Privacy

At AccordD, we respect your privacy and protecting your personal information is our highest priority. This Statement is intended to explain AccordD procedures and policies on collection and processing the information you provide when you use the AccirdD website.

AccordD is acting as Data controller for the purposes of the General Data Protection Regulation (“GDPR”) and may process information relating to Data Subjects (individuals / natural persons) collected mandatorily or voluntarily, permanently or irregularly, in any suitable manner from the data subjects themselves, as well as from our customers, counterparties, interested parties who cooperate or intend to cooperate with (including open-source information, where appropriate).

We may collect data directly from the information you provide, for example, by completing a form on our website or reaching out to us, or in combination with other information received indirectly or publicly available. This also includes information you provide when you enter a service contract, subscribe to use our Services. Depending on the specific AccordD services you use, for the purposes of the processing we may collect different categories of personal data :

• Your personal identification information, contact details such as name, address, telephone number, email address.
• Your professional, familial and social background such as your marital status, employment and educations details (for example when applying to our open job position).
• Your photo, image or sound of your voice such as on your CV, during an event organised and recorded, on your KYC documents.
• Publicly available data such as your communications and behavioural data collected from your social medias (linkedIn profile), postings, emails etc.
• Financial and tax related information such as payment related information.
• Technical data based on your visits to our website, IP address, device used, type of browser, language, access logs, information received through emails.
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From AccordD or employees who have a relationship with clients (staff, consultants, auditors, etc.); from service providers; from suppliers who need access to your personal data in order to provide AccordD services, e.g. cybersecurity etc; from the state and government authorities, regulators, law enforcement agencies, public bodies and the judiciary;

AccordD may access your Personal Data where it relates to legal proceedings to protect our rights and those of our agents, customers and others, including to enforce our agreements and policies.

If your Personal Data is disclosed to a third party, AccordD will require the third party to use appropriate measures to protect the confidentiality and security of your Personal Data.

AccordD processes your Personal Data for the following purposes and bases:

• To provide and improve our professional services: Advisory, Tool implementation and maintenance, project management, etc.
• Drafting and signing of contracts, compliance with legal requirements;
• Tracking and managing clients/contractors, invoicing and payment;
• Advertising and developing our services;
• Event organisation;
• To improve the quality of our services (surveys and feedback);
• For minimising reputational and compliance risks (including AML/CFT, fraud, combating bribery and terrorist financing);
• To minimise cyber security, operational and IT risks;
• To develop our website and communicate with our customers, e.g. using techno-communication devices.

Any other data processing where it is necessary to serve AccordD legitimate interests such as protecting AccordD activity, support client needs and wealth, or with the data subject’s permission.

In accordance with GDPR regulations, personal data collected will retain during a short period of time and no longer than is necessary for the data collection purposes unless there is a Luxembourg legal requirement to retain it for a longer period.

Protection and security

AccordD takes appropriate administrative, technical and physical measures to protect your personal data. These measures comply with applicable Luxemburg privacy and data security laws and regulations.

AccordD does not transfer your Personal Data outside the European Union, unless:

⦁ a decision by the European Commission (to countries that provide an adequate level of personal data protection) or;

⦁ to whom the relevant agreement contains legal requirements for such a transfer.

In accordance with the GDPR and applicable Luxembourg regulations, if you are in the European Economic Area, you have the right to:

• gain access to your personal data and to information concerning the recipients of your personal data, the purposes for which personal data is processed, the retention period of personal data and the source of the personal data that has not been provided by you;
• to correct or amend inaccurate / incomplete personal data concerning you, taking into account the purposes of the processing, as well as the right to complete incomplete personal data;
• delete your personal data in certain circumstances;
• restrict the processing of your personal data in certain circumstances;
• object to the processing of personal data in certain circumstances;
• withdraw your consent to the processing of your personal data if AccordD requests your consent to the processing of your personal data. Withdrawal does not affect the lawfulness of processing based on your consent prior to withdrawal.
• know whether your personal data is used for automated decision making, including profiling;
• and other rights under applicable GDPR legislation.
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In order to support our operations we rely on several Service Providers. They help us with various services such as payment processing, web audience analysis, cloud hosting, marketing and communication, etc.

Whenever we share data with these Service Providers, we make sure that they use it in compliance with Data Protection legislation, and that the processing they carry out for us is limited to our specific purpose and covered by a specific data processing contract.

Below is a list of the Service Providers we are currently using, why we use them, and what kind of data we share with them.

These third-party service providers are processing data for which Odoo is Controller or Processor, on behalf of Odoo. Due to the great variability in resources and services provided by these subprocessors, AccordD Customers cannot select the subprocessor that will be used to process their data..

If you wish to exercise your rights or If you have any questions about our Privacy Statement you can contact us by email: dpo@accordd.eu

Should you wish to report a complaint or if you feel that Our Company has not addressed your concern in a satisfactory manner, you may contact the CNPD.

   CNPD (Commission Nationale pour la Protection des Données)

    1, avenue du Rock’n’Roll

   L-4361 Esch-sur-Alzette

   Tél. : (+352) 26 10 60 -1