retention

We keep personal data only for as long as necessary for the purposes for which it was collected, including to comply with legal obligations and to establish, exercise or defend legal claims. Records we are required to keep by law, such as accounting records, are retained for the periods prescribed by applicable law (currently up to ten years). Personal data is subsequently deleted or anonymised.

Security

We take appropriate technical and organisational measures to protect personal data. However, no transmission over the internet or method of storage is completely secure, and we cannot guarantee absolute security. Please consider this when sending information to us by unencrypted email.

Cookies and similar technologies

Cookies are small text files stored on your device when you visit a website.

Essential cookies

We currently use only cookies that are strictly necessary for the operation and security of the website. These cookies do not require consent.

Analytics and other non-essential cookies

Should we use analytics cookies or similar technologies in the future (such as Google Analytics), these will only be placed with your prior consent, which you will be able to give or refuse via a cookie banner. Details of such cookies, including their providers, purposes and duration, will then be made available in the cookie banner. Third-party providers process data in accordance with their own privacy policies.

Managing your preferences

Where you have given consent, you can change or withdraw it at any time via the cookie settings on our website or through your browser settings. Withdrawal of consent does not affect the lawfulness of processing before the withdrawal. You can also block or delete cookies through your browser settings; disabling certain cookies may affect website functionality.

Your rights

Subject to the conditions and limits set by applicable law, you have the right to:

• access your personal data;
• rectify inaccurate personal data;
• request erasure of your personal data;
• restrict processing of your personal data;
• object to processing based on our legitimate interests;
• receive your personal data in a portable format; and
• withdraw your consent at any time, where processing is based on consent.

Requests may be sent to info@sdoatlas.com. We may ask you to verify your identity before responding. Where a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act on it, as permitted by law.

You also have the right to lodge a complaint with the Commission nationale pour la protection des données (CNPD), 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg (www.cnpd.lu). We would, however, appreciate the opportunity to address your concerns first.

Third-party websites

Our website may contain links to third-party websites. We are not responsible for the content or privacy practices of such websites.

Changes to this policy

We may amend this Policy at any time. The current version is published on our website. Where required by law, we will inform you of material changes.

Contact

For any questions about this Policy or our processing of personal data, please contact:

SDO Atlas S.à r.l.
92, Rue de Strasbourg, L-2560 Luxembourg
info@sdoatlas.com