Welcome to Onda Holding S.A.’s privacy notice.
Last updated: May 2023
This privacy notice provides information on how Onda Holding SA collects and processes your personal data.
Important information and who we are
Onda Holding S.A. is the controller and responsible for your personal data.
Onda takes its data protection obligations very seriously. If you have any questions about this privacy notice or our data protection practices please contact us.
Contact details
Onda Holding S.A, registered in Luxembourg under company number B266272 (“we”/“us”/”our”). Our registered office is at 33, rue du Puits Romain, L-8070, Bertrange.
Email address: [email protected]
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data – your name
- Contact Data –your email address, telephone number and business address
- Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
- Profile Data – includes your username and password
- Usage Data – details you provide us on how you use our website and software
We also collect, use and share aggregated data as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We are required to conduct various checks to comply with money laundering and other applicable laws and regulations. This may include data referring to political affiliation and trade union memberships.
We collect this data through our direct interaction with you or via your employer in order to enable us to set you up with using our software and to interact with us when using it and providing your feedback.
How we use your personal data
We will only use your personal data for the purpose for which we collected it which include the following:
- To register you as a new user to use our software – the legal basis we use is performance of the contract we are about to enter into or have entered into with you.
- To manage your relationship with us – the legal basis we use is: (i) performance of the contract we are about to enter into or have entered into with you; and (ii) necessary to comply with a legal obligation.
- To improve our products/services, marketing or customer relationships (including feedback from you and analysing use of our software) – the legal basis we use is where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
- To recommend products or services which may be of interest to you – the legal basis we use is where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
- To comply with a legal obligation – the legal basis we use is compliance with a legal obligation.
How we share your personal data
We may share your personal data within the Onda group and with external third parties (such as cloud providers).
International transfers
We may transfer, store and process your personal data outside the EU and the UK (as for transfers between the EU and UK they are deemed by each other to provide an adequate level of protection for personal data and therefore do not require legal transfer mechanisms).
Where we transfer your personal data out of the EU or the UK, we will always do so using the permitted legal transfer mechanisms.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU or the UK.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you, the right to rectification or erasure of your personal data, the right to restrict processing of your personal data and the right to object to processing.
You can contact the Commission Nationale pour la Protection des Données (CNPD) in Luxembourg.
We would like the opportunity to resolve any issues you might have with us first before you contact a regulators so please contact us: [email protected]
How long do we keep your data ?
We keep your personal data in line with set periods calculated using the following criteria:
- How long it is reasonable to keep records to show we have met the obligations we have to you and by law;
- Any periods for keeping information with are set by law or recommended by regulators, professional bodies or associations;
- Any relevant proceedings that apply.
If you would like more information about how long we will keep your information for, please contact us at [email protected]
Further details
If you are looking for more information on how we process your personal data including on data security, data retention and lawful processing bases, please contact us for further details.