Privacy Policy - updated on [2016-07-25]

HOW WE USE YOUR DATA

This website belongs to Garfunkelux Holdco 2 S.A.  (hereinafter “We” or “Garfunkelux Holdco 2 S.A.”).  This privacy policy outlines how We will use, store and share your personal data.
We will use your personal data fairly and lawfully and in accordance with the Luxembourg Law of 2 August 2002 on the protection of persons with regard to the processing of personal data, as amended (the “Data Protection Law”).  For the purposes of the Data Protection Law, We are the data controller.

PERSONAL DATA WE MAY COLLECT AND USE

Where We Get Your Personal Data From: You may share personal data about yourself through use of our website or within phone calls, emails or otherwise contacting us.  

What Categories of Personal Data Do We Collect?:  The personal data that We collect may include email addresses together with any other personal information that you may inform us of via email, if you call us or by any other means that you may contact us.  
Also, each time you visit our website We may automatically collect information and personal data about your computer for system administration, including where available, your IP address, operating system and browser type.

USES MADE OF YOUR PERSONAL DATA

The website belongs to Garfunkelux Holdco 2 S.A. and some of our group companies located in the European Union may act as data processor and may process any personal data obtained in accordance with this privacy policy on behalf of Garfunkelux Holdco 2 S.A.
We and our group companies may use personal data held about you in the following ways:

•    to administer our website;
•    to improve our website to ensure that content is presented in the most effective manner;
•    to send to you information about our company (e.g. notifications if you opt in to receive them).
•    at a later stage, to prevent money laundering and fraud.

We may also share your personal data with our suppliers located in the European Union who provide services to us to enable them to provide these to us.  These suppliers are our data processors and may only use your personal data in the way We specify on our behalf.

BASIS FOR USING YOUR PERSONAL DATA

You can exercise your right to stop receiving the information which you have consented to receive by following the ‘opt-out’ link on the specific correspondence which contains the information. You can also exercise the right at any time by contacting us at admin@lowellgroup.co.uk.

DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

We may share your personal data with some of our group companies located in the European Union but only for the purposes set out at ‘Uses Made of Your Personal Data’ above.  
We may share your personal data with third parties if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use http://lowellgroup.com/terms-and-conditions/ or to protect the rights, property, or safety of our clients, our employees agents and subcontractors or others

WHERE WE PROCESS YOUR PERSONAL DATA

The data that We collect from you will not be transferred to or stored anywhere outside of the EEA.  Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to our website.

COOKIES

“Cookies” are small pieces of information sent by a web server (such as that used to run this website) to your computer, which are then stored on the computer’s hard drive. Although cookies contain identifying information, they do not contain any information that identifies you personally, but they allow us to recognise you when you return to our website.
We do not use persistent cookies i.e. those that are pushed out to a user’s machine and stored. This website uses Session Cookies. These are temporary cookies, which only exist in the period you access the website (or more strictly, until you close the browser after accessing the website). Session cookies help the website remember what you chose on the previous page, therefore avoiding the need to re-enter information and improve your experience whilst using the website. These cookies do not contain personal information and cannot be used to identify you. We also use cookies to track how visitors reach our website and the path they take through it to help us improve our service to you. For example, We use Google Analytics, a popular web analytics service provided by Google. Google Analytics uses cookies to help us to analyse how users use the website. Find out more about how these cookies are used on the Google Privacy site.
You can change your browser settings so that cookies are not accepted. If you do this, you may lose some of the functionality of this website, including the use of the secure area of the website.

For further information about cookies and how to disable them please go to: www.aboutcookies.org.

GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

In case of activation of the IP anonymization, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area.  Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA.  On behalf of the website provider Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google.  
You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website.
Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage /gaoptout?hl=en-GB.  You can refuse the use of Google Analytics by clicking on the following link. An opt-out cookie will be set on the computer, which prevents the future collection of your data when visiting this website:
Deactivate Google Analytics

Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html or at https://www.google.de/intl/en_uk/policies/. Please note that on this website, Google Analytics code is supplemented by “gat._anonymizeIp();” to ensure an anonymized collection of IP addresses (so called IP-masking).

RECORDED PHONE CALLS

Should you call us on any landline contact number provided to you, your call will be directed to one of our group companies in the UK.  Please note that your call may be monitored or recorded for security purposes, to resolve complaints, for training purposes and/or to improve quality and service standards.

OTHER WEBSITES

Our website may, from time to time, contain links to and from the websites of third parties.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies or your use of those websites.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this policy from time to time and if We do We will bring the new terms to your attention when you visit the website and you will be deemed to have accepted the policy in order to continue using the website.

CONTACT, COMPLAINTS AND ACCESS TO PERSONAL DATA

The Data Protection Law gives you the right to access and to rectify personal data held about you.  If you would like to access this personal data, have any question, comments or requests, or are unhappy with how We use your personal data then please contact our Data Protection Officer:

By letter: The Data Protection Officer, Ellington House, 9 Savannah Way, Leeds LS10 1AB.

By admin@lowellgroup.co.uk