Politique de protection des données

1. Who are we?

Work-in-luxembourg.lu is a recruitment portal (Portal) for talents residing worldwide and Luxembourgish employers, established on the initiative of ADEM and EURES Luxembourg in collaboration with the Luxembourgish company InTech S.A.

The Agency for the Development of Employment (ADEM) is a Luxembourgish administration under the authority of the Ministry of Labour, Employment and the Social and Solidarity Economy, with a mission to promote employment.

In the context of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), ADEM and InTech are joint controllers (hereinafter jointly referred to as "we").

ADEM Contact Information

ADEM's headquarters is located at 19, rue de Bitbourg, L-1273 Luxembourg-Hamm.

Contact telephone:
- for jobseekers: (+352) 247-88888
- for employers: (+352) 247-88000
ADEM DPO Contact Information
- email: info.rgpd@adem.etat.lu
- postal address: ADEM, Attn: DPO, B.P. 2208, L-1022 Luxembourg
InTech Contact Information

InTech S.A.'s headquarters is located at 208 rue de Noertzange, L-3670 KAYL, LUXEMBOURG.
InTech DPO Contact Information
- email: privacy@en-virtuel.eu
- postal address: InTech S.A., 208 rue de Noertzange, L-3670 KAYL, LUXEMBOURG

2. Why are your data being processed?

We process your personal data for the following purposes:

to enable you to use the recruitment Portal, including:

create your user account and complete your profile
view job offers and CVs that interest you
participate in online job fairs and other recruitment events organized by ADEM
allow ADEM to connect you with a candidate or employer
directly interact with a candidate or employer during recruitment events.

to conduct statistics on the use and effectiveness of the Portal (for example, the number of candidates and employers who participated in an online job fair)
to respond to your possible complaints or questions and resolve any technical malfunctions of the Portal
to improve the content of the Portal, the quality of related services and your user experience.

As part of an event, and if it includes conferences, you may be asked to ask questions in your name that are visible to the speakers and other users.

During events, instant messaging facilities are also available for private exchanges with stand representatives or publicly with booth members and other users. Your name, first name and profile picture will be visible to identify you.

If you use other sites from InTech's en-virtuel product, please note that you can register on the Portal using the same login data (email, password, first name, last name, profile picture, phone number) as you use on these other sites.

3. What is the legal basis for processing your data?

ADEM justifies the processing of your personal data based on its public interest missions to connect job seekers and employers, as defined in Article L. 621-1 of the Labor Code and in accordance with Article 6(1)(e) of the GDPR.

InTech justifies the processing of your personal data based on Article 6(1)(b) of the GDPR ("the processing is necessary for the performance of a contract to which the data subject is party") and based on its legitimate interest in improving the quality of its services in accordance with Article 6(1)(f) of the GDPR.

4. What categories of data do we process?

Data Subjects	Categories of Processed Data
Job Applicants	Identification and contact data (name, email address, password, phone number, nationality) Educational background, skills, and work experience data (field of study, level of education, educational institution, languages, years of experience, CV, CV language, last position, driving license) Job-seeking information (desired position, preferred sectors, type of contract, preferred work schedule) Profile picture URL link to LinkedIn profile Cookies Personal data exchanged with other users via the Portal (e.g., data exchanged via chats or noted in interview comments during recruitment events)
Recruiters	Identification and contact data (name, email address, password, position, company) Cookies Personal data exchanged with other users via the Portal (e.g., data exchanged via chats or noted in interview comments during recruitment events)
Platform Administrators	Identification and contact data (name, position)

For more information on cookie usage, you can refer to our cookie policy.

5. How do we obtain your personal data?

We obtain your personal data directly from you via the registration forms on the Portal. If you are a recruiter, please note that your email address and the identity of your employer may come from job postings declared by your employer to ADEM.

6. With whom do we share your personal data?

Your personal data may be viewed by other registered users on the Portal (candidates and recruiters) and by ADEM agents responsible for managing the Portal and organizing online recruitment events. Other registered users on the Portal can view your first name, last name and profile picture during your exchanges in public chats or during conferences. Recruiters can also access your personal data when you directly engage with them or if you choose to appear in the site's CV database. In addition, your data is also shared with our subcontractors as indicated below.

Subcontractor Identity and Contact Details	Purpose of Processing	Categories of Data Concerned	Location of Personal Data Processing and Storage, and, where applicable, indication of the appropriate safeguards applicable to transfers to third countries
OVH 2, rue Kellermann 59100 Roubaix, France	Portal data hosting and execution of processing applications	All Portal data	France
Scaleway 8, rue de la Ville-l’Évêque 75008 Paris, France	Portal data hosting and execution of processing applications	All Portal data	France
Postmark, ActiveCampaign, LLC 1 North Dearborn Street, 5th floor, Chicago, IL 60602	Communication of information necessary for sending transactional emails	First name, last name, email, candidate's CV, other personal data contained in emails exchanged via the Portal	United States The transfer of personal data to the United States is based on standard contractual clauses for the transfer of personal data to third countries (cf. Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council). These clauses are available on the Postmark website (https://postmarkapp.com/dpa).

7. How long do we retain your personal data?

You have the option to request the deletion of all data associated with your user account at any time, as provided for in section 9 below.

In the absence of a deletion request, your personal data will be retained for a period of 2 years after the date of your last activity on the Portal. The retention and processing of your personal data by recruiters registered on the Portal are their sole responsibility.

8. Are you required to provide us with your personal data?

Fields marked with an asterisk (*) in the registration forms on the Portal are mandatory for you to create a user account as a candidate or employer. You have the option to enhance your profile by providing additional data.

9. What are your rights and how can you exercise them?

According to the GDPR, you have the following rights:

Right of access

You have the right to inquire about the personal data we hold about you. Upon request, we can provide you with a copy free of charge. We reserve the right to redact certain information to respect the rights of third parties.

Right to rectification

You believe your data is inaccurate or outdated? You have the right to ask us to correct your email address or you can log in to the Portal to correct other data directly from your personal account.

Right to data portability

When the processing of your data is based on the performance of the contract, you have the right to ask us for the direct transfer of your personal data, either to you or to a third party.

Right to restriction of processing

You can ask us to restrict the processing of your personal data in certain circumstances, for example, when we are verifying the accuracy of your personal data.

Right to erasure or deletion

You have the right to ask us to delete your personal data. If we are legally required to retain certain personal data, however, we cannot comply with this request.

In case of a deletion request, if you use other products from InTech's en-virtuel, your login data (email, password, name, surname, profile picture, phone number) will be kept to allow you to continue using these other sites. If you wish to delete all your personal data from the Portal and other InTech's en-virtuel sites, please specify.

Right to lodge a complaint

If you believe that your data protection rights have been violated, you have the right to lodge a complaint about the processing of your personal data by ADEM with a local supervisory authority. The competent supervisory authority in the Grand Duchy of Luxembourg is the National Commission for Data Protection (CNPD). For more information, you can visit the CNPD website, https://cnpd.public.lu/.

Exercise of rights

If you have a complaint, question, or issue regarding how we use your personal data, you can contact InTech's DPO as follows:

email: privacy@en-virtuel.eu
postal address: InTech S.A., 208 rue de Noertzange, L-3670 KAYL, Luxembourg

If you contact us to exercise your rights, we will respond to you within one month. In exceptional cases, this period may be extended (up to a maximum of 3 months), but we will inform you within one month. Whether you can exercise your rights depends on the processing and the legal basis.

We reserve the right to request additional information to identify you (e.g., copy of an identity document) before granting your request.