PRIVACY POLICY

This Privacy Policy entered into force on March 1st, 2019.

Utopian Future Technologies S.A.  (“UFT”) is committed to protecting the privacy of users and will do everything in its power to ensure that users’ Personal Data is treated with respect to their fundamental rights and freedoms as well as personal dignity, with particular reference to confidentiality.

We at UFT have thus prepared this Privacy Policy in order to briefly explain to you how we will collect, use, share and secure your Personal Data. It also describes your choices regarding use, access and correction of your Personal Data.

We may require users to provide certain personal information and details in order to provide our services, and we would therefore like to explain the procedures and ways in which we handle data supplied to us.

This Privacy Policy will also provide you with full information so that you are able to consent to the processing of your Personal Data in an explicit and informed manner, where appropriate.

In general, any information and data which you provide, or which is otherwise gathered by us in the context of the Website, will be used by UFT in compliance with Regulation (EU) 2016/679 (“GDPR”).

This means, in particular that any Personal Data processing (cf. GDPR, Art. 4) carried out by UFT will respect the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.

Data Controller

The Data Controller regarding all Personal Data processing operations carried out through the Website is UFT, with registered offices at 59 Boulevard Royal, 2449 Luxembourg, Luxembourg. UFT has appointed a local coordinator for privacy/Data Protection Officer (DPO). To get in touch with him/her for any information regarding the processing of Personal Data by UFT, including a list of its data processors, please contact: dpo@uft.lu.

What information do we collect from you?

When using our website,  you will have the possibility to contact us for asking questions, setting a meeting, or receiving regular information about the company.  This is why we will ask you some personal data to be able to answer you. (“Personal Data”).

Mandatory Data vs Data voluntarily provided by users

As you visit the website, you can choose to fulfill the form “Request a Demo” and to “subscribe to the UFT newsletter”  to receive further information about the products and services of our company. If so, the mandatory data required are:

  • the family name,
  • The surname,
  • and the email address.

The other information are not mandatory thus you decide to provide them voluntarily and you will suffer no consequences if you choose not to give it.

If you have subscribed to the UFT newsletter, we will use "MailChimp", a newsletter distribution platform for sending out our newsletter. Subscription to our newsletter is subject to the opt-in procedure. This means that you will receive an e-mail asking you to confirm your registration.

Find here the privacy policy of MailChimp: https://mailchimp.com/legal/privacy

Browsing data

The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation, whose transmission is automatic when using Internet communication protocols.

Although UFT does not collect this information in order to associate it to specific users, it is still possible that, by their nature and through processing and association with further data held by third parties, such data may permit to identify user, either directly via that information or by using other information collected. As such, this information must also be considered Personal Data:

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, information about your activities on our Website (for instance, the pages you visit), the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), details on the device (for instance, your computer, tablet or smartphone) which you use to access our Website and so on, by means of cookies and other technologies which allow this tracking. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service, as further described below.

Such data shall only be used by UFT for anonymous, statistical purposes about the use of the Website, without associating them to any identifier of the users, to ensure its correct operation and identify any faults and/or abuse of the Website. This data may also be used for the purposes of investigating liabilities in the event of information crimes committed against the Website. Those data is also not collected by UFT directly but by the help of processors, namely Google Analytics and Facebook (see section below).

Processing activities

UFT intends to use your Personal Data, collected through the Website, for the following purposes:

  • To provide answers or services your request; to receive information from UFT; to contact you when necessary and respond to your requests and enquiries, including emails; and to provide any other services which you may request. No consent is required for the processing of data for the purposes since such processing is necessary to provide the services requested and, therefore, for the performance of an agreement to which you are a party or for the implementation of measures requested by you prior to entering into an agreement (GDPR art. 6,1b). It is not mandatory for you to give UFT your Personal Data for these purposes; however, if you do not, UFT will not be able to provide any services to you.
  • For marketing, promotional and publicity purposes, (“Marketing”), and to send you offers, promotions or other information about our goods and services. Processing for these purposes is based on your consent. It is never mandatory for you to give consent to UFT for the use of your Personal Data for these purposes, and you will suffer no consequences if you choose not to give it (aside from not being able to receive further marketing communications from the company UFT). Any consent given may also be withdrawn at any time.
  • To analyze and improve our service provision, enhance the Website, perform statistical and demographics analyses and registered users (“Analytics”). Processing for this purpose is necessary to pursue UFT’s legitimate interests in the development and administration of the Website and to improve the services provided on the Website.

Who will be able to access your Personal Data?

In the framework of its activity and for the purposes specified above, your Personal Data may be shared with the following entities (“Recipients”):

  • Selected individuals employed at or authorized by UFT to process Personal Data, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of UFT);
  • Public entities, bodies or authorities, in accordance with the applicable law or binding orders of those entities, bodies or authorities. We may also disclose your Personal Data when we believe in good faith that disclosure is necessary to protect your safety or the safety of others, investigate fraud, or respond to a government request.

Data Transfer

Personal Data may be transferred to other countries of the European Union where the premises or the servers of UFT or of any of its suppliers are located. In this case an adequate level of protection is ensured (GDPR. Art. 45 & Art. 32).

Security of Personal Data

All Personal Data collected and processed through the Website will be stored and processed so as to minimize the risk of destruction, loss (including accidental loss), unauthorized access / use or incompatible use with the initial purpose of collection. This is achieved by the technical and organizational security measures put in place by UFT. For further information, you can contact dpo@uft.lu

Retention of Personal Data

Generally, UFT will keep your Personal Data only for as long as strictly necessary, according to the reason for which it was collected:

  • Personal Data processed for Service Provision will be kept by UFT for the period deemed strictly necessary to fulfil such purposes. Information will, however, be kept for longer if we need it to address any claims regarding the services or to protect UFT’s interests related to potential liability related to the Service Provision.
  • Personal Data processed for Marketing will be kept by UFT from the moment you give consent until the latter is withdrawn. Where it is not withdrawn, consent will be asked to be renewed at fixed intervals of 24 months. Once consent is withdrawn (or not given, following a renewal request), Personal Data will no longer be used for these purposes, although it may still be kept by UFT as it may be necessary to protect UFT’s interests related to potential liability related to this processing. Personal Data processed for Soft Spam will be kept by UFT from the moment where it is provided by you to UFT until you object to this processing. Once you have objected, Personal Data will no longer be used for these purposes, although it may still be kept by UFT, in particular as may be necessary to protect UFT’s interests related to potential liability related to this processing.

After such periods, all data shall be deleted or anonymized, except that data we are required by law to keep for a longer period.

What are your rights? How can you exercise them?

As a data subject, you are entitled to exercise the following rights, at any time:

  • Obtain confirmation as to the existence of your Personal Data being processed by UFT, access and obtain copy of such data;
  • Update, modify and/or rectify your Personal Data where it may be inaccurate or incomplete;
  • Erasure of your Personal Data
  • Object to processing of Personal Data that is made for the purposes of sending advertising material, carrying out direct sales, market researches or for commercial communication;
  • Withdraw your consent to processing (for Marketing and Profiling), where your consent serves as the legal basis for processing – this will not affect the lawfulness of processing carried out prior to your withdrawal.
  • Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, or that the processing is unnecessary or unlawful, as well as where you have objected to the processing;
  • Portability – you have the right to obtain a copy of the Personal Data you provided to UFT in a structured, commonly used and machine-readable format, as well as to request the transmission of those Personal Data to another data controller;

At any time, you shall be entitled to exercise the rights established by the law in force, by addressing the relevant request to our Privacy Department at physical and email address: dpo@uft.lu

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us  

Finally, you are entitled to file complaints with to your local EU Data Protection Authority or to the data protection authority of Country of the UFT entity (CNPD at https://cnpd.public.lu/fr/support/contact.html), if you believe that we have handled your information in an unlawful manner.

Amendments

This Privacy Policy entered into force on  March 1st, 2019 for the first time.

UFT reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. If UFT makes any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. UFT therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how UFT collects and uses Personal Data.

Miscellaneous

This Privacy Policy shall be governed and construed in accordance with the laws of the Grand-Duchy of Luxembourg. The courts of the judicial district of Luxembourg-City have exclusive jurisdiction in relation to any dispute arising out of or in relation with this Agreement.  UFT may alter terms and conditions of this Privacy Policy, in whole or in part, by notifying Licensee of such alterations beforehand via an appropriate method of information.