Introduction

To cope with technological change, it is necessary to pay attention to privacy. AB-INITIO PROPERTY PARTNERS (now "AB-INITIO") is committed to complying with the new European General Data Protection Regulation (GDPR) which came into force on 25 May 2018. The personal data collected by AB-INITIO is fully subject to this new regulation.

Index

1. COLLECTION OF PERSONAL INFORMATION

2. FINALITY OF THE TREATMENT OF THE DATA
- INFORMATION THAT YOU DO- Registration information - Transaction information - Comments and notices - WE COLLECT AUTOMATICALLY - Information about activity- Cookies and similar technologies - WHAT WE DO TO SOURCE TIERCES- Analytical Reports and Market Reports
3. LEGAL BASIS

4. FORMS AND INTERACTION
- LINKS TO THIRD-PARTY SITES
5. NEWSPAPER FILES AND COOKIES

6. THIRD PARTIES

7. STORAGE TIME

8. RIGHT OF OPPOSITION, WITHDRAWAL AND TRANSFER

9. RIGHT OF ACCESS AND RECTIFICATION

10. RIGHT TO LIMIT TREATMENT

11. EXECUTING RIGHTS REQUESTS

12. SECURITY

1. COLLECTING PERSONAL INFORMATION

In general, your personal data is not automatically stored when you browse the AB-INITIO website.

Cookies does not collect personal data, they simply provide a better browsing experience. These are session cookies.

In some cases, especially when you want to leave a message on the website, you will be asked to provide your name, first name and email address (hereafter your "Personal Data"). By providing this information, you expressly agree that your data will be processed by  AB-INITIO  for the purposes shown in Section 2 below. If there are other purposes than those indicated in point 2, they will be communicated at the end of each form.

2. PURPOSE OF DATA PROCESSING

AB-INITIO may process your Personal Data for the following purposes:
(a) provide you with the information or services you requested (including sending the Newsletter, a commercial offer or responding to a contact request);
(b) collecting information that allows us to improve our site, products and services;
(c) contact you about various AB-INITIO events, including product updates and customer support.
(d) registration information: When you create an AB-INITIO account, sign up or fill out Service forms, we collect information about you, including your name, address, phone number, email address and password you create (encrypted).
(e) transaction Information: Payment transactions are outsourced to our subcontractors and we do not store your credit card information in our systems.  We also collect billing details.

(f) information about your marketing preferences: We collect information about your preferences to receive marketing information every time you subscribe or unsubscribe.
(g) comments: When you post messages and reviews about the Services or contact you, for example, for a question, problem or comment, we collect information about you, including your name and the content of your query. If you contact our customer support teams, we will record and keep a record of your conversation for quality and training purposes and to help you answer your questions.

INFORMATION YOU VOLUNTARILY PROVIDE

Registration Information
The registration information you provide when you create an AB-INITIO account allows us to give you access to the Services and provide them to you under our terms. We also use this information to authenticate your access to the Services, to contact you for your views, and to inform you of significant changes or updates to our Services.
Transaction Information
Your transaction information (such as the information to be provided when registering for the event) allows us to process your request.

INFORMATION WE COLLECT AUTOMATICALLY

When you access our services, we can automatically collect certain information from your device, such as your IP address, MAC address or device ID. In some countries, including Europe, this information may be considered personal information under applicable data protection laws.
Information about the activity
We analyze your  files, your subscription to the newsletter, the details of the information provided when registering for the contest. We allow you to access your personal file so you can easily rearrange your documents.
Cookies and similar technologies
Like many websites and online services, we use cookies and other technologies to keep a record of your interaction with our services. Cookies also help us manage a range of features and content. For more information on the types of cookies and similar technologies we use, why and how you can control these technologies, please visit our special "cookies" section.

3. LEGAL BASIS

For purposes explained in the point (2):

a) Legitimate interest (answer to a question) or consent (newsletter);
b) Legitimate interest (log-based anonymized navigation data);
c) Consent;

d) Contractual obligation.

4. FORMS AND INTERACTION

Your personal information is collected via our contact form or newsletter request form. We use the information collected for the following purpose: Tracking requests

• Information;

• Statistics;

• Contacts.

When you access our services, we can collect certain information automatically from your device. In some countries, including Europe, this information may be considered personal information under applicable data protection laws. Like what:

• Activity information: We collect information about your use of services and information about you from orders

• Cookies and similar technologies: We use cookies and similar tracking technologies to collect and use personal information about you (for example, your IP address, your device's ID, the type of browser and the time, frequency and duration of your interaction with theservices)

• There is no data collected for advertising purposes.

LINKS TO THIRD-PARTY SITES

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates or to a number of websites that may provide useful information to our visitors. We provide you with these links only for convenience and the inclusion of a link does not involve the approval of the website concerned by AB-INITIO. If you follow a link to one of these websites, please note that they have their own privacy policies and we do not accept any responsibility for these related policies or websites. Please check these policies before submitting personal information to these websites.

5. FILES LOGS AND COOKIES

We collect certain information through log files and cookies. These are mainly the following information:

• IP address;

• Operating system;

• Pages visited and queries;

• Day and time of connection.

The use of such files allows us to:

• Improve service and offer a personalized welcome;

• Collect statistical data.

6. THIRD PARTIES

Your data can be stored, but encrypted, on our cloud servers.

7. STORAGE TIME

Your personal data is stored by AB-INITIO only for time in relation to the purpose of our communication exchanges (contact us via our contact form) or your order or until you opt out of our newsletter, if you are registered (a churn link is available in every newsletter we send).

8. RIGHT OF OPPOSITION, WITHDRAWAL AND TRANSFER

You have the right to object, delete your personal data and withdraw your consent. You can also request the transfer of your personal data. The right of objection is the possibility offered to Internet users to refuse to have their personal information used for certain purposes mentioned in the collection. You may express your opposition to the handling of your personal information if we have a legitimate (or third-party) interest in doing so and there is a valid reason to object to the processing of the data. You also have the right to object if we process your personal information for direct marketing purposes. The right of retraction is the ability for users to request the removal of their personal information. You can also request the removal of your personal information when you have expressed your right to object to the processing of your data (see above). When you give your explicit consent to authorize the collection, processing and transfer of your personal information for a particular purpose, you have the right to withdraw your consent for this data processing at any time. Once we have received the notice of withdrawal of your consent, we will no longer process your information for the purposes for which you have given your consent, unless we have a legitimate reason to do so. You can request the transfer of your personal information on your behalf or on behalf of another processing manager in an electronic and structured format (right to data portability). This allows you to retrieve and transfer your data in a usable electronic format.

9. RIGHT OF ACCESS AND RECTIFICATION

You can request access to your personal information (commonly referred to as "request for access to personal data"). This request allows you to receive a copy of your personal information and verify that we are legally processing that data. You can also request information to find out if we have personal information about you and, if so, what information is available and why we keep/use it. In addition, you can request the correction of the personal information we have about you. This allows you to correct any incomplete or inaccurate information we have about you.

10. RIGHT TO LIMIT TREATMENT

You can request a limitation of the processing of your personal information. This allows you to suspend processing your personal information, for example if you want to establish the accuracy or reason for processing the data.

11. ENFORCEMENT OF RIGHTS CLAIMS

To request the execution of your rights, you can contact us at the following email address dpo@abinitioproperty.com. Your application will be processed within one month of confirming your identity. You will not have to pay a fee to access your personal information (or perform any other of your rights). However, we may charge you a reasonable fee if your access request is manifestly unfounded or inappropriate. We may also refuse to process your application for the same reason. We may ask for this information to help us confirm your identity and to ensure that you respect your right to access this information (or for the performance of any other of your rights). This is a security measure to ensure that your personal information is not disclosed to an unauthorized person. You are allowed to file a complaint with the National Data Protection Commission ("CNDP") if you feel that your rights are not being respected.

12. SECURITY

The personal information we collect is stored in a secure environment. Our employees are required to respect the confidentiality of your information. To ensure the security of your personal information, we use the following measures:

• SSL Protocol (Secure Sockets Layer);

• Access management — authorized person:

• Backups:

• Firewall.

We are committed to maintaining a high level of confidentiality by integrating the latest technological innovations to ensure the confidentiality of your data. However, as there is no mechanism for maximum security, there is always a risk of using the Internet to transfer personal information.

COOKIES

Our cookie policy allows you to better understand the provisions we implement in terms of browsing our website. It informs you about the cookies on our website, their purpose (part 1.) and gives you the procedure to set them up (part 2.).

1. GENERAL INFORMATION ABOUT COOKIES ON THE SITE

As the publisher of this site, can set up a cookie on the hard drive of your device (computer, tablet, mobile, etc.) to ensure smooth and optimal navigation on our website. This page describes the information they collect, how we use it and why we sometimes need to store these cookies. "Cookies" are small, small text files that are downloaded to your computer and allow us to recognize your computer, tablet or mobile to customize the services we offer and enhance your experience. The information collected through cookies does not identify you in any way. Cookies are used exclusively for our own needs to improve the interactivity and performance of our site and send you content tailored to your interests. None of this information is disclosed to third parties. To better inform you about the information cookies identify, you will find below the different types of cookies that can be used on the website, their name, purpose and shelf life.

2. YOUR COOKIE SETTINGS PREFERENCES

When you log on to the website, certain browsing information may be stored in files called cookies. Saloncyberetcompliance.lu  uses cookies. However, these cookies (listed below) do not contain any personal data that is not required for its use and does not require the explicit consent of the user. From time to time, we test new features and make subtle changes to the way the site is structured. When we test new features, some cookies can be used to ensure that you receive a consistent experience on the site while making sure we understand which optimizations our users like the most. We use the following cookies on our website:

Statistics

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Cookie name: fedops.logger.sessionld

Provider: abinitioproperty.com

Type: HTML

Expiry: Persistent

Cookie purpose description: Registers statistical data on users' behavior on the website. Used for internal analytics by the website operator.

Initiator: Script tag, page source line number 169.

Source: https://static.parastorage.com/unkpg/lodash@4.17.15/lodash.min.js

Data is sent to: United Kingdom (adequate). Adequate country under GDPR (EU).

Session

Six session cookies are used, and a cookie persists to retain your browsing preferences.

No statistics or treatment are performed beyond this treatment.

Explanations

Session Cookies - these are temporary cookie files that are deleted when you close your browser. When you restart your browser and return to the site that created the cookie, the website will not recognize you. You'll need to reconnect (if a connection is required) or re-select your preferences/themes if the site uses these features. A new session cookie will be generated, it will store your browsing information and it will be active until you leave the site and close your browser. More information about session cookies (link to).

Persistent Cookies - These files remain in one of your browser's sub-files until you manually delete them or your browser deletes them according to the time specified in the persistent cookie file (more information about persistent cookies)