The following terms and conditions of use (hereinafter the " Terms and Conditions of Use " or " CGU ") apply to and govern the use of the website (hereinafter the " Website ") of eSST.
eSST reserves the right to modify these Terms and Conditions of Use at any time in its sole discretion. The Terms and Conditions so modified shall automatically apply to the Website.
eSST strives to ensure that users ("Users") have access to the Users "You may access the Website 24 hours a day, 7 days a week, subject to maintenance and the limitations set forth in these TOU.
By using the Website, you understand and agree that eSST will perform maintenance on the Website and that any interruption of access to the Website due to such maintenance shall not constitute a breach by eSST of these TOU.
By using the Website, you understand and agree that access to it is provided " as is " and " as available "without warranty of any kind, express or implied.
By using the Website, you understand and agree that its use is governed by technical compatibility and interoperability requirements and restrictions (the " Technical Conditions "). You agree to comply with these Technical Terms.
By using the Website, you confirm that you have the appropriate computer equipment to use the Website and agree not to use any device or take any action that may cause harm to eSST.
By using the Website, you acknowledge the characteristics of the Internet and agree that eSST shall not be responsible for any interruptions to the Internet Protocol system resulting from any act of the Internet service provider or any act beyond the control of eSST.
You will take all necessary actions to limit the damage that could result from a possible corruption of your computer equipment while accessing the Website.
If you fail to comply with any of your obligations under these TOS, including by using the Website for illegal purposes, eSST may suspend or terminate your access to the Website without prior notice.
By using the Website, you warrant at all times that you will not use the Website to:
- Undertake or promote illegal activities, or misleading or deceptive information;
- unauthorized or illegal copying of copyrighted works, patents or trademarks;
- Stimulate, induce, or encourage the sending of e-mail, chain letters, unsolicited mass e-mail, instant messages, junk mail, or unsolicited mail;
- promote or encourage any criminal act or activity, or provide guidance or instructions on promoting criminal activities, invading privacy, or spreading or creating computer viruses;
- Solicit passwords or personal information from other users for illegal commercial purposes;
- distribute, reproduce, publish or modify materials protected by copyrights, trademarks or other proprietary rights owned by third parties in any way without their prior consent.
eSST is not able to guarantee continuous and permanent availability of the Website. eSST will use its best efforts to provide availability of the Website in the most efficient manner possible for the User, subject to maintenance periods.
In accordance with Article 3, eSST reserves the right to interrupt the use of the Website in order to carry out maintenance operations. The interruption of access to the Website shall not entitle the User to compensation.
As part of the use of the Website, you may open a ticket to report technical problems if the Website is unavailable due to technical failures caused by eSST, and if these failures are not resolved in a timely manner, eSST will use its best efforts to resolve these failures as soon as possible, provided that :
- you have described them precisely when you opened the ticket,
- you cooperate fully with eSST and that,
- such failures are not the result of misuse of the Website by you or an attack by third parties.
eSST shall not be liable for the unavailability of the Website or for any loss of data resulting from your fault or default.
More generally, eSST declines all responsibility in case of interruption or malfunction of the Website resulting from:
- Your failure to comply with these TOU, the Technical Terms or eSST's recommendations;
- Your improper or unlawful use of the Website;
- Cases of force majeure;
- Events dependent on third parties such as telecommunication operators;
- Of your acts or omissions.
While using the Website, you may be required to click on links that direct you to third party service providers. eSST is not responsible for the unavailability of such third party websites or services. In general, eSST is not responsible for the operation, content or any other aspect of third-party sites or services or for any direct or indirect damage caused by following a link to a third-party site or service.
Violation of the TOS
If you breach your obligations under this TOU, eSST may terminate or suspend your access to the Website.
You shall not be entitled to any compensation of any kind on the basis of the suspension or prohibition of access to the Website resulting from your sole fault.
The Website remains the exclusive property of eSST. The provision of access to the Website does not constitute a transfer of intellectual property rights to the User.
Protection of personal data
Applicable law and jurisdiction
Last update: January 12, 2022
Compliance with data protection legislation
eSST is committed to making every effort to comply with laws and regulations governing the processing of personal data, including, but not limited to, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the " RGPD ") and any other applicable national laws or regulations governing the processing of personal data.
Data Protection Officer
eSST has appointed a Data Protection Officer (the "DPO"). DPO ") which can be contacted at the following coordinates
Address: 49 rue Gabriel Lippmann, L-6947 Luxembourg, Grand Duchy of Luxembourg
Telephone: +352 46 36 84 31
Email address: [email protected]
Who are the Concerned Persons?
The persons concerned (the " Persons Concerned "), i.e. the individuals whose personal data eSST processes are:
- Users of the eSST Site (the " Users ") or any other person who contacts eSST without being a customer, in particular to find out about eSST's activity;
- eSST's customers who are individuals or representatives and/or employees of eSST's customers who are legal entities (the " Customers "); and
- Any other natural person, including a Data Subject, partner or supplier, submits personal data to eSST. The personal data of such other persons is submitted to eSST under the responsibility of the Data Subjects who undertake to transmit it to eSST in accordance with the applicable legal provisions. The data will only be used by eSST if it is necessary for the provision by eSST of its services in the course of its business.
What personal data is collected by eSST and why is it used?
- Identification and contact information The identification and contact information of Data Subjects may correspond to (i) the name and e-mail address provided in the contact form on the eSST Site (the " Form "(ii) the data contained in the business card provided by the Data Subject or the email signature of the Data Subject. This data will be processed by eSST to respond to the Data Subject's requests or in the course of its business.
- Content of CVs and cover letters The data provided by the Candidates will be used in the context of applications and vacancies. This data includes surnames, first names, date of birth, nationality, means of contact (e-mail address, postal address, telephone number), training, professional qualifications, professional experience and any other personal data contained in these documents.
- Content of the messages of the Persons Concerned transmitted whatever the chosen mode of communication Data Subjects: Data Subjects may contact eSST through various means, including through social networks, to make their requests. This data will be processed by eSST to respond to the Data Subjects' requests or in the course of its business.
- Any other personal data provided to eSST in the course of its business with any of its CustomersThis data, collected directly or indirectly, allows eSST to provide its consulting and assistance services within the framework of its activities.
- Content and metadata These elements correspond to the operations carried out on the eSST Site, i.e. the data flows generated by the activity of the Users. In principle, these data are not used by eSST, for which the eSST Site is simply the medium for exchanging these data. However, some of these elements may be used by eSST to allow eSST to better understand how Users interact with the eSST Site and to improve its operation.
- Technical information Technical Information: This technical information may include browser type, language settings, country and time zone, cookie ID and settings, type of device used for connection, hardware model and operating system, unique identifiers such as IDFA (for iOS), MAC address or user ID, IP addresses and mobile network information, social network sharing, geolocation data. eSST never uses the precise GPS location of the User's device except with the User's explicit consent. This data is used to ensure optimal use of the eSST Site and to personalize the eSST Site for each User (by adapting the language in which the eSST Site is displayed, for example, or by offering the eSST Site in a mobile version if the connection comes from a cell phone).
Source of personal data
We obtain certain personal data directly from Data Subjects. However, and in particular in the course of our business, we may obtain personal data indirectly, for example: when verifying information provided through public sources, when employees and partners of the Data Subject provide us with personal data of a Data Subject, or when we are put in contact with a Data Subject through a third party.
Use of social networks
The personal data of Data Subjects collected through the use of social networks may be processed by eSST, which has a legitimate interest in using them for marketing purposes and to improve its advertising materials and its image on the basis of voluntary information transmitted or published by Data Subjects.
eSST is present on various social networks and acts as a joint controller with them for certain processing operations, in particular when the logo of the social network used appears on the eSST Site.
For more information on the processing of personal data on the various social networks, Data Subjects may consult the following information notices in particular:
- Facebook: data use policy
Other social networks may also be added at any time by eSST.
eSST also uses " cookies We may also use "cookies" to improve the User's experience on the Site or to compile aggregate, anonymous statistics to understand the use of the eSST Site by Users and to improve its structure and content.
Some cookies do not require Users' consent because they are purely technical and their use is in the legitimate interests of eSST. For others, eSST collects the consent of Users before collecting personal data about them via cookies.
For more information, including how long cookies are retained, Users may consult eSST's cookie management policy, available on the eSST Site.
How does eSST protect personal data?
eSST implements appropriate security measures throughout the life cycle of personal data to protect against unauthorized access, alteration, disclosure or destruction of personally identifiable information and, whenever possible, anonymizes the personal data of Data Subjects.
Data Subjects are responsible for ensuring that any personal data they send to eSST is secure.
eSST takes reasonable steps to:
- to ensure that your personal data is accurate and, if necessary, updated by allowing Data Subjects to modify any inaccurate data at any time;
Sharing of personal data
eSST is the sole recipient of personal data which may only be shared with third parties (i) in the context of the performance of its business and on a strictly necessity basis (e.g. recipients of our mailings and documents), (ii) with all state and/or public authorities when required by law (iii) to joint processors for organizational purposes and future solicitations, (iv) to its subcontractors, service providers, to enable them to perform their services to the exclusion of any other purpose or eSST has entered into a contract with each such service provider to specify the manner in which they may access and process Personal Data. Service providers are subject to a confidentiality undertaking and implement personal data security measures at least equivalent to ours.
eSST does not transfer personal data to any third country or international organization, except when strictly necessary for the provision of its services, in which case such data transfers will be based on the "data transfer" (together, the " Transfer Mechanisms "):
- On an adequacy decision adopted by the European Commission. The countries covered are listed on the European Commission website ;
- Based on appropriate contractual test cases;
- On any other valid data transfer mechanism within the meaning of the GDPR and in particular in case of necessity related to the performance of a contract between the Data Subject and eSST.
Any Data Subject may contact the DPO at the above address for further information in this regard.
With their prior consent, eSST may still communicate the name of its Customers, as a commercial reference (i) on the eSST Website, social networks and any other media and/or (ii) to its other Customers or prospects.
The reference to the Customer may be accompanied, if necessary, by an explanation of the service, depending on the agreement given by the Customer. In principle, this will always be a summary of the service provided to the Customer, the financial volume of the service(s) concerned and the contact details of a contact person.
Such processing is carried out solely on the basis of the consent of the Customer who always has the opportunity to withdraw his consent at any time, without charge or penalty. Such withdrawal will not, however, affect the lawfulness of the processing based on the consent given prior to the withdrawal of consent.
eSST may send informational emails for similar services provided by eSST (the " Electronic Communications ("eSST") to Data Subjects whose email addresses eSST has obtained by providing its services where such Data Subjects have not objected to such use at the time of collection of their email address.
Any other unsolicited electronic communication that is not covered by the above provisions will be made exclusively on the basis of the consent of the Person concerned.
Data Subjects still have the possibility to object to such use of their email address, free of charge and in a simple manner, by contacting the DPO directly at the contact details indicated above.
If a Data Subject objects to receiving Electronic Communications, he or she will not receive any of them once he or she has expressed his or her objection through any of the channels identified in the preceding paragraph.
This processing is based on the legitimate interest of eSST to inform about its activity, thus allowing eSST to continue to provide its services and to promote its image towards the Data Subjects.
Events and conferences
eSST participates in physical and online events and conferences, either directly or in conjunction with other partners (the " eOSH Events "). When a Data Subject participates in these eSST Events, eSST collects personal data about the Data Subject, such as identification, contact information, and data related to the Data Subject's attendance at the eSST Event, and any other personal data or business information that the Data Subject may volunteer to eSST for the purpose of organizing and conducting the eSST Event. The data of the Persons concerned may also be used for the sending of Electronic Communications according to the methods indicated above.
This personal data is processed directly by eSST or by its partners organizing the eSST Event if applicable.
This personal data is kept for the time necessary to organize and carry out the eSST Event, with the exception of the identification, contact details and reference of the eSST Event to which the Data Subject was invited or in which he or she participated, which will be kept for a period of five (5) years from the end of the relationship between the Data Subject and eSST.
The Concerned Person is informed that he or she may be photographed or appear in videos taken during his or her participation in the eSST Event (the " Images "). These Images may be published in paper or digital format, via the usual media channels and will be archived internally to document the history of eSST. The Data Subject may object to the processing of his or her Images by contacting the DPO at the contact details given above to enable eSST to take appropriate action accordingly, to the extent possible.
The processing carried out within the framework of eSST Events is based on the execution of a contract when the Person Concerned has registered for the eSST Event and on the legitimate interests of eSST for the rest and in particular the management of invitations and the organization of the event prior to the acceptance by the Person Concerned of the invitation to the eSST Event. The legitimate interests of eSST correspond to its desire to inform and contribute to the training of all as well as to bring together its partners and Clients around eSST Events to promote each of them around common values.
eSST is required to process personal data contained in the CVs and cover letters sent by the candidates.
The processing of applications corresponds to the execution of pre-contractual measures.
The personal data of the candidates will be kept for a maximum of two (2) years after the last contact.
- For Concerned Persons who are not eSST Clients five (5) years from the end of the relationship between the Data Subject and eSST, except in the case of applications where the period is extended to two (2) years after the last contact with the applicant;
- For Concerned Persons who are eSST CustomersThe term of the contract with eSST is ten (10) years from the end of the calendar year in which the contract with eSST is terminated, except where there is a statute of limitations or a longer legal obligation to retain.
- For all Concerned Persons The implementation of backups by eSST ensures the availability of data as well as their access within appropriate timeframes in case of a physical or technical incident. The data included in the backups are kept until they are overwritten by a new backup. This is data that is " out of order "These backups are used for backup purposes only. If a Data Subject requests the deletion of his or her personal data, the personal data contained in these backups will be deleted to the extent technically possible.
eSST undertakes to delete or anonymize your personal data at the end of the retention period described above, plus a period of a few days or weeks, in proportion to the above-mentioned period, if necessary to ensure the deletion or anonymization of the data concerned in practice, unless there is an imperative reason for doing so (e.g. in the context of a dispute).
Rights of the person concerned
Each Data Subject has the right to access, modify, limit and object to the processing of his or her personal data, the right to erasure and the right to portability of his or her personal data by contacting the DPO at the contact details given above, in accordance with the applicable legislation on personal data protection. These rights can only be exercised within the limits provided for by law and in particular by any contractual or legal obligation. Each Data Subject also has the right to file a complaint with the Luxembourg supervisory authority, namely the National Commission for Data Protection.
Last update: January 12, 2022
When you visit the eSST Sites, cookies may be placed in accordance with this Policy. This Policy provides information on the nature of the cookies used and how to accept or decline them, either in aggregate or by type.
What is a cookie?
Cookies are files or pieces of information that may be stored on your computer (or other Internet-connected devices, such as a smartphone or tablet) when you visit the eSST Sites. A cookie typically contains the name of the website from which it originated, the "lifetime" of the cookie (i.e., how long it will remain on your device), and a value, which is usually a randomly generated unique number.
What types of cookies do we use?
These cookies allow eSST Sites to remember the choices you make.
We use Google Analytics, which uses internal cookies to generate reports about visitors' interactions with the eSST Sites. These cookies are used to store non-personally identifiable information. These cookies store an encrypted unique identifier, which is used to generate statistical data about how the visitor uses the site. They do not identify you in any way, neither during your visit nor during the analysis of the data.
Other third party cookies
In addition to Google Analytics, the eSST Sites rely on certain services offered by third-party sites. These include:
- Share buttons (LinkedIn, Twitter, Facebook, Email);
- Interactive maps (Google Maps);
- Captchas to check that you are not a robot (Google).
These features use third-party cookies set directly by these services. We make every effort to identify these cookies so that you can decide whether or not to accept them. If you choose not to accept them, you may not be able to access these services and some pages of the eSST Sites may not function properly or be accessible. You can indicate your preferences as described below.
How do I control or delete cookies?
You can control or delete cookies through your Internet browser settings. In fact, most web browsers are set to automatically accept cookies. You can change these settings to block cookies or to alert you when cookies are being sent to your device. There are several different ways to manage cookies. Please refer to your browser's instructions or help service to learn more about how to adjust or change the settings.
If you use multiple devices to access the eSST Sites (e.g., your computer, smartphone, tablet, etc.) you should ensure that the browser on each of your devices is adjusted according to the cookie settings you have set.
If you disable the cookies we use, it may affect your experience on the eSST Sites.
Last update: January 12, 2022