Data Protection Policy

CapeToFlow Sàrl (hereinafter “CapeToFlow”) places great importance on the protection of your privacy.

For any processing of personal data, CapeToFlow undertakes to protect the data of users of its website CapeToFlow.com in accordance with applicable regulations, in particular the General Data Protection Regulation (“GDPR”) in force since May 25, 2018.

Within the scope of this Policy, personal data refers to any information relating to an identified or identifiable natural person, directly or indirectly.

For all processing activities implemented, CapeToFlow acts as the data controller within the meaning of the GDPR.

1 / Data we collect

As a general rule, your personal data is not automatically collected when you browse our website.

However, during your visit, a banner appears at the bottom of the screen informing you about the use of cookies during your browsing. You are responsible for choosing whether to accept or refuse cookies depending on their purpose. Some cookies do not collect any personal data but simply provide a better browsing experience.

To learn more about the types of cookies and similar technologies we use, why and how you can control them, please refer to our Cookie Policy.

When you fill in the contact forms available on our website, we collect data such as:

• Last name
• First name
• Company name
• Email address
• Phone number
• Number of users
• Content of messages sent to us

By providing this information, you expressly agree that your data will be processed by CapeToFlow for the purposes indicated in section 2 below. If there are additional purposes beyond those mentioned in section 2, they will be specified at the end of each form.

In addition, we collect data when you contact us directly through any communication channel (for example, when you send us an email containing a comment or feedback).

Finally, certain information is collected automatically. When you access our website, we may, through log files and cookies, automatically collect certain information from your device, such as your IP address, MAC address, device ID, as well as your device’s operating system, pages visited, requests made, and the date and time of connection.

The use of these files allows us to improve our website and collect statistical data.

2 / Purposes of data collection

We process your personal data for the following purposes:

• Management of contact and/or information requests submitted via the website;
• Management of service demonstration requests;
• Commercial prospecting (including by email): development of marketing campaigns, promotional offers, sending email alerts to prospects and clients, and providing information about new or existing services to personal clients;
• Contact regarding various events organized by CapeToFlow, including service updates and customer support;
• Information regarding your marketing preferences: we collect information about your preferences to send you marketing communications when you subscribe or unsubscribe;
• Improvement of website functionalities.

In the event that data processing is carried out for a purpose other than those listed above, we undertake to inform you in advance about this additional purpose.

3 / Legal bases for processing

4 / Data recipients

To achieve the purposes listed in section 2, your data may be shared with the following recipients:

• CapeToFlow staff;
• Network providers;
• Other service providers acting as subcontractors on behalf of CapeToFlow and under its instructions.

In such cases, a contract is established between CapeToFlow and the subcontractor, and appropriate technical and organizational measures are implemented in accordance with Articles 28 and 32 of the GDPR.

As a general rule, no personal data is transferred outside the Grand Duchy of Luxembourg or outside the European Union.

However, if your personal data is transferred (including via remote access) to a country outside the EU that is not subject to an adequacy decision, appropriate safeguards in accordance with Chapter V of the GDPR are implemented, including contracts based on standard contractual clauses adopted by the European Commission.

5 / Data retention period

Your personal data is retained only for the time necessary in relation to the purpose of our communications (for example, when you contact us via the contact form).

6 / Data security

CapeToFlow undertakes to implement appropriate technical and organizational measures to ensure the security of your data.

The personal data collected is stored in a secure environment. Individuals working for CapeToFlow are required to respect the confidentiality of the information.

CapeToFlow is committed to maintaining a high level of confidentiality by integrating the latest technological innovations to ensure data protection.

7 / Data subject rights

As an individual, you have several rights regarding your personal data, including:

• Right of access: You can request access to your data and obtain a copy at any time;
• Right to rectification: You can request correction of inaccurate or incomplete data;
• Right to erasure: You can request deletion of your data, for example when it is no longer necessary for the purposes for which it was collected or processed;
• Right to restriction of processing: You can request that CapeToFlow restrict the processing of your data, for example if you contest its accuracy or object to its processing;
• Right to data portability: You can request that your data be transferred to another controller in a structured, commonly used, and machine-readable format, where processing is based on consent or carried out by automated means;
• Right to object: You can object to the processing of your data and withdraw your consent at any time where processing is based on consent, for example in the case of marketing communications.

To exercise your rights, please contact us at: dpo@capetoflow.com

Your request will be processed within one (1) month from confirmation of your identity. You will not be charged for accessing your personal data or exercising your rights. However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. We may also refuse to process your request in such cases.

We may request additional information to verify your identity and ensure that your personal data is not disclosed to unauthorized persons. This is a security measure.

If you are not satisfied, you may lodge a complaint with the National Commission for Data Protection (CNPD): https://cnpd.public.lu/

8 / Hyperlinks

Our website may contain hyperlinks to other websites.

This Policy applies only to personal data collected via the CapeToFlow website and to the way CapeToFlow processes such data.

We are not responsible for the privacy practices of other websites.

9 / Updates to this Policy

We may modify, amend, or remove parts of this Policy at any time and will inform you of any changes by publishing an updated version of this Policy on our website.