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Privacy Policy

SIA LUXEGEL - society with limited responsibility


Approved on 25 May 2018

The purpose of the privacy policy is to provide information to a natural person about the purpose, scope, protection and time of processing personal data during the acquisition and processing of the data. 

In cooperation with SIA LUXEGEL, personal information may be required from a person, including name and surname, phone number, e-mail address, payment information and delivery address. Information is required to provide direct cooperation – processing of the orders, delivery and invoice administration and/or the establishment and maintenance of employment relationships. At SIA LUXEGEL personal data is used in compliance with the highest safety standards.  

Personal Data Manager and its contact information

Personal Data Manager is SIA LUXEGEL, unified registration No. 675334, registered office Office 3, Burgundy Court, Forster Way, Swords, Ireland K67 EA29. SIA LUXEGEL contact information in matters regarding the processing of personal data is the telephone number +353 833 994 972 or e-mail address Inquiries about personal data processing can be made by using this contact information. 

The Scope of document application

Personal data is any information about an identified or identifiable natural person – client, co-worker, employee, job applicant or company visitor of SIA LUXEGEL. The privacy policy is applied to the provision of privacy and personal data protection regarding:

  • natural persons – employees, potential employees, clients and other service users (including the potential, former and existing ones);
  • Visitors of SIA LUXEGEL premises, including those regarding which video surveillance is executed.

SIA LUXEGEL cares about the person’s privacy and the protection of personal data, observes the right of a person to the lawfulness of the processing of personal data in accordance with the applicable regulatory enactments – the Personal Data Protection Law, Regulation No. 2016/679 of the European Parliament and 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 and other applicable laws in the field of privacy and data processing. 

Privacy policy applies to data processing, regardless of the form and/or environment, in which the person provides the data (SIA LUXEGEL website (, an e-mail format, phone or in person) and regardless of on what company systems or paper forms they are processed. 

The purpose of personal data processing

SIA LUXEGEL processes personal data for the following purposes:

  • For the provision of services and for the sale of goods:
    • for customer identification;
    • for preparing and signing agreements and/or invoices;
    • for the supply of goods and/or provision of services;
    • for the execution of warranty liabilities;
    • for customer service;
    • for reviewing and processing claims;
    • for customer retention, loyalty, satisfaction surveys;
    • for payment administration;
  • For the provision of SIA LUXEGEL service quality, for reviewing and processing claims. 
  • Within video surveillance for the safety of SIA LUXEGEL property and for the safety of persons, for the elimination of thefts and fraudulent activities in the SIA LUXEGEL premises, for the recording of criminal offences, for the identification of potential offenders. Within video surveillance the data is stored for one month. After the end of this period SIA LUXEGEL provides full automatic data deletion, if these data have not been requested before or if no criminal offences have been stated. If data has been previously requested by competent state or local government authorities or if criminal offences are detected, data is stored according to necessity.
  • For the provision of information to state regulatory institutions and the subjects of emergency operations in cases and to the extent as provided by external regulatory enactments.
  • For other specific purposes, which the person is informed about at the moment when the relevant data is provided to SIA LUXEGEL.

Processing of personal data

SIA LUXEGEL processes personal data using the capabilities of today’s technology, taking into account the existing privacy risks and the available organisational, financial and technical resources. 

Personal data can be transferred to trusted service partners, who provide specific services, such as providers of resource planning systems, undertakings providing security and safety services.  

Categories of recipients of personal data

SIA LUXEGEL does not disclose personal data or any information obtained during cooperation to third persons, except for:

  • if the data must be provided to the relevant third party within a signed agreement, in order to implement any function required for the performance of the agreement or legally applied (for example, to the bank within a settlement, to a courier service for delivery of the order outside the SIA LUXEGEL delivery area, to the provider of a resource planning system for the purpose of data storage and processing, to the security company within video surveillance for the provision of safety);
  • to persons provided by the external regulatory enactments upon their reasonable request, in accordance with the procedure and amount as provided for by the external regulatory enactments;
  • in the cases specified by the external regulatory enactments, for the protection of the legitimate interests of SIA LUXEGEL, for example by appealing to a court or other public authority against a person, who has violated its legitimate interest.

Period of personal data storage

SIA LUXEGEL stores and processes personal data, while at least one of the following criteria exists:

  • only as long as the agreement signed with the person is in force;
  • while in the order as provided by the external regulatory enactments SIA LUXEGEL or the person can exercise its legitimate interests (for example, file a complaint or bring an action in court);
  • while one of the parties has a legal obligation to store the data;
  • as long as the consent of the person for the processing of personal data is in force, unless another legal basis for processing is in place.

After the above-mentioned conditions expire, personal data is archived, deleted, or liquidated. 

Access to personal data and rights of another person

A person has the right to receive information specified by the regulatory enactments regarding the processing of his/her data. 

In accordance with the regulatory enactments, a person also has the right to request SIA LUXEGEL give access to his/her personal data and to request that it is supplemented, corrected or deleted, or the limitation of its processing regarding the person, or the right to object against processing (including the processing of personal data based on the lawful (legitimate) interests of SIA LUXEGEL) as well as the right to data portability. This right is enforceable insofar as the processing does not result from the obligations of SIA LUXEGEL imposed on it by the applicable laws and regulatory enactments and that are executed in the public interest. 

A person may apply for the exercising of his/her rights:

  • in writing in person at the SIA LUXEGEL office, by presenting a personal identification document;
  • by electronic mail, signed by a secure electronic signature.

Upon receiving a person’s request for the exercising of his/her rights, SIA LUXEGEL verifies the identity of the person, evaluates the request and enforces it in accordance with the regulatory enactments. 

SIA LUXEGEL replies to the person via registered mail or e-mail using his/her provided contact information, taking the method of receiving the reply indicated by the person into account as far as possible.  

SIA LUXEGEL ensures the execution of data processing and protection in accordance with the requirements of the regulatory enactments and in the event of a person’s objections, takes the reasonable measures to resolve the complaint. However, if it is not possible, the person has the right to contact the supervisory authority – the Estonian Data Protection Inspectorate. 

Communication with the person

SIA LUXEGEL communicates with the person using the contact information indicated by the person (telephone number, e-mail address, postal address). SIA LUXEGEL executes communication on the performance of the service agreement on the basis of the signed agreement and/or issued invoice (for example, coordination or modification of service delivery, billing information, etc.). 

Commercial messages

SIA LUXEGEL can use personal data in marketing and communication activities to provide a person with information about up-to-date offers and news that might be of interest to the person. A person may refuse to receive these promotional items at any time in one of the following ways:

  • using the automated option provided in the commercial communication to refuse to receive further notifications by clicking on the waiver notice at the end of the relevant commercial communication (e-mail);
  • by sending an e-mail to;
  • by calling the SIA LUXEGEL office +353 833 994 972.

SIA LUXEGEL terminates the sending of commercial notifications, as soon as a person’s request is processed. Processing of the request can take up to one business day.  

SIA LUXEGEL shall never allow the use of personal data for advertising and communication purposes from third parties. 

Other regulations

SIA LUXEGEL has the right to supplement the Privacy Policy by making the current version available to the person on the SIA LUXEGEL website – 

Links may be published on the SIA LUXEGEL website to third-party websites that have their own terms of use and personal data protection, which SIA LUXEGEL is not liable for.

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