PART ONE: Why is this Notice important to you?
This Privacy Notice relating to the protection of personal data (hereinafter, the “Privacy Notice“) is designed to inform the visitors (hereafter “you”) of the website accessible at https://www.adepa.com (hereinafter, the “Website“) about the personal data relating to you processed by ADEPA Asset Management S.A., (hereinafter, “we” or “our“, as the case may be), acting as data controller and whose registered office is located 6A, rue Gabriel Lippmann – Parc d’Activités Syrdall 5365 Munsbach, Grand Duchy of Luxembourg and registered with the Trade and Companies Register of Luxembourg under number B114.721.
We attach a great importance to the protection of the personal data entrusted to us. That is why we secure and protect your data in accordance with applicable legislation, including the General Data Protection Regulation (hereinafter, the “GDPR“) and the Luxembourg Law of August 1st 2018 relating to the organization of the Commission nationale pour la protection des données and implementation of 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.
Through this Privacy Notice, we wish to inform you about what personal data we process about you, for what purpose we use it and with whom we share it. We will detail the legal basis on which we process your data and explain your rights and the choices available to you.
 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 (General Data Protection Regulation)
PART TWO: What data about you do we process and how?
2.1 What personal data do we process about you?
We have indicated in the table below the categories of personal data that we process about you and how we collect them.
|Categories of data||Description of the data|
|Identification data of job applicants||This is data that is communicated to us by yourself when you decide to candidate to one of our job positions via the website (first name, last name, email address, postal address)|
|Job application details||This is data that is communicated to us by yourself when you decide to candidate to one of our job positions via the website: Career, Education (resume details, qualifications, employer, position, title, place of work, work history, covering letter content), Personal Interests & Characteristics, Non-professional affiliations (visa existence, hobbies, sports…)|
|Contact form data||This is data that is communicated to us through the contact form on our website : company, name, email address, content of the request|
|Professional comments and annotations during the recruitment process||Handwritten notes taken by ADEPA Staff during job interviews|
2.2 For what purposes do we use your personal data and on what legal basis do we use them?
We have indicated in the table below the purposes for which we process your personal data, the associated legal ground on which we legally process your personal data and the categories of personal data (as identified above) used for those purposes:
|Purpose||Legal basis||Categories of data|
|Processing your job application (including but not limited to registering the job applications, assessing the job applicant’s profiles, contacting the job applicants interviewing the applicants, drafting an employment contract)||Pre-contractual measures (art. 6, 1, (b) GDPR)||Identification data of job applicants; Job application details; Criminal record extract; Professional comments and annotations during the recruitment process|
|Creation of a CV-library||Legitimate interest (art. 6, 1, (f) GDPR)||Identification data of job applicants and job application details|
|Respond to requests submitted through the contact form||Your consent (art. 6, 1, (a) GDPR)||Contact form data|
2.3 Who has access to your data?
In order to pursue the purposes specified above, we will share your personal data with the following recipients:
|Categories of recipients||Reason for sharing|
|Service Providers||We collaborate with Service Providers, namely IT Service Providers and ADEPA Global Services SA as HR Service Provider, who work on our behalf and who may need access to some of your personal data to provide us with their services.|
|Other ADEPA Group entities||If you have expressed your wish to apply for a job with any other affiliate of the ADEPA Group, we will transfer your data to such entity on the basis of such consent|
|ADEPA Asset Management S.A. Staff||In some cases, our Staff will need access to your personal data in order to enable us to pursue the purposes indicated above|
Some of our service providers are located outside Luxembourg. When we transfer personal data to countries outside the European Economic Area that are considered by the European Commission as not providing an adequate level of protection for personal data, we either rely on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission to ensure adequate protection or derogations for specific situations as provided by article 49 GDPR. For further information, including a copy of the documents used to protect your personal data in such case, please contact us as indicated in section 4.2. below.
Cookies are small text files placed in the browser of your computer (or other digital device used) by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
Cookies not requiring consent
|Name of cookies||Domain that places the cookie||First-party or third-party cookie||Information processed||Purpose||Legal base for processing||Running time||Possibility for third parties to have access|
|PHPSESSID||adepa.com||First party Cookie||Session ID ( randomly generated). It doesn’t store data.||This cookie is set by the website when a user visits the site and is an essential cookie for the operation of the website This cookie does not display any identifiable or tracking information and is deleted when the user closes their browser .The cookie is strictly necessary to provide a service expressly requested by the subscriber or the final user.||Legitimate interest||Session||No|
Sharing on social networks
We do not use a “share” button that would qualify as a cookie.
2.5 Links to third party websites
On certain areas of this Website, we may provide links to third parties websites, which are not subject to this Privacy Notice. These links are provided as a convenience to you; however please be aware that we do not control such third parties or their websites and that those third parties will have a different privacy notice applying to information collected from you when you are on those third parties’ websites. We encourage you read the privacy notices of all websites carefully before providing personal data.
PART THREE: How do we protect your data?
3.1 Storage duration
We retain your personal data only for as long as is necessary to fulfill the purposes described in section 2 above or in accordance with our data retention policy.
The personal data of rejected job applicants are deleted, with the exception of certain profiles retained by us for the purpose of populating our CV-library for future opportunities (cf. point 2.2). In this case, the personal data are kept for a maximum period of 2 years, unless the job applicant objects, in accordance with our data retention policy.
Where appropriate, the personal data related to your extract of criminal record are deleted (i) without delay when the recruitment process it not successful and (ii) 1 month from the signature of the employment contract for hired candidates; in accordance with our data retention policy.
The personal data of successful job applicants are kept in their personal file as a member of our staff for 10 years after the end of their employment contract, in accordance with our data retention policy.
3.2 Security of your data
We have implemented technical and organizational measures in accordance with standard industry practices to ensure an appropriate level of security of the Personal Data processed. Nevertheless, security requires efforts from all actors involved. We thus encourage you to contribute to these efforts by taking appropriate security measures yourself, including using strong passwords and keeping all usernames and passwords (if any) confidential.
3.3 Automated decision making and profiling
No automated decision-making or profiling will be made about you as part of the personal data processing described in this Privacy Notice.
This Website is not intended for or directed to children. We do not knowingly or directly collect information from children. If you are a child, please do not use this Website and do not provide any personal data. If you are a parent or legal guardian and you believe that your child has provided us with personal information, please contact us using the contact information provided in Section 4 below.
PART FOUR: You can contact us
4.1 What are your rights?
The GDPR grants individuals certain rights with respect to their personal data. Consequently, we are at your disposal to help you to benefit from these rights. Except as limited by applicable law and subject to applicability, the following rights are granted to individuals:
- Right of access: the right to be informed about and to obtain access to the personal data processed about you;
- Right to rectification: the right to obtain that we rectify or update your personal data when they are inaccurate or incomplete ;
- Right to erasure: the right to obtain that we delete your personal data ;
- Right to restriction of processing: the right to obtain that we limit the processing of all or part of your personal data ;
- Right to object :
- the right to object at any time to the processing of your personal data for reasons relating to your particular situation ;
- the right to object at any time to the processing of your personal data for direct marketing purposes;
- Right to data portability: the right to receive a copy of your personal data in electronic format and the right to transmit such personal data for use by a third party service; and
- Right to object to automated decision making: the right not to be subject to a decision based exclusively on automated processing, including profiling, producing legal effects concerning you or significantly affecting you in a similar way.
These rights may be limited, for example, if the execution of your request reveals personal data of another person, or if you ask us to delete information that we are required to retain by law or because of compelling legitimate interests.
Once we have asked for your consent, you may withdraw it at any time without justification. If you request to withdraw your consent, this will not affect the lawfulness of the processing based on consent before its withdrawal.
To exercise your rights, please contact us using the contact information provided in section 4.2 below.
Finally, as a data subject, you have the right to lodge a complaint with a supervisory authority (in particular in the European Union Member State of your usual residence, or your place of work, or the place of the breach) if you consider that the processing of your personal data violates the applicable legislation on the protection of personal data. For your information, you will find the contact details of the Luxembourgish Supervisory Authority on its website: www.cnpd.lu .
4.2 How to contact us
If you have any questions about this Privacy Notice or wish to exercise your rights, please contact our Group Head of Legal and Compliance by Fax: (+352) 26898051 or by sending us an e-mail to firstname.lastname@example.org or by writing to us at:
ADEPA Asset Management S.A. 6A, rue Gabriel Lippmann
Parc d’Activités Syrdall L-5365 Munsbach
Grand-Duché de Luxembourg.
4.3 Effective date and changes
This Privacy Notice is in effect since 1st May, 2022. We reserve the right, at our complete discretion, to change, modify, add, or remove portions of this Privacy Notice at any time. You should check back periodically at this page to read the most recent version of this Privacy Notice as your continued use of this Website following the posting of changes to these terms will mean you acknowledge these changes.
Thank you for visiting this Website.