Data Privacy Policy

Introduction

This Privacy Policy explains how puremodelhubum SARL ("we", "us", or "our") collects, uses, and protects your personal data when you visit our website, use our services, or interact with us. We are committed to protecting your privacy and ensuring transparency about our data practices in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

Data Controller Information

The data controller for your personal information is:

Data Collection

We collect personal data that you provide directly to us and information that is automatically collected when you use our website. The types of data we collect include:

Information You Provide

• Contact Information: Name, email address, phone number, company name, and job title when you fill out contact forms or request our services
• Communication Data: Any information you provide when you contact us via email, phone, or through our website forms
• Service Information: Details about your business, industry, and specific requirements when you request consultations or services
• Newsletter Data: Email address and preferences when you subscribe to our newsletter

Automatically Collected Information

• Website Usage Data: IP address, browser type, device information, pages visited, time spent on pages, and referral sources
• Cookie Data: Information collected through cookies and similar tracking technologies as described in our Cookie Policy
• Technical Data: Information about your device, browser settings, and technical specifications

How We Use Your Information

We use your personal data for the following purposes, based on legitimate interests, contractual necessity, or your consent:

• Service Provision: To provide our comparison and consultation services, respond to your enquiries, and fulfil our contractual obligations
• Communication: To respond to your questions, provide customer support, and send you information about our services
• Marketing: To send you newsletters, service updates, and relevant information about pricing software trends (with your consent)
• Website Improvement: To analyse website usage, improve our content, and enhance user experience
• Legal Compliance: To comply with applicable laws, regulations, and legal processes
• Business Operations: To maintain our records, conduct business analysis, and protect our legitimate business interests

Legal Basis for Processing

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

• Consent: For marketing communications and optional cookies
• Contract Performance: To provide our services and fulfil our agreements with you
• Legitimate Interests: For website analytics, business communications, and service improvement
• Legal Obligation: To comply with applicable laws and regulations

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 or by visiting our detailed Cookie Policy page.

Data Sharing and Disclosure

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

• Service Providers: With trusted third-party service providers who assist us in operating our website and providing our services (e.g., hosting providers, email services)
• Legal Requirements: When required by law, regulation, or legal process
• Business Protection: To protect our rights, property, or safety, or that of our users or the public
• Business Transfers: In connection with a merger, acquisition, or sale of assets (with appropriate protections)

All third-party service providers are contractually required to protect your data and use it only for the specified purposes.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy or as required by law. Our typical data retention periods are:

• Contact Information: 3 years from last contact or end of business relationship
• Website Analytics: 26 months (Google Analytics default)
• Marketing Data: Until you unsubscribe or withdraw consent
• Legal Documentation: As required by Luxembourg and EU law

After the retention period expires, we securely delete or anonymise your personal data.

Your Rights

Under GDPR and applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing based on legitimate interests or direct marketing
• Right to Withdraw Consent: Withdraw consent for processing that requires your consent

To exercise these rights, please contact us at privacy@puremodelhubum.top. We will respond to your request within one month.

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 of data in transit and at rest
• Regular security assessments and updates
• Access controls and employee training
• Secure hosting and backup systems
• Incident response procedures

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) where our service providers are located. When we transfer data outside the EEA, we ensure adequate protection through:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Certification schemes and codes of conduct
• Other appropriate safeguards approved by supervisory authorities

Children's Privacy

Our services are not directed to children under the age of 16. We do not knowingly collect personal data from children under 16. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately so we can delete such information.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this policy periodically.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Supervisory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD):