Privacy Policy

Introduction

ultranova SARL ("we", "our", or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, and protect your information when you use our website and services. We are the data controller for the purposes of the General Data Protection Regulation (GDPR) and Luxembourg data protection laws.

Data We Collect

The data we collect includes personal information you provide directly to us and information we collect automatically through your use of our website. We collect the following types of personal data:

• Contact Information: Name, email address, phone number, company name, and job title when you contact us or request our services
• Communication Data: Messages, enquiries, and correspondence when you communicate with us
• Technical Data: IP address, browser type, device information, and website usage data collected through cookies and similar technologies
• Marketing Data: Your preferences for receiving marketing communications and your interaction with our marketing materials

How We Use Your Information

We use your personal data for legitimate business purposes and how we use your information depends on the services you use and your relationship with us. The primary ways we use of your data include:

• Providing and delivering our training comparison services
• Responding to your enquiries and providing customer support
• Processing and managing your service requests
• Sending you service-related communications and updates
• Improving our website and services through analytics
• Complying with legal obligations and protecting our legitimate interests
• Marketing our services to you (with your consent where required)

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use, please refer to our Cookie Policy.

Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

• Contractual Necessity: To provide our services and fulfil our contractual obligations
• Legitimate Interests: To improve our services, conduct analytics, and protect our business interests
• Consent: For marketing communications and non-essential cookies (where required)
• Legal Obligation: To comply with applicable laws and regulations

Data Sharing and Disclosure

We do not sell, trade, or rent your personal data to third parties. We may share your information in the following limited circumstances:

• With service providers who assist us in operating our website and providing our services
• When required by law or to protect our legal rights
• In connection with a business transfer, merger, or acquisition
• With your explicit consent for specific purposes

Data Retention

We retain your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Our data retention periods are based on business needs and legal requirements:

• Client data: Retained for the duration of our business relationship plus 7 years for legal and accounting purposes
• Marketing data: Retained until you withdraw consent or for 3 years of inactivity
• Website analytics data: Retained for 26 months in accordance with Google Analytics settings
• Contact enquiries: Retained for 2 years unless you request deletion

Your Rights

Under GDPR and Luxembourg law, your rights regarding your personal data include:

• Right of Access: Request copies of your personal data
• Right of Rectification: Request correction of inaccurate or incomplete data
• Right of Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of how we process your data
• Right to Data Portability: Request transfer of your data in a structured format
• Right to Object: Object to processing based on legitimate interests or for marketing purposes
• Right to Withdraw Consent: Withdraw consent for processing based on consent at any time

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) for service provision purposes. When we transfer data internationally, we ensure appropriate safeguards are in place, including adequacy decisions, standard contractual clauses, or other approved transfer mechanisms under GDPR.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, secure data transmission, access controls, and regular security assessments. However, no method of transmission over the internet or electronic storage is completely secure.

Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us using the following information:

You also have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) if you believe your data protection rights have been violated.