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  1. Context and introduction

This Privacy Notice (the “Notice”) has been prepared in accordance with the requirements of 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 (the “GDPR”).

All capitalised words used in the Notice shall have the same meaning as they are defined or referred to in the GDPR, unless specifically indicated to the contrary herein.

IGS S.à r.l.-S, acting through Sebastian Scherer is the Data Controller of the Personal Data of any Data Subjects with whom IGS S.à r.l.-S deals in the daily performance of its duties and delivery of services, as further described herein.

IGS S.à r.l.-S is committed to hold the Personal Data in confidence in strict compliance with the provisions of the Notice, any internal procedures, the GDPR, as well as any applicable Luxembourg law. However, IGS S.à r.l.-S does not accept any liability with respect to an unauthorised third party receiving knowledge and/or having access to Personal Data provided to IGS S.à r.l.-S except in case of gross negligence or willful misconduct of IGS S.à r.l.-S. Furthermore,

IGS S.à r.l.-S will not incur any liability for the processing of Related Personal Data (as defined hereafter) accepted in good faith by IGS S.à r.l.-S as having been provided in accordance with Section 3 of this Notice. This Notice contains the information prescribed by article 12 of the GDPR.

2. Identity and contact details of the Data Controller and the Supervisory Authority

Data Controller:

IGS S.à r.l.-S

Sebastian Scherer

147A, Rue Principale

L-3770 Tetange

Grand Duchy of Luxembourg



Supervisory Authority:

Commission Nationale pour la Protection des Données

Service des plaintes

1, avenue du Rock’n’Roll

L-4361 Esch-sur-Alzette


3. Categories of Personal Data concerned

IGS S.à r.l.-S will collect and process the following Personal Data provided by or on behalf of a Data Subject, including Personal Data relating to the Data Subject obtained from other sources:

Name(s), Surname, contact information (telephone numbers, email addresses, postal address, website title, function in the Data Subject’s organisation), IP address, the outcome of technical processes (such as cookies, analytics, third party embeds) and other Personal Data that is necessary for the purposes described below collected or obtained from publicly available sources, social media or registers.

Any person providing Personal Data not provided directly by the relevant Data Subject itself (“Related Personal Data”) to IGS S.à r.l.-S represents and warrants that such person has full authority from the relevant Data Subject (“Related Data Subject”) to provide the Related Personal Data to IGS S.à r.l.-S and has informed the Related Data Subject of the processing of the Related Personal Data by IGS S.à r.l.-S in accordance with this Notice. Data Subject shall encompass the term Related Data Subject and Personal Data shall encompass Related Personal Data hereafter.

4. Purpose of the Processing and legal basis of the Processing

IGS S.à r.l.-S will use Personal Data for the following purposes with the relevant associated legal basis:

a) Compliance with legal obligations:

Ensuring compliance with anti-money laundering/combatting financing of terrorism legislation, including, but not limited to the amended law of 12 November 2004 on the fight against money laundering and terrorist financing (the “2004 Law”) and/or with any applicable fiscal rules and regulations;

b) Performance of a contract with a Data Subject:

  • Fulfilling the obligations of IGS S.à r.l.-S under any agreement that IGS S.à r.l.-S may have entered into with a Data Subject;

  • Fulfilling IGS S.à r.l.-S’ obligations under any agreement between a Data Subject and a third party, under which

IGS S.à r.l.-S has to fulfil any duties.

c) Consent of the Data Subject:

IGS S.à r.l.-S may use Personal Data for any other purpose expressly agreed to by the Data Subject, provided that such consent may be withdrawn at any time by the Data Subject, without however affecting any Processing performed by

IGS S.à r.l.-S prior to such withdrawal.

d) IGS S.à r.l.-S’ legitimate interest:

  • Managing and administering the relationship between IGS S.à r.l.-S and a Data Subject;

  • Maintaining a client relationship management database for communication and promoting services offered by

IGS S.à r.l.-S to Data Subjects;

  • Monitoring and recording, correspondence, telephone calls and emails in accordance with IGS S.à r.l.-S’ IT set-up.

IGS S.à r.l.-S’ legitimate interest results from IGS S.à r.l.-S’ activities, consisting in the provision of independent directorship services, legal, regulatory and business consulting.


5. Recipients of Personal Data

IGS S.à r.l.-S may share Personal Data with the following Recipients:

a) Any service providers of IGS S.à r.l.-S and any service providers of the Data Subjects or the organisation employing the Data Subjects, including Google, Apple and LinkedIn;

b) Any lawyers, auditors, consultants or other professionals which IGS S.à r.l.-S may consult to obtain advice or assistance for the performance of its duties;

c) The CSSF or other supervisory authorities, tax authorities, law enforcement agencies or courts of competent jurisdiction in order to allow IGS S.à r.l.-S to comply with any legal or regulatory obligations and instructions.


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