PRIVACY Policy

TRUESHINE SARL-S

The following privacy policy (hereafter the “Privacy Policy”) governs the manner in which TrueShine S.à r.l.-S, a Luxembourgish simplified limited liability company with registered office at 14, rue de Kriibsebaach, L-6185 Gonderange, Grand Duchy of Luxembourg, registered with the Luxembourg Trade and Companies Registry under number B 278731 (hereafter “TrueShine”, “we”, “us”, “our”) collects, uses, maintains and discloses information collected from its customers (hereafter “Customer”, “you”, “yours”) of its website or any other services (the “Services”).

  1. Compliance with Data protection Law

TrueShine acknowledges and undertakes to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereafter“GDPR”) and any other national applicable laws or regulations governing the processing of any personal data.

  1. Personal identification information

TrueShine may collect personal identification information (any information that can be used to distinguish or trace an individual’s identity) from Users in a variety of ways, including, but not limited to, when Users visit TrueShine’s website, register on such websites, fill out a form, sign a contract, purchase a product and in connection with other activities, applications and Services proposed by TrueShine. Users may be asked for the following information: name, date of birth, place of birth, e-mail address, postal address, phone number, social security number etc.

  1. Non-personal identification information

3.1 TrueShine may collect non-personal identification information (data that cannot be used on its own to trace or identify a person) about Users whenever they use TrueShine’s website. Non-personal identification information may include technical information about Users means of connection, such as the operating system and the Internet service provider utilized, geographical information such as country of origin, behavioural information such as time spent on the website, as well as further non- personal analytical data to improve customer experience, products and services.

3.2 Each User recognizes and accepts that the performance of the Services may depend on the collection and processing of personal identification information and non-personal identification information.

  1. Web browser cookies

TrueShine may use « cookies » to improve the User’s experience in regard of the Services. In that case, the User’s Internet navigator places cookies on his hard drive to gather a certain set of information used to customize the navigation in the framework of the Services, thus enabling certain unique functionalities.

  1. How TrueShine uses collected information

Principally, personal and non-personal identification information is used to provide the Users with the Services and to ensure a full efficiency of the Services they have registered for or they requested in any other manner.

In this framework, TrueShine may collect and use Users’ personal and non-personal identification information for the following purposes:

  • To improve Services: Information Users provide will help TrueShine respond to certain Users’ requests.
  • To personalize User experience: TrueShine may use non-personal identification information to understand how Users as a group use TrueShine’ Services.
  • To improve TrueShine’s website and other internet presence as well as other communication tools or tools for specific Services: TrueShine may use feedback Users provide to improve its products and services.
  • To send periodic e-mails and other text messages and/or notifications: TrueShine may use the e-mail address or mobile phone number provided by Users to respond to inquiries, questions, and/or other requests. TrueShine Customers will receive periodic information that may include, company news, updates, related product or service information, private sales etc. (the “Periodic Information Service”). In the case that, at any time, Users would like to unsubscribe from the Periodic Information Service, they should do it according to article 26.2 of the present General Terms and conditions.
  1. How TrueShine protects personal identification information

TrueShine adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information within the limits of TrueShine’s role with respect to the relevant Services.

  1. Sharing personal information

TrueShine does not sell, trade, or otherwise transfer to third parties Users’ personal identification information. However each User accepts that its personal identification information can be transmitted to website hosting and editing partners and other sub-contractors who assist TrueShine in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the information only according to TrueShine’s instructions and to comply with the applicable law regarding the protection of personal identification information. TrueShine may also release User’s personal identification information when it believes that such release is necessary to comply with the law, enforce its websites’ general terms and conditions, or protect its or others’ rights, property, or safety.

However, Users’ non-personal identification information may be provided to third parties for marketing, advertising, or other uses.

  1. Changes to this Privacy Policy

TrueShine has the discretion to update this Privacy Policy at any time. TrueShine will therefore revise the “last update date” at the bottom of this page. TrueShine encourages Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.

  1. Data Retention

TrueShine takes all reasonable measures to ensure that your personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy. The criteria for determining the duration for which we will retain your personal data in connection with the Services are as follows:

  • as long as we maintain an ongoing relationship with you (e.g., where you are a recipient of our services, or you are lawfully included in our mailing list and have not unsubscribed);
  • as long as your personal data are necessary in connection with the lawful purposes set out in this Privacy Policy, for which we have a valid legal basis;
  • until the expiry of a period of a two (2) months’ period following the end of any applicable limitation period under applicable law; and
  • with your prior consent, until the expiry of any additional retention period.

TrueShine undertakes to delete or to anonymise your personal data upon expiry of the retention period as described above.

  1. Data Security and data transfer

TrueShine has implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

You are responsible for ensuring that any personal data that you send to us are sent securely.

TrueShine does not transfer personal data to any third country nor to any international organisation, except as the case may be on the basis of:

  • adequacy decisions;
  • suitable Standard Contractual Clauses; or
  • other valid transfer mechanisms under GDPR.
  1. Data Accuracy and minimization

We take reasonable measures:

  • to ensure that your personal data are accurate and, when necessary, kept up to date; and
  • to ensure that your personal data are collected as a needed basis, in connection with the purposes set out in this Privacy Policy.
  1. Data subject rights

Each User benefits under data protection law from a right of access, modification and opposition to the processing of its personal data, a right to erasure and a right to portability of its personal data by sending an e-mail to trueshine.lu@gmail.com. Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the Luxembourg supervisory authority, namely the Commission nationale pour la protection des données (https://cnpd.public.lu/fr.html).

  1. Acceptance of these terms

By using the Services, Users confirm their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, TrueShine recommends to such User that he shall not use the Services. The continued use of the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.

This Privacy Policy is applicable from 1st September 2023.

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