Privacy Policy

 

At Paperjam S.A. (“we”, “our” or “us”), we take confidentiality and privacy very seriously. We have developed this Privacy Policy (the “Privacy Policy”) to clearly define and explain how we are committed to protecting your privacy rights, how we collect personal data through your use of our websites (www.wearepaperjam.lu, paperjam.lu), our newsletters, and our mobile applications (the “Service”), and how we use and disclose this personal data.

 

All processing of your personal data is carried out in accordance with applicable data protection laws, including but not limited to the European General Data Protection Regulation 2016/679 of 27 April 2016 (the “GDPR”).

 

By using our Services, you acknowledge that you have been informed of this Privacy Policy and that you understand and accept its contents.

 

 

Definitions

 

Personal Data

“Personal Data” means any information relating to an identified or identifiable natural person.

 

Usage Data

“Usage Data” means data collected automatically, generated by the use of the Service or from the Service’s own infrastructure (e.g. the duration of a page visit).

 

Cookies

“Cookies” are small files stored on your device’s hard drive or browser memory when you use our Services.

 

Data Controller

“Data Controller” means the person who, alone or jointly with others, determines the purposes and means of the processing of personal data.

For the purposes of this Privacy Policy, we are the Data Controller of your Personal Data.

 

Processors (or Service Providers)

“Processor” (or “Service Provider”) means any person (other than an employee of the Data Controller) who processes personal data on behalf of the Data Controller. We may use multiple service providers in order to process your personal data more efficiently.

 

Data Subject

“Data Subject” means any identified or identifiable natural person to whom personal data relates.

 

User

“User” refers to any individual using our Services. The User corresponds to the Data Subject, i.e. “you”, “your”.

 

 

Collection of Information

 

We collect various types of information, including Personal Data, to provide you with a personalized service and improve it.

 

We make every effort to keep the Personal Data we hold accurate. However, Data Subjects who provide Personal Data are responsible for promptly informing us of any changes.

 

You have the right to refuse to provide us with Personal Data; however, please note that failure to provide certain information (e.g. data required to contact you) may prevent us from responding or providing services, or from entering into or maintaining an agreement with you.

 

When do we collect your Personal Data?

We collect your Personal Data in particular when:

 

• you browse our websites or use our mobile apps;

• you log in to our Services;

• you attend an event;

• you subscribe to newsletters;

• you apply for a job or sign up for job alerts;

• you use our online store and purchase products;

• you request to be contacted;

• you apply to become a member, speaker or sponsor;

• you download documents or our applications.

 

Important note: most of the time, we collect Personal Data directly from you. If you provide information (including Personal Data) on behalf of someone else (e.g. an employee), you agree to do so in accordance with applicable data protection law, including informing the third party of the processing of their data and providing them with this Privacy Policy.

 

Types of Personal Data collected

 

• Identification data: name, surname, date and place of birth

• Contact details: email, phone number, address, postal code, city, country of residence

• Professional information: employer/company represented, role, position, country of work

• Your name and photo when attending our events

• Hobbies and areas of interest

• Purchased products

• Professional experience (CV, cover letter)

• Personal Data in cookies

• Any other data you provide when using our Services

 

Usage Data

We may collect information your browser sends whenever you visit our Service: IP address, browser type and version, pages visited, time/date, location, time spent, unique device identifiers, diagnostics.

 

When accessed via mobile device: device type, unique ID, IP address, OS, browser, location.

 

Location Data

We may use and store information about your location (“Location Data”) to provide features, improve and personalize the Service.

 

Cookies and Tracking Data

We use cookies and tracking technologies (web beacons, tags, scripts) to monitor activity and store information.

 

Types include:

 

• Session cookies (temporary, for Service operation)

• Preference cookies (to remember settings/preferences)

• Security cookies (protect login info)

• Advertising cookies (serve relevant ads)

 

We also use third-party cookies (Google Analytics, Google Ads/DoubleClick, etc.) — see full list in the original French text with links to their privacy policies.

 

 

Purposes of Processing

 

We process Personal Data based on:

 

• Contract performance or to enter into a contract with you

• Compliance with legal obligations

• Our legitimate interests (or those of a third party), including: providing and maintaining the Service, responding to requests, customer service, monitoring usage, detecting/preventing technical issues or fraud, marketing (in compliance with applicable law), event photos in newsletters/publications, supplier relations, dispute management, protecting our rights, property and safety

• Your consent (where required by law, e.g. marketing communications, third-party cookies)

 

No automated decision-making is carried out on the basis of Personal Data.

 

 

Data Retention

 

We retain Personal Data only as long as necessary for the purposes outlined, and to comply with legal obligations, resolve disputes, and enforce agreements. Usage Data is generally retained for shorter periods, unless needed for security, improved functionality, or legal compliance.

 

 

Disclosure of Data

 

We may disclose Personal Data to:

 

• Paperjam S.A. group entities

• Business partners, subcontractors, external service providers

• Professional advisors

• Buyers/sellers of our assets

• Public bodies, administrative or judicial authorities, regulators

 

 

Data Transfers

 

Your Personal Data may be transferred and stored outside your country or the EEA, where data protection laws may differ. If so, transfers will be covered by adequate safeguards (e.g. EU standard contractual clauses) or otherwise permitted by law.

 

 

Data Security

 

We use appropriate technical and organizational security measures, but no method of transmission or storage is 100% secure. Employees have access to Personal Data only as required for their duties and are bound by confidentiality.

 

 

Your Rights

 

You have the right to:

 

• Access your data and receive information on its processing

• Rectify inaccurate or incomplete data

• Request erasure of your data in certain circumstances

• Object to processing based on legitimate interest

• Receive and transmit your data (data portability)

• Withdraw consent at any time (where processing is based on consent)

• Restrict processing in certain circumstances

 

Requests are free of charge and handled within one month (unless prevented by overriding legal obligations).

 

You may lodge a complaint with Luxembourg’s Commission Nationale pour la Protection des Données (CNPD) or your local data protection authority. (Full CNPD contact details included in original.)

 

 

Service Providers

 

We may employ third-party companies and individuals to facilitate the Service, perform tasks, or process payments. These providers have access to Personal Data only to perform these tasks and must not use or disclose it otherwise.

 

Payment processors used: Google Play, Stripe, PayPal/Braintree (see their respective privacy policies).

 

 

Links to Other Sites

 

Our Service may contain links to third-party websites. We are not responsible for their content or privacy practices.

 

 

Children’s Privacy

 

Our Service is not directed to anyone under 18. We do not knowingly collect data from children. If we discover such collection, we will delete it.

 

 

Changes to this Privacy Policy

 

We may update this Privacy Policy from time to time. Updates will be posted on this page, with a new “effective date” at the top. In case of material changes, we will notify you via email and/or a notice on the Service before the changes take effect. Continued use of the Service after changes constitutes acceptance.