Privacy Policy

Data Controller

Winova S.à r.l.-S is the data controller for the purposes of the GDPR:

Personal Data We Collect

We collect the following categories of personal data:

Information you provide directly

• Contact information: Name, email address, phone number
• Business information: Company name, job title, industry
• Communication data: Messages, inquiries, and correspondence
• Marketing preferences: Consent for newsletters and promotional materials

Information collected automatically

• Technical data: IP address, browser type, operating system
• Usage data: Pages visited, time spent on site, referring websites
• Device information: Device type, screen resolution, language preference

Legal Basis for Processing

We process your personal data based on the following legal grounds under Article 6 of the GDPR:

• Contract performance: To provide our services and respond to inquiries
• Legitimate interests: To improve our services and website functionality
• Consent: For marketing communications and non-essential cookies
• Legal obligation: To comply with applicable laws and regulations

How We Use Your Data

We use your personal data for the following purposes:

• Providing and improving our web development, photography, and content creation services
• Responding to inquiries and providing customer support
• Processing orders and managing project workflows
• Sending marketing communications (with your consent)
• Complying with legal and regulatory obligations
• Analyzing website usage to enhance user experience
• Protecting against fraud and ensuring website security

Data Sharing and Transfers

We may share your personal data with:

• Service providers: Trusted third-party vendors who assist in our operations
• Professional advisors: Lawyers, accountants, and consultants when necessary
• Legal authorities: When required by law or to protect our rights

We do not sell your personal data to third parties. Any data sharing is done in compliance with GDPR requirements.

International Data Transfers

If we transfer your data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including adequacy decisions or Standard Contractual Clauses approved by the European Commission.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy:

• Customer data: 7 years after last interaction for legal and tax purposes
• Marketing data: Until consent is withdrawn or 3 years after last engagement
• Website analytics: 26 months from collection
• Job applications: 6 months unless consent given for longer retention

Your Data Protection Rights

Under the GDPR, you have the following rights:

• Right of access: Request a copy of your personal data
• Right to rectification: Correct inaccurate or incomplete data
• Right to erasure: Request deletion of your personal data ("right to be forgotten")
• Right to restriction: Limit how we process your data
• Right to data portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, please contact us at info@winova.lu.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, regular security assessments, access controls, and staff training.

Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your browsing experience and analyze website usage. For detailed information about our use of cookies, please see our Cookie Policy.

Children's Privacy

Our services are not directed to children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected such data, we will take steps to delete it promptly.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "last updated" date.

Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

Supervisory Authority

You have the right to lodge a complaint with the Luxembourg data protection authority (CNPD) if you believe that our processing of your personal data violates the GDPR.