Article 01Preamble
ADVENA Sàrl is committed to protecting the privacy and personal data of visitors to its advena.lu website and of its clients.
This privacy policy describes how we collect, use, store, and protect your personal data, in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) and the Luxembourg law of 1st August 2018 on the organization of the National Commission for Data Protection and on the general data protection regime.
Article 02Data controller
The controller responsible for processing your personal data is:
ADVENA Sàrl
18, rue de l'Industrie
L-8399 Windhof (Koerich)
Grand Duchy of Luxembourg
Luxembourg RCS number: B307492
For any question regarding the protection of your data, you may contact us at hello@advena.lu.
Article 03Data collected and purposes
We collect the following categories of personal data:
3.1 Identification and contact data
When you contact us through our form or by email, we collect:
- your first and last name;
- your business email address;
- your phone number (if provided);
- your company name (if provided);
- the content of your message and the service concerned by your request.
Purpose: to respond to your request, provide the information you requested, and establish a possible contractual relationship.
3.2 Technical browsing data
When you browse our site, we collect the following via Vercel Web Analytics:
- the pages visited and the timestamp of the visit;
- the type of device and browser used;
- the referral source (external link, search engine);
- the country of origin of the connection (without precise identification).
This data is anonymized by Vercel at the point of collection. It cannot be used to identify you personally and is not associated with any cookie or persistent identifier.
Purpose: to understand the site's audience, improve its content, and identify high-performing pages and any malfunctions.
3.3 Customer relationship data
When you become an Advena client, we process the data required to carry out the engagement: billing information, company data, and documents provided in connection with the service. This data is described in detail in the applicable service agreement and in the Terms and Conditions.
Article 04Legal bases for processing
The processing of your personal data relies, depending on the case, on one of the following legal bases:
- the performance of a contract or pre-contractual measures at your request (Article 6.1.b GDPR), for example when you fill out our contact form;
- the legitimate interest of ADVENA Sàrl (Article 6.1.f GDPR), for example for anonymized audience statistics and website security;
- compliance with legal obligations (Article 6.1.c GDPR), for example for the retention of accounting documents;
- your explicit consent (Article 6.1.a of the GDPR), for optional processing, where required.
Article 05Retention periods
Your personal data is retained for the following periods:
- Prospect and lead data (contact form): 3 years from the last active contact, then deletion or anonymization.
- Customer data (contractual relationship): for the entire duration of the relationship, then 5 years from the end of the contractual relationship, in compliance with legal obligations and in accordance with the Terms and Conditions.
- Accounting and invoicing data: 10 years from the close of the relevant financial year, in accordance with applicable Luxembourg regulations.
- Technical browsing data (Vercel Analytics): retained in aggregated and anonymized form, with no specific retention period applicable to identifying data (the data is not personally identifiable).
Article 06Data recipients
Your personal data is accessible, strictly to the extent of their respective needs, to:
- to authorized staff of ADVENA Sàrl;
- to our technical subcontractors, within the scope of their assignment and under a confidentiality undertaking (in particular our cloud host, our ERP vendor, and our transactional email providers);
- to the competent administrative or judicial authorities, where a legal obligation requires us to do so.
Your data is never sold, rented, or transferred to third parties for commercial purposes.
The website forms record your request directly in our customer relationship management tool (Odoo CRM), operated by ADVENA Sàrl. No third-party form-relay provider is involved in this collection. The data you enter is processed by our authorized staff for the sole purpose of responding to your request, in accordance with the purposes described in this document.
Article 07Transfers outside the European Union
Some of our technical subcontractors operate infrastructure located outside the European Union, notably in the United States. This is the case for our cloud host.
These transfers are governed by the safeguards provided for in Chapter V of the GDPR, in particular:
- the standard contractual clauses adopted by the European Commission;
- recognized data protection certifications (Data Privacy Framework, ISO 27001);
- the technical and organizational measures for encryption and pseudonymization.
You can obtain a copy of the applicable safeguards by contacting us at hello@advena.lu.
Article 08Your rights
In accordance with the GDPR, you have the following rights regarding your personal data:
- right of access (Article 15 GDPR): obtain confirmation that your data is being processed and obtain a copy thereof;
- right to rectification (Article 16 GDPR): have inaccurate or incomplete data corrected;
- right to erasure (Article 17 GDPR): request the deletion of your data, subject to our legal retention obligations;
- right to restriction of processing (Article 18 GDPR);
- right to data portability (Article 20 GDPR): receive your data in a structured, machine-readable format;
- right to object (Article 21 GDPR): object to the processing of your data on legitimate grounds;
- the right to set post-mortem directives regarding the fate of your data.
To exercise any of these rights, contact us at hello@advena.lu specifying your request. We will respond within a maximum of one month.
Article 09Data security
ADVENA Sàrl implements appropriate technical and organizational measures to protect your personal data against loss, unauthorized access, disclosure, alteration, or destruction. These measures include, in particular, the encryption of communications (HTTPS throughout), restricting data access to authorized staff only, regular backups, and ongoing staff training on security matters.
Article 10Cookies and trackers
Our website uses a minimal number of cookies, strictly functional ones. No advertising cookies, no behavioral tracking cookies, and no third-party cookies for marketing purposes are placed on your device.
A detailed list of the cookies used is available on our dedicated page: Cookie policy.
Article 11Amendments to the policy
ADVENA Sàrl reserves the right to amend this privacy policy at any time, in particular to bring it into line with legislative developments or with the practices of the website.
The date of the last update is shown at the top of the document. In the event of a substantial change, we will inform you by any appropriate means (a notice on the website, an email to active clients).
Article 12Contact and complaints
For any question regarding the processing of your personal data, or to exercise your rights, contact us:
- By email: hello@advena.lu
- By mail: ADVENA Sàrl, 18 rue de l'Industrie, L-8399 Windhof, Luxembourg
If, after contacting us, you believe that your rights are not being respected, you have the right to lodge a complaint with the National Commission for Data Protection (CNPD):
Commission nationale pour la protection des données
15, boulevard du Jazz
L-4370 Belvaux
Phone: +352 26 10 60 1
Website: cnpd.public.lu