Introduction​

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https://rumya.clsinfo.lu/brunata

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The companies of the Brunata Metrona Group, namely Brunata Metrona FL Sàrl, E-Trash Location Sàrl, E-Trash Sàrl, Marth Group Sàrl, Marth Invest Sàrl, René Marth Sàrl, RPM SCI, Voltizy Sàrl, Voltizy Community Scop, hereinafter referred to as the “Companies”, offer a wide range of products and services, hereinafter referred to as the “Products & Services”, including in particular:

• Installation and reading of energy and water meters

• Preparation and issuance of energy and water consumption statements

• Manufacture and installation of waste containers and supervision of waste facilities

• Creation and installation of measurement systems for waste containers

• Preparation and issuance of waste statements

• Development of services and databases based on measurement data

• Provision of services based on measurement data

• Making measurement data available to third parties via IT platforms

• Development and implementation of measurement processes to make data available to third parties

• Sale of heating and sanitary equipment, materials, and tools

• Management, installation of charging stations, and preparation and issuance of statements

• Energy communities: management of energy flow distribution and preparation and issuance of statements

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Personal data we collect

We may collect your personal data for various reasons, including the provision of our Products & Services, compliance with professional obligations, performance of a contract, processing of your files, correspondence, or job applications, etc.

In particular, we process the following data:

• Installation and reading of energy and water meters

• Preparation and issuance of energy and water consumption statements

• Consumption data (heating, water, waste, electricity, etc.) of users

• Billing data, commercial data, supplier data

• Identity, addresses, personal and professional contact details, civil status

• Profession, economic category, activities

• Bank accounts and statements

• Identity cards, passports (where permitted)

• Information relating to the Companies’ human resources: income, salaries, personnel numbers, time tracking, working hours, bonuses, commissions, travel expenses, benefits in kind, absences, leave, long-term illnesses, wage garnishments and assignments, recruitment, diplomas, authorizations, certifications, etc.

• Photographs for identification or marketing purposes

We collect this data mainly directly from you or from your service provider (property manager, municipality, real estate agency) in the context of performing a contract concluded with you or with your service provider, for whom we act as a data processor. In the interest of the Companies, we may also combine the information collected with data obtained from other sources in order to supplement it, provide our Products & Services, and personalize our interactions with you. With your consent, we also collect information related to your use of our websites through various technologies, such as cookies (via Cookie Dot).

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How we use your personal data

Personal data provided by you, your service provider, or your employer, or lawfully received by our Companies from related entities or third parties, may be processed for the purpose of:

• Managing contracts

• Activating and providing the Products & Services

• Improving the Products & Services

• Ensuring business operations and performance

• Providing customer service

• Managing commercial relationships and updating customer records

• Detecting, preventing, and combating fraud

• Producing statistics

• Managing disputes and debt recovery

• Settling services

The personal data provided may also be processed by our Companies for direct marketing purposes (commercial actions, personalized advertising, data matching, brand awareness), in order to improve knowledge of our customers and prospects and to inform them about our activities, products, and services.

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How we share your personal data

We share your personal data with your consent or when such sharing is necessary to carry out a transaction, provide a product or service you have requested or authorized, or comply with legal obligations.

Your personal data may be shared with service providers acting on our behalf as data processors for the benefit of the Companies, who may need access to personal data to provide customer support or to help protect and secure our systems and services. In such cases, these entities are required to comply with our data protection and security requirements and are not authorized to use the personal data we provide to them for other purposes.

We also share data when required by law, to respond to legal proceedings, to comply with obligations towards supervisory authorities, to protect our customers, to ensure the security of our Products & Services, to protect the rights or property of the Companies, for the management of disputes and debt recovery, and for the settlement of services.

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Transfer of data outside the European Union

Where applicable, companies and/or individuals to whom personal data is disclosed may be located within or outside the European Union. In the event of data transfers to third parties located outside the European Union, the Companies comply with the applicable legal and regulatory provisions and, in particular, ensure an adequate level of protection for the personal data transferred, based on mechanisms established by the European Commission or other contractual safeguards.

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How we protect your personal data

The personal information we collect is stored in a secure environment. Our employees are trained to respect the confidentiality of your information. To ensure the security of your personal data, we limit it to the strict minimum and implement, in particular, the following measures:

• Management of access rights and authorizations

• Securing workstations: anti-spam, antivirus, leak detection

• Securing mobile IT equipment and telephones

• Protection of IT networks and servers: encryption, backups, traffic management, firewalls

• Business continuity planning

• Supervision of software development

• Physical security of premises: fire detection, intrusion prevention, surveillance cameras

• Secure exchange of information

We are committed to maintaining a high level of confidentiality by integrating the latest technological innovations to ensure the security of your transactions.

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Retention of your personal data

We retain your personal data for as long as necessary to provide the Products & Services and carry out the transactions you have requested, or for other essential purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

The criteria used to determine retention periods include in particular:

• The necessity of retaining data to provide the requested Products & Services

• The sensitivity of the data collected or entrusted

• Specific consent given or agreed limitations

• Legal or contractual obligations

• Retention policies adopted by the Companies based on their legitimate interests

Retention periods may include, in particular:

• 10 years after the end of the contract for consumption measurement data (heating, water, waste, etc.)

• 10 years for accounting, commercial management, purchase and sales registers, real estate, and commercial lease data

• 5 years for general corporate documents (shareholder resolutions, board deliberations, meeting minutes, articles of association, shareholder registers, internal regulations, lawyers’ documents)

• Up to 10 years for human resources documents, employment contracts, and salary-related data

• 3 years for data relating to occupational accidents, working conditions, labor inspections, and health and safety committees

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Right of access, rectification, restriction, and objection

The Companies comply with the General Data Protection Regulation (EU) 2016/679 and guarantee you the following rights:

• If the processing of personal data is based on your consent, you have the right to withdraw your consent at any time

• You may access, rectify, and restrict the processing of your personal data

• You have the right to object to the processing of your personal data

• You have the right to lodge a complaint with a data protection authority

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How to contact us

For any questions regarding the confidentiality of your data, complaints, or questions relating to your rights, you may send a dated and signed request accompanied by a double-sided copy of your identity card to:

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Brunata Metrona Group
15, Zone d’Activités Économiques
L-8287 Kehlen
Tel.: +352 30 92 06-1
gdpr@brunata.lu

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Or to:

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National Commission for Data Protection (CNPD)
15, Boulevard du Jazz
L-4370 Belvaux
Tel.: +352 26 10 60-1

info@cnpd.lu