The client is informed that our company treats Personal Data relating to them in strict compliance with all applicable laws and regulations, industry standards and other applicable requirements that relate in any way to the privacy, data protection, confidentiality or security of Personal Data and apply to the delivery of the Subscribed Services, including Euro­pean Union directives and regulations governing the protection of Personal Data, and notably the Regulation EU 2016/679 of the European Parliament and of 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 repealing Directive 95/46/EC, as may be replaced, amended or re-enacted (hereinafter “GDPR”).

The Personal Data processed is the information concerning the client that is provided to our company at the time of the con­clusion of the Contract and which is generated through use of the Subscribed Services and the performance of the Contract.

The communication of the Personal Data necessary for the execution of the contract is obliga­tory for the client.

2. Personal Data are processed by our Company insofar as this is necessary:

(a) For the performance and execution of the Contract.

(b) To meet the purposes of the legitimate interests pursued by our company or by a third party, for instance, for billing purposes, customer management, in the fight against fraud, to enforce these Terms and Conditions.

(c) For the purpose of providing evidence of a commercial transaction or any other commercial communication.

3. The client is informed that, in strict compliance with the provisions of the GDPR, our company retains and processes the relevant Personal Data after the end of the Con­tract for a minimum period of 10 years after the date of the contract.

Our company will comply with applicable legislation and any directives issued by the authorities in this regard.

4. The client is informed that, in strict compliance with the provisions of the GDPR, all or part of the Personal Data may be transmitted to the client, to third parties, the local authorities, the companies which request it with the prior consent of the client, to the public on the Internet and to the extent permitted by the law, to public organizations, administrative or legal authorities and supervisory bodies.

Personal Data may therefore be communicated or made accessible to persons outside the European Union who are not in a country offering an adequate level of protection within the meaning of the legislation on the protection of Personal Data.

5. The client is informed of their right to:

(a) Access, free of charge at reasonable intervals, the Personal Data held about him and receive additional information about how it is processed;

(b) Rectify any inaccurate Personal Data or complete any incomplete Personal Data;

(c) Seek the erasure of their Personal Data when the processing of their Personal Data is no longer necessary for the purposes described in article 2. above, when the client has withdrawn his consent to a specific processing (to the extent that consent justifies this processing), when the processing is not or no longer lawful for any reasons, when the erasure is necessary to comply with applicable law or when the client objects to the processing either in the absence of any overriding legitimate ground for such processing or when the processing is carried out for direct marketing purposes;

(d) Object at any time to processing for direct marketing purposes and to object, on grounds relating to their particular situation, to any processing based on our company’s legitimate interests;

(e) Receive the Personal Data relating to the client and transmit them to another data controller to the extent that the legitimacy of the processing lies on contractual performance and is carried out by automated means; and

(f) Seek the restriction of the processing for instance when the client con­tests the accuracy of the Personal Data or when the processing is not or no longer compliant with applicable law and the client has objected to the erasure of the Personal Data;

(g) Withdraw his consent to the processing to the extent that the legitimacy of such processing lies on consent.

Any changes to Personal Data must be notified promptly by the client to our company.

The client may exercise these rights by emailing our company at info(at)royalcaviar.com.

In addition, the client has a right to file a complaint with the Luxembourg data protection authority, the “Commission nationale pour la protection des données” (CNPD) in case they have concern about the processing of his Personal Data.

Hereafter, the contact details of the “Commission nationale pour la protection des données”:

Address: 1, avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette

Telephone: (+352) 26 10 60 -1

Fax. : (+352) 26 10 60 - 29

Website: https://cnpd.public.lu/en.html

Web-form: https://cnpd.public.lu/en/droits/faire-valoir/formulaire-plainte.html