1) Legal notice & privacy

Introduction

This Legal Notice & Privacy policy applies to all visitors (referred to in this document as “visitors” or as “you”) of CTI Systems S.à r.l. (hereinafter called “CTI Systems”, "us", "we", or "our") website at www.ctisystems.com. This policy does not form part of any contract nor does it establish any obligation to provide services. We reserve the right to modify, change or update the Legal Notice & Privacy Policy.

Website Owner and Contact Details

CTI Systems S.à r.l.  
Op der Bréimicht 11
9779 Lentzweiler
Luxembourg

cti@ctisystems.com
+352 2685 2000

VAT ID: LU28752252
Registry Nr: B94647

2) Conditions of access to the website and modifications

Once the visitors click the button ACCEPT, they accept the version of the terms, which is in force at the time of the access. 

The website is accessible at all times anywhere in the world. The visitors, who connect to it, bear sole responsibility for compliance with the legislation and/or regulations in force in the country where they reside or from where they connect to the website. The visitors acknowledge that they have verified that the used computer configuration does not contain any viruses or any other malicious software and that it operates perfectly.

The website’s applicable conditions of use are those available and published on the website at the time it is consulted by the visitors. The nullity or non-validity of a provision of these conditions of use shall not affect the validity of the remaining provisions.

3) Copyright & trademarks

Website: © 2012-2021 CTI Systems. All rights reserved.

Photos & Illustrations: © CTI Systems.

Any and all intellectual property rights associated with the website and its contents (including, but not limited to texts, graphic images, audio, videos, html codes, buttons, trademarks, software, logos, e-catalogues) are sole property of CTI Systems, unless otherwise clearly indicated in a contract or in any other way perceivable as third party rights. The content may not be sold, distributed, transmitted, copied, modified or decompiled, in any way, without the prior written consent of CTI Systems or the owner of the intellectual property right. Any unauthorised use of the content is expressly prohibited and may constitute a violation of copyright law, trademark, patent law or other industrial property rights.

4) Production & hosting

MUM digital agency
Strategy | Marketing | Websites | Applications | Design

3, Om Knupp
L-9991 Weiswampach
Luxembourg
www.mum.lu

5) Disclaimer

Although all information on the website has been checked thoroughly, the visitors should not take the accuracy of the information for granted. In any case, CTI Systems cannot be held responsible for the accuracy of the information provided nor give a guarantee that the details are complete, accurate and current. All information provided is subject to modification, error or omission.

This website may contain links to websites not operated, controlled or supervised by CTI Systems. If the visitors follow these links, the visitors will leave the website, and will be subject to the terms of use and privacy policy applicable to those websites. By providing such links, CTI Systems makes no judgment or warranty with respect to such other websites and takes no responsibility for contents appearing on third parties websites to which the site makes hyperlinks or from which it receives hyperlinks. Neither does CTI Systems accept any responsibility for the availability or the contents of such websites or any liability for damage resulting from the use of such contents, of whatever form.

The visitors of this website declare that they agree to access and to use the website and its content at their own risk. CTI Systems cannot be held liable for any direct, indirect, or other losses or damages of whatsoever kind resulting from access or use of this website, from inaccuracies or omissions in this website, from any decisions the visitors make based on information contained in this website, from viruses or non-accessibility of this website. In case of failure of partial or all transactions caused by abnormal conditions that cannot be controlled by CTI Systems, such as force majeure, act of gods, accident or technical obstacles, CTI Systems has the right to temporarily or technically stop the transaction and bear no liabilities.

6) Privacy policy for website visitors

General Information

CTI Systems S.à r.l. is committed to protecting the privacy and security of your personal information. This privacy policy describes how we collect and use personal information about you, in accordance with the Regulation (UE) 2016/679 of the European Parliament and of the Council of 27 April 2016, commonly called General Personal Data Regulation (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

It is important that you read this policy, when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

You have the right to object, on grounds relating to your particular situation, to the processing of your personal data at any time based on our legitimate interests. Please refer to sections “Purposes and legal bases of data processing” and “Right to object” of this document for further information.

Important note: Most of the time we collect personal data directly from the data subject. Should you provide information, including personal data, on behalf of a third party individual (e.g one of your employees), you undertake to do so in compliance with the applicable data protection laws, and in particular to inform this third party of such processing and to provide him/her with this privacy policy.

7) Controller information

Name: CTI Systems S.à r.l.

Address: Op der Bréimicht 11, 9779 Lentzweiler, Luxembourg

Contact: Data Protection Responsible, dpo@ctisystems.com

8) Purposes of processing

CTI Systems uses the collected personal data for one or more of the following purposes:

  • The processing is necessary for the performance of a contract or for entering into a contract with you;
  • The processing is necessary for us to comply with legal obligations, for instance to allow us to comply with applicable commercial laws and any regulatory obligations and to allow us to respond to requests and comply with requirements from public authorities;
  • The processing is necessary for our or a third party’s legitimate interests, for example, (i) in the context of services: to provide and maintain our services, to answer any of your queries or provide requested services, to allow you to participate in interactive features of our services when you choose to do so, to notify you about changes to our services, to provide customer support, to monitor the usage of our services and gather analysis or valuable information so that we can improve our it in accordance with applicable laws, to detect, prevent and address technical issues, to provide you with news and general information about other goods, services and events which we offer in accordance with applicable laws, to present our services and their contents in a suitable and effective manner, to enforce our policies and other agreements; (ii) outside the context services: to manage our relationships with our suppliers, services providers and subcontractors as well as to prevent fraud, manage litigation and to protect the rights, property, or safety of CTI Systems and their affiliates;
  • You have given your prior consent, for example, to receive commercial communications from us where such consent is required, or to receive third parties or for us to use third party cookies;
  • We may use your personal data to contact you at your request, or via newsletters, marketing, sales, events or promotional materials and other information that may be of interest to you in compliance with applicable laws. Regarding commercial communications we send to you where your consent is not legally required, you may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us directly. We may use your photograph when attending our events within our newsletters, websites and/or print publications;
  • No automated decisions will be made in relation to the personal data we process.

Disclosure of Personal Data

To achieve the above purposes, we may disclose personal data to the following recipients: other entity members of CTI Systems, our commercial partners, subcontractors, external service providers, professional advisors, purchasers or sellers of our assets (if any), as well as public organisations, administrative or legal authorities and supervisory bodies, if applicable.

9) Types of personal data and retention periods

CTI Systems will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

The data may include information such as your computer's Internet Protocol address (IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the location, the time spent on those pages, unique device identifiers and other diagnostic data.

​When you access the service by or through a mobile device, this usage data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, location, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We may also be required to retain data longer than described below if necessary for an ongoing legal process or to comply with a decision from a court or authority.

While using our service, we may ask you to provide us with personal data, which may include but is not limited to:

  • Identification information such as first name and last name, place of birth, birthdate;
  • Contact information such as email address, phone number, address, postal code, city, country of residence;
  • Business related information such as the company you work for or represent, role, position, country of work;
  • Your name and photograph while attending our events;
  • Products purchased;
  • Information on professional experience (resume, cover letter, hobbies and areas of interest);
  • Personal data contained in cookies;
  • Any other type of personal data provided to us in the course of the services.

CTI Systems collects your personal data mainly directly from you but also from Cookies and other similar technologies. For more information, please see the cookie policy below.

10) Recipients of personal data

  • Outside legal counsels;
  • IT system management service providers;
  • Information security service providers;
  • CTI group companies;
  • Third party as part of a merger or an acquisition.

Please note that while most recipients are located in Luxembourg or elsewhere in the EU or EEA, some of the above-listed recipients may be located or process data in third countries, depending on the person whose data is being processed and the situation at hand. If CTI Systems and/or its service providers processing data on behalf of CTI Systems transfer your personal data to countries outside the EU or the EEA, the transfer is subject to standard data protection clauses adopted by the EU Commission or other appropriate safeguards such as binding corporate rules, unless the EU Commission has found that the level of data protection is adequate in the country in question.

11) Security of personal data

The security of your personal data is important to us. CTI Systems uses Security Sockets Layer (SSL) encryption technology to encrypt sensitive personal information before it travels over the Internet and state-of-the art technology to protect its network against intrusion or malicious program code, but cannot guarantee the non-existence of any viruses or other malicious code on the website. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

The security of your personal data also means that we undertake to use all our best efforts to protect it from data breaches. We implement adequate technical and organizational security measures, such as, depending on the equipment, password protection, physical locks, etc., to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected.

Access to personal data is permitted to our employees for the sole purpose of performing their professional duties. They are subject to a confidential obligation and are notably provided with training and documentation in order to improve their practical skills and knowledge on data protection issues.

12) Your rights

In relation to your personal data, you have the right to:

  • Access the personal data held about you and receive additional information about how it is processed;
  • Rectify or complete any inaccurate or incomplete personal data;
  • Seek the erasure of your personal data when its processing is no longer necessary for the purposes described above, when the processing is not or no longer lawful for any reasons, when you have withdrawn your consent to the processing according to applicable laws, when the erasure is necessary to comply with applicable laws or when you object to the processing in the absence of any overriding legitimate grounds for such processing;
  • Object, on grounds relating to your particular situation, to any processing based on our legitimate interest;
  • Receive your personal data and transmit it to another data controller to the extent that the legitimacy of the processing lies on contractual performance;
  • Withdraw any consent given to the processing at any time to the extent that your consent justified such processing;
  • Seek the restriction of the processing, for instance, when you contest the accuracy of the personal data or when the processing is not or no longer compliant with the exception of storage, only processed in specific cases (e.g. for the establishment, exercise or defence of our legal claims).

Your Right to Lodge a Complaint

We will respond to individual complaints and questions relating to privacy and will investigate and attempt to resolve all complaints. We will only be able to answer favourably to any of the above requests related to the right to oppose, right of erasure and right of restriction provided that it does not interfere with or contradict one of our legal obligations (e.g. legal obligation to keep the related personal data) or due to any other impediment that would justify that we would not be able to grant such requests. We undertake to handle each request free of charge and within a reasonable timeframe (in any case no longer than one (1) month).

In case we do not comply with applicable data protection legislation, you have the right to lodge a complaint with a supervisory authority. The supervisory authority in Luxembourg is the Commission nationale pour la protection des données, 15 Boulevard du Jazz, L-4370 Belvaux, LUXEMBOURG.

13) How to contact us

We are happy to assist you in case you have any questions or concerns over the processing of your personal data or the exercise of your rights. In order for us to provide you with sufficient information and pragmatic advice, we ask you to address your questions or comments in writing to dpo@ctisystems.com.

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

14) Cookies policy for website visitors

Cookies are small, innocuous text files that are downloaded to your device by websites you visit. They allow the website to recognise your device and store some information about your location and past actions.

The website uses cookies to enhance the visitor’s experience and improve performance.

​You can find more information about cookies at www.allaboutcookies.org.

15) Cookies setting and opting out

You can choose whether or not to accept cookies using the toggle on this page. Some cookies are essential cookies and cannot be turned off using the toggle. As the website cannot operate without the use of the website's cookies, CTI Systems requests the visitors who decline cookies to leave the website and abandon their browsing session immediately. 

Please find detailed information on how to disable cookies here (http://www.allaboutcookies.org/manage-cookies/).

The cookies we use are listed below. In order to remove these cookies you will need to visit the third party sites and follow the instructions in their cookies notices. Alternatively, follow the instructions under the changing cookie settings in your browser heading.

16) Cookies we use

We have listed these cookies, what they are used for and how long they are retained:

  • Technical cookies: technical cookies, which last until you delete the cookie cash history on your computer, are used to operate our services (set user language preferences, user authentication).
  • Functional cookies: our functional cookies enable to set acceptance of the cookie policy. This cookie is stored on your computer until you delete your cookie cash history.
  • Session cookies: session cookies preserve the users' session state across page requests. It is used to collect anonymised marketing-relevant data about a user during a single visit: originating website, search engine or marketing campaign, number of page views, first and last page visited, session duration, anonymised IP address. When engaging with the website through a form or any other explicit contact feature, this session information is transmitted to the website publisher and is correlated with personal data the user deliberately submits. The publisher processes the personal information received from the user for the sole purpose of replying to the user’s inquiry and for any future email communications resulting from possible business relationships between the user and the publisher. This data might be stored on the server for backup/logging/statistical purposes, please refer to the section “Processing of Personal Data”.
  • Analytic Cookies: we use analytic cookies from third parties to monitor and analyse, together with anonymised IP addresses, how visitors use the site. The information generated by the cookie about the visitors’ use of the site are stored for the duration of two (2) years.

Google

By using the website, the visitors consent to the processing of data about the visitors by Google in the manner and for the purposes set out above. If this is not the case, the visitors should adapt their cookies settings as explained below.

The visitors have the option to disable Google Analytics Tracking on the website by clicking this link. This will place an opt-out cookie on the visitors’ device that will prevent the visitors’ sessions from being tracked, as long as the cookie remains installed on the visitors’ system.

The website may use Google Maps API, in order to visually display geographical information or 360° virtual tours of the locations(s) of CTI Systems. By using Google Maps, data about map usage is collected, stored in cookies and transferred to Google.

More information about data processing by Google can be found in the Google Privacy statement at: https://policies.google.com/privacy.  

Embedded YouTube Videos

When visiting a page containing an embedded YouTube video, information about the visitors’ view and usage of this video is collected, stored in cookies and transferred to YouTube. If the visitors’ browser is authenticated to YouTube, the visitors’ personal identification may also be transferred to YouTube. The visitors may avoid this personal identification by logging out of YouTube before using the Website.

More information about Youtube’s privacy policy and opt-out options can be found at: https://www.youtube.com/t/terms.

Embedded Facebook Plug-Ins

The publisher uses the Facebook Plugin, a service provided by the social media network facebook, Inc. (“Facebook”).

When the user visits a page containing an embedded Facebook Plugin (feed, Like buttons, sharing buttons), the plugin’s files are loaded from Facebook servers and Facebook will thereby obtain information about the users IP address, the page he visited as well the date, time of this visit.

In case the user’s browser has previously logged in to the users account on the the Facebook.com website, Facebook will be able to identify the user and associate his visit to the publisher’s website to his account. Also, any interaction of the user with the Facebook plugin is tracked by Facebook and may be published on the users Facebook profile.

The user may refuse this behavior by logging out of Facebook.com prior to his visit of the publisher’s website, or by making use of a browser add-on blocking the tracking by Facebook.

More information about Facebook’s privacy policy and opt-out options can be found at https://www.facebook.com/policy.php.

 

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