1. Introduction

SK Consulting[1] is committed to our mission of empowering organizations through innovation. Achieving our mission isn’t just about building technology. Our mission reflects who we are as a company, how we manage our business internally, and how we work externally with customers, partners, governments, and suppliers. The present document (hereinafter the “Privacy Statement” or the “Document”) outlines how we collect, use, and safeguard your data, as well as your rights and choices regarding its management. Your privacy is of utmost importance to us, and we encourage you to review this document to understand how we handle your information in a transparent and responsible manner.

Any questions related to our privacy statement should be addressed to dpo@skc.lu

2. Summary

2.1. Which data do we collect?

Through your interactions with us and through using our products and services, SK Consulting collects data from you. Some of this data is directly provided by you and other data is collected during the usage of our products. The data we collect depends on the context of your interactions with SK Consulting and the choices you make, including your privacy settings and the products and features you sue. We also obtain data about you from third parties.

When considering the technology you utilize and the information you decide to share, options are available. When we request your personal information, you have the freedom to decline. Some of our products necessitate certain personal details to furnish you with a service. Opting out of providing the necessary data for a particular product or feature implies forfeiting its use. Similarly, in cases where legal requirements or contractual obligations demand the collection of personal information for the purpose of establishing or fulfilling an agreement, failing to provide said information will result in the inability to form the contract. In situations involving an existing product you’re currently utilizing, non-compliance might lead to temporary suspension or cancellation; you will be duly informed should this scenario arise. When sharing data is a discretionary choice and you opt not to, features such as personalization that rely on such data will be non-functional for you.

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2.2. Why do we collect this data?

SK Consulting uses the data we collect to provide you with rich, interactive experiences. In particular, we use data to:

∙ Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.

∙ Improve and develop our products.

∙ Personalize our products and make recommendations.

∙ Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.

In carrying out these purposes, we combine data we collect from different contexts (for example, from your use of two Microsoft products) or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods.

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2.3. Who has access to your data?

We share your personal data with your consent or to complete any transaction or provide any product you have requested or authorized. We also share data with SK Consulting -controlled affiliates and subsidiaries; with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights and property of SK Consulting and its customers.

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2.4. What do you control?

You can also make choices about the collection and use of your data by SK Consulting. You can control your personal data that SK Consulting has obtained, and exercise your data protection rights, by contacting SK Consulting or using various tools we provide. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law. How you can access or control your personal data will also depend on which products you use. For example, you can:

∙ Control the use of your data for personalized advertising from SK Consulting by visiting our opt-out page.

∙ Choose whether you wish to receive promotional emails, SMS messages, telephone calls, and postal mail from SK Consulting.

∙ Access and clear some of your data through the SK Consulting privacy dashboard.

Not all personal data processed by SK Consulting can be accessed or controlled via the tools above. If you want to access or control personal data processed by SK Consulting that is not available via the tools above or directly through the SK Consulting products you use, you can always contact SK Consulting at the address in the How to contact us section or by using our web form.

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  Privacy Statement

This Privacy Statement is intended to inform you, in a transparent manner, about the data we collect, the purpose for collecting it, the way we use it and the rights you have regarding the processing of such data.

SK Consulting reserves the right to change, modify and update this Privacy Statement by posting a revised version on our Website. Therefore, we recommend that you regularly consult this Privacy Statement, to make sure that you are aware of all changes.

Any questions related to our privacy statement should be addressed to dpo@skc.lu

1. Article – General

1. SK Consulting takes responsibility for the processing of Personal Data as a (1)“data processor”, when it processes Personal Data for the purpose of providing its Services to its clients and customers (hereinafter, “User”,“Users”), pursuant to the applicable data processing terms with those customers and as a (2)“data controller”, when or if it processes data for other purposes.

2. SK Consulting processes Personal Data in accordance with the legislation in force, and, in particular, Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, applicable from 25 May 2018 (hereinafter the “GDPR”).

3. The access to or use of our Websites, the use of our services implies the user’s full and unreserved acceptance of this Privacy Statement as well as its General Terms of Use. This means that you fully agree to how SK Consulting collects, uses and processes your Personal Data.

4. The visitor and User acknowledge having read the information below and authorizes SK Consulting to process, in accordance with the provisions of this Privacy Statement, the Personal Data that he/she/it communicates to us, for the provision of our products and/or services.

5. This Privacy Statement is only valid for the pages hosted on our websites and for the products and/or Services we offer in accordance with our General Terms and Conditions. It is not valid for the pages hosted by any third party to which SK Consulting may refer to and whose privacy policies may differ. SK Consulting will therefore not be held responsible for any data processed on these third party websites or by them.

1. Article – What data does SK Consulting collect?

Hereby, you grant, SK Consulting the right to process, for the purposes mentioned below, the following categories of Personal Data:

1.1. Category 1: Visitors, users of our website and customers and their employees

By visiting our website and/or by creating an account, and especially by using our Onboarding or Contact page, we ask you to provide us your identity data including:

∙ First name

∙ Last name

We also request information relating to your employer:

∙ Company Name

∙ Phone number

∙ Email address

∙ Register of Commerce No. of your company

∙ VAT No. of your company

∙ Other identifiers of your company

∙ The type of activity of your company

∙ The website of your company

∙ Microsoft 365 Tenant (in some cases)

∙ Country (in some cases)

For marketing purposes we use tools like Cookies and Google Analytics that may store:

∙ The type of domain with which the user connects

∙ The IP address assigned to the user

∙ The date and time of access of the website and other data related to traffic

∙ Location data or other data related to communication

∙ The pages visited and the actions used

∙ The type of operating system and browser used

∙ Your screen resolution and type of monitor

∙ The search engine or source of your visit

1.2. Category 2: Job applicants or employees

When applying to a job, or working for SK Consulting, we collect the following data from you:

1) First name

2) Last name

3) Email address (personal and professional)

4) Phone number (personal and professional)

5) Birth date

6) All information provided on your application (including photo if provided)

7) Matricula or other identifier

8) ID Card or Passport No.

9) Your bank account number

10) A copy of your ID card

1.3. Category 3: Information received from third parties

We sometimes collect information obtained from third parties about you or your company, including data from the European Commission (VAT VIES), Register of Commerce, Microsoft (Commercial Leads or Support Cases) and other parties. This may include:

∙ VAT No.

∙ Validity of your VAT No.

∙ Your company’s Credit risk information

∙ Your company’s latest financial statements

∙ Your company’s statutes

In special cases it could include data listed on specific sources like:

∙ United States – Denied Persons List

∙ United States – Specially Designated Nationals and Blocked Persons List

∙ Swiss – Seco List

∙ United Kingdom – HM Treasury’s List

∙ European Union – Common Foreign and Security Policy

2. Article – purposes of data processing

We process your data in order to offer you our best possible services while handling your needs. For each purpose, only the data relevant to the pursuit of the purpose in question are processed. The processing consists of any operation (manual or automated) on Personal Data SK Consulting collects, stores and uses its visitor’s and/or Users’ data for the following purposes, in particular:

2.1. Category 1: Visitors, users of our website and customers and their employees

Under the legal basis of your consent, business compliance and legal requirements we collect the data to:

∙ establish, carry out and conduct a contractual relationship with you and/or your company

∙ provide you with an optimized service and product experience

∙ allow you to receive messages

∙ allow you to request and us to respond to your requests for information, products and services

∙ perform marketing activities[2]

∙ to inform you about upcoming changes or new features

∙ create statistics

∙ improve our website experience

With regard to the eventual use of non-essential cookies, we shall only process your data based upon your consent given through our cookie banner.

2.2. Category 2: Job applicants or employees

Under the legal basis of your consent, applicant data will be processed by SK Consulting to evaluate the candidate and allow us to pursue our recruitment policy. The data will be withhold and complemented by additional data once the candidate has accepted our offer.

1.1. Category 3: Information received from third parties

Under the legal basis of regulatory requirements or conducting business, minimizing risk and insuring operations, SK Consulting may collect information received from third parties about you. This could for example include a credit limit request or a background screening.

2. Article – Direct marketing

Your Personal Data will only be used for direct marketing purposes, based on your consent or based upon our legitimate interest if we have concluded an agreement with you.

Your Personal Data will not be used for direct marketing purposes for any services that would not be identical or similar to those to which you have already subscribed, unless you have previously explicitly consented to such use.

When you give us your consent to use your Personal Data for direct marketing purposes, you also retain the right to revoke such consent at any time, upon request and free of charge. You may simply communicate your request by clicking the unsubscribe button below every promotional E-mail or by writing to us via the following E- mail address:  dpo@skc.lu.

3. Article – Data Sharing to third parties

SK Consulting treats Personal Data as confidential information and will not disclose or communicate them to third parties under any condition other than those specified in this Privacy Statement, to achieve the objectives pursued or under the conditions in which the law requires it to do so.

SK Consulting will not sell, hire out or pass on your Personal Data to third parties, except in the situations described in this Privacy Statement or unless you explicitly provide your prior consent.

SK Consulting may communicate its your personal information to third parties to the extent that such information is necessary for the performance, execution and management of a contract with you, including but not limited to reporting, support, marketing, computer security or offering specific other services.

In extraordinary circumstances it may occur that SK Consulting is obliged to transfer your Personal Data following a court order, or in order to comply with imperative laws and/or regulations. SK Consulting will, if reasonably possible, try to inform you on beforehand, unless revealing this information is subject to legal constraints.

4. Article – Storage periods

SK Consulting will store your Personal data for the duration necessary to achieve the objectives pursued, or for as long as necessary to comply with our obligations and only as long as legally permitted. SK Consulting may also store your Personal data after the termination of the contract, in order to comply with all applicable laws or as part of legal requirements.

4.1. Category 1: Visitors, users of our website and customers and their employees

We store your data as long as necessary for us to communicate with you, with a maximum of five (5) years after the first request or contact. In case of a contractual relationship, we will keep your identity data for maximum ten (10) years after the end of the contractual relationship.

With regards to cookies the retention period may vary depending on the specific cookie, ranging from end of the session to 2 years.

4.2. Category 2: Job applicants or employees

We store your data for maximum five (5) years after the last qualitative contact. 

1.1. Category 3: Information received from third parties

SK Consulting will store your Personal data for the duration necessary to achieve the objectives pursued, or for as long as necessary to comply with our obligations and only as long as legally permitted. SK Consulting may also store your Personal data after the termination of the contract, in order to comply with all applicable laws or as part of legal requirements.

2. Article – Your rights

As a Data Controller, SK Consulting User(s) is/are responsible for disclosing the rights of individuals (“Data Subjects”) with respect to their Personal Data and other information regarding the collection and use of that Personal Data, in accordance with the GDPR and other laws requiring such disclosures. According to the regulations on the processing of Personal Data, you have the rights described hereunder.

2.1. Right of access and right to obtain a copy

The right to freely obtain access to Personal Data, as well as to be informed about the purpose of the processing, at any moment.

2.2. Right to rectification, erasure or restriction

The right to request the restriction of processing of your Personal Data, if you think your data is inaccurate and you subsequently notified us about it or its erasure.

2.3. Right to object:

The right to object to the processing of your Personal Data when you have serious and legitimate reasons to do so and the right to object to its use for direct marketing purposes.

2.4. Right to data portability:

The right to obtain your Personal Data, which is processed by SK Consulting in a structured, commonly used format and/or to transfer this data to another data controller.

2.5. Right to withdraw consent:

When the processing is based on prior consent you have the right to withdraw this consent.

2.6. Automated decisions and profiling:

The right to request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

2.7. Exercising your rights:

You can exercise your rights by contacting us with a copy of the essential parts of your ID, such as name and date of birth, as attachment;

∙ Either through E-mail to dpo@skc.lu

∙ Or via ordinary mail to: SK Consulting S.A., 49, rue de Cessange 1320 Luxembourg

You can also consult or modify many of your data through our web portals like the customer portal or the support portal.

2.8. Right to file a complaint:

The right to file a complaint with the supervising Data Protection Authority:

Commission Nationale de la protection des données

15 Boulevard du Jazz

L-4370 Belvaux

Tel: +352.261.601

This does not affect a procedure before the civil court. Following hereto, if you have suffered damages caused by the processing of your Personal Data, you can file a claim for damages.

3. Article – Safety and Confidentiality

SK Consulting has adopted safety measures which are suited on a technical, organizational and physical level to avoid the destruction, the loss, the forgery, the adjustment, the non-authorized access or the notification of the Personal Data by accident to a third party, as well as the non-authorized processing of these data.

Nevertheless, if these events would occur and would affect your Personal Data, SK Consulting will inform you of the breach without undue delay, including a summary description of the potential impact and a recommendation on measures to mitigate the possible adverse effects of the breach.

Examples of safety measures adopted by SK Consulting include:

∙ Physical access control

∙ Digital access control

∙ Secure data storage

∙ Microsoft Trust Center Home

SK Consulting shall not be liable in any way for direct or indirect damages caused by a wrongfully or improper use of the Personal Data by a third party. At the same time, you also share responsibility for maintaining the privacy and security of the Services, for example: by not allowing any third party to have insight in your confidential communication(s).

4. Article 7 – Applicable Law and Jurisdiction

This Privacy Statement is managed, interpreted and executed in accordance with Luxembourg law which exclusively applies to every potential dispute. The courts and tribunals of the City of Luxembourg have exclusive jurisdiction to settle any dispute arising out of or in connection to the interpretation or execution of the present Privacy Statement.

5. Article – Safety and Confidentiality

5.1. What are cookies?

A “cookie” is a small file sent by SK Consulting’s server and placed on your computer’s hard drive. The information stored on these cookies can only be read by SK Consulting and only for the duration of the visit to the Website.

5.2. Why do we use cookies?

Our Website uses cookies and similar technologies to distinguish your preferences for use from those of other visitors and Users of our Website. This helps us to provide you with a better experience when you visit our Website and also allows us to optimize our Website.

All websites that target certain parts of the European Union are required to obtain your consent to the use or storage of cookies and similar technologies on your computers or mobile devices. This cookie policy gives you clear and complete information about the cookies we use and their purpose.

1. The cookies we use are safe. The information we collect using cookies helps us to identify any errors or to show you specific services that might be of your interest.

5.3. Types of cookies

There are many different cookies that can be distinguished according to functionality, origin or storage period. Below you may find a general description of the most common types of cookies. Next, a detailed overview is given of the different cookies that are used on our Website.

∙ Necessary cookies: these cookies are necessary for the Website to function and cannot be disabled in our systems. They are usually set in response to actions taken by you, such as setting your privacy preferences, logging in or filling out forms. They are necessary for the good communication and facilitation of the page navigation (e.g. returning to a previous page, etc.).

∙ Functional cookies: these cookies increase the user-friendliness of the Website by reminding you of your choices (e.g. language preference) and offering improved visitor and User functionality and personalization. For example, these cookies allow certain settings to be personalized at your request. Non-acceptance of these cookies may affect the Website performance and functionality and may restrict access to Website content. These cookies can be set by us or by third party providers whose services we have added to our pages.

∙ Analytic cookies: these cookies collect information about the use of our Website such as the number of visitors, the time visitors spend on a Web page and any error messages. They help us improve the performance of the Website. These cookies will not identify you.

∙ Marketing cookies: these cookies are used to deliver content that is more relevant to you. They can be used to deliver targeted ads or to limit the number of times you see an ad. These cookies can be used to remember websites that you have visited and share this information with other parties, including advertisers. These cookies may also be set by advertising partners through a website and used by those companies to build a profile of your interests and show you relevant ads on other sites.

∙ Social Sharing Cookies: we use some social sharing plugins, to allow you to share certain pages of our Website on social media. These plugins place cookies so that you can correctly view how many times a page has been shared.

∙ Third party cookies: first party cookies are cookies that are sent from our servers or domains from which the requested service is offered. Third party cookies are cookies that are sent to your browser from a server or domain that is not managed by us, but by a cooperating organization. Only these third parties have access to those cookies and the information collected by the cookie. If you would like to know more about these cookies, please refer to the policies that these parties offer on their respective websites. Please note that we have no influence on the content of their policy or on the content of these third-party cookies.

∙ We use other tools like Google Analytics, a web analytics tool that may set cookies in your browser, in order to help Us understand how Users engage with this Website and to help Us improve our products and services for you.

5.4. Your consent

Upon your first visit to our Website you will be asked to accept or refuse cookies. With this consent you agree to the different types of cookies we use.

5.5. Managing your cookies

You can block cookies by altering your browser’s settings. The rejection of these cookies may inhibit some functionalities on the Website.