Our confidentiality policy
Version 1 from March 1st 2021
In the scope of its activities, MindForest gathers and treats your personal information. We take data protection very seriously and assure you that we will maintain total transparency about the way we collect and process your data; furthermore, we assure you that we will respect all the criteria of current data protection legislation at all times (legislation UE2016/679 (GDPR)).
1 About us
Founded in 2000 in Luxembourg, MindForest is a consulting company specialized in change management, which operates both in Luxembourg and in an international context. MindForest guides companies throughout their projects linked with organizational restructuration, improved performance, increased competitiveness and durable development.
Our company headquarters are located at 34, rue Michel Rodange, L-2430 Luxembourg. We are responsible for the following websites: www.mindforest.com and www.changex.center.
Contact : MindForest
34, rue Michel Rodange
L-2430 Luxembourg
tel : +352 43 93 66 67 70
mailto:contact@changex.center
We are not under the obligation of employing a data protection officer, please address any questions concerning the use of your personal data to the above-mentioned address.
2 Use of your personal data
When you enter a commercial relationship with us
When you apply for a job vacancy
When you subscribe to our newsletter
3 When you enter a commercial relationship with us
If a commercial/contractual relationship already exists or if we are in discussions to enter into such a relationship (as a client, prospective client, supplier or partner), we will ask you to provide certain data, which we require in order to formulate our contract correctly: for example in the event of an offer creation, order follow-up, order delivery, follow up on a possible maintenance contract or coordination of planned maintenance or other interventions such as invoicing, payment follow-up etc.
In this context we will ask you for:
- Your name and your coordinates: first name and surname, telephone number, email address, postal address, company address (which ever applies);
- Your bank account number (solely in the event of a contractual relationship).
We require this information in order to carry out our contract; it will be stocked on our servers located in Luxembourg. The data will be stored for the duration or our contractual relationship plus 10 years.
We do not use the information you provide to generate automatic messages.
4 When you use our website
Our website uses the analytical services provided by Google Analytics. This service is provided by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (henceforth known as Google). This analytical tool works on the basis of cookies. A cookie is a text message, which is automatically sent when you visit our website and is added to the cache on the website user’s hard disk in order to analyse the way you use the website.
Normally, the information gathered is transmitted to a Google server in the USA and is then stored there. In order to render your IP address anonymous, it will be modified by Google in an EU member state or in any other state forming part of the European Economic Area. On our behalf, Google will use the information transmitted to generate a report about the use of our website. The IP address transmitted in the course of Google Analytics will not be merged with other Google data. If you wish to prevent the use of cookies, you may do so by making local changes to the browser settings on your computer (e.g. Safari, Internet Explorer, Opera, Firefox, etc.) – in other words in the software you use to access the Internet. In addition to this, you may prevent Google form gathering your data by downloading and installing a navigator plugin supplied by Google; to do so please click here.
5 When you use the CHANGEx platform
In order to create an account on our platform www.changex.center you will have to provide a valid email address and a password. We automatically collect certain types of data when you use the platform; this data relates to the way you use the platform and the available material, as well as your progress through the different online courses.
We can use this data for the following purposes:
- Identification and validation: we use your data to record when you log on to your account.
- Provision of our services: we use your data to provide our services, to provide support and to fulfil our contractual obligations.
- Communication with you: we use your data when we contact you (e.g. when we respond to a request for support or any other request).
- Improvement of our services: we use your data to understand how our services are used and how they can be improved. In general, we assess global data rather than individual data. However, we may need to analyse individual data in order to deal with a specific issue (e.g. a problem, which only affects certain accounts).
- Personalising your experience: we use your data to improve the service we provide to you. This may include recording your language, volume, video preferences to maximise your enjoyment of our content material.
- Exercising our rights: only if it is really necessary, we will use your data to exercise our legal rights and prevent abuse of our services. For example, we may use your data to detect and prevent fraud, spams or any other content which violates our user conditions.
- Respect of legal obligations: we will use your data when we are legally obliged to do so. For example, we may be required to gather your data in response to a summons or a court order.
Should we process your data for one of these reasons, we will ascertain that one or several of the following legal criteria apply:
- Execution of a contract.
- Legitimate commercial interest.
All your information is stored on our servers in Luxembourg. We save your data during the entire duration of your subscription. After this period, your data will be deleted or rendered anonymous.
We do not use the information you provide to generate automatic messages.
6 When you use the contact form
When you submit a request via the website, you will be asked to include your name, email address, details of your request, as well as your phone number and address.
We will use this information to process your request. We may contact you again after your request has been dealt with to check that you are satisfied with the answer you received; this is because we place great importance on providing a good service.
Your request is stored and saved as a message hosted on our servers in Luxembourg. We do not use the information you provide to generate automatic messages.
All such messages are saved for one year and then deleted.
7 When you apply for a job vacancy
If you apply for a job vacancy via our website, we will collect some information about you. This includes:
- - your name and surname, address, telephone number, email address;
- - your personal characteristics: sex, date of birth, place of birth, marital status, nationality
- - details of your education and qualifications;
- - details of your professional experience, current employer, job title and description, recruitment date, place of work, specialisation;
All this information will be saved on our servers in Luxembourg.
We do not use the information provided by you to take automatic decisions.
During the recruitment process we have a legitimate interest in processing your personal data. This enables us to manage the recruitment process, to evaluate and determine the suitability of a candidate and to decide who to make a job offer to. We may also need to process this data to reply to candidates and to defend ourselves against any legal claims.
We do not process your data for any other reason than as part of the recruitment process.
Your data will be shared internally with our departments as part of the recruitment process. This includes members of the HR team, the interviewers concerned and the decision makers in the fields linked to the job offer.
We will not share your data with any third parties.
If your application is not accepted, we will keep your data for a maximum of three months. After this period, we will erase or delete your application data (unless we need to keep it for a longer period to execute or defend our legal rights).
8 When you subscribe to our newsletter
You may subscribe to our newsletter via our website.
The newsletter is sent out via a website belonging to the company mailchimp, registered at The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA.
Your email address, as well as the data described in this paragraph, is saved on the mailchimp company servers in the USA. Mailchimp uses this information to send out and evaluate newsletters on our behalf. In addition, according to Mailchimp, this information may be used to improve their services, e.g. optimising mailing techniques, newsletter presentation or also for economic reasons, for example to track which countries the recipients live in. At no time will mailchimp use this data to contact you or to transmit information from third parties. You may consult the mailchimp privacy policy here.
Survey and statistical analysis
The newsletters contain a so-called “web-marker”, a pixel-sized file, which is tracked by the mailchimp servers when the newsletter is opened. At this moment they record some technical information, such as the navigator in use, your operating system, your IP address and the time when you received the newsletter. This information is used to improve the technical quality of their services based on the technical information or the target groups as well as their location-related reading behaviour (determined by the IP address) and the length of time spent reading the newsletter.
The statistical analysis also checks whether newsletters are opened, when they were opened and which links were clicked. Technically speaking this information can be attributed to individual readers. However, neither we nor mailchimp have any intention of observing our individual readers so closely. Such evaluations serve merely to gain information about our readers’ habits and to adapt our content material correspondingly to suit them.
Online access and data management
On occasion we may divert the recipients of our newsletters to the mailchimp websites. For example, if our newsletter contains a link which redirects them to an online newsletter (e.g. if there are issues with presentation in the email software). In this context, we underline that cookies are used on the mailchimp websites and that personal data will be processed by mailchimp, their partners and service suppliers (e.g. Google Analytics). We have no influence whatsoever on the way this data is collected. For more information, please consult the mailchimp privacy policy. You may of course express your opposition to such data collection for publicity purposes via either of these websites: http://www.aboutads.info/choices/ or http://www.youronline choices.com/ (these apply to the European area).
9 How do we protect your data?
We take data security very seriously. We have implemented internal processes and checks to ensure that your data is never lost, accidentally destroyed, misused or shared. Your data will only be available to our staff in the context of their professional tasks.
10 Your personal rights
With no prejudice to the scope of the GDPR agreement, you have the right to consult the data we have about you and also to request any necessary corrections. If your permission was requested in order to process your data, you may rescind this at any moment.
If your personal data is processed to prove agreement or to honour a contract, you may request this to be sent to you in such a form that it can easily be machine-read and then transferred to a different supplier.
With no prejudice to the scope of the GDPR agreement, if your personal data is used to prove agreement, you may request it be deleted.
You have the right to ask us to stop using your data during a specific period if you believe that we are not respecting legal requirements.
You may submit a request concerning your personal data by email, post or telephone. Please use the coordinates listed under the section “About us” in this policy presentation.
11 Your right to complain
If you would like to make a complaint about the use of your data, please contact us first, so that we can deal with your complaint. You may however also contact the CNPD via their website www.cnpd.lu or write to them at this address:
Commission nationale pour la protection des données
Service des plaintes
1, avenue du Rock’n’Roll
L-4361 Esch-sur-Alzette
12 If you do not want to provide your personal data?
You do not have any statuary or contractual obligation to provide your personal data. However, if you do not provide this information, we will not be able to process your request or provide you with the requested service.
13 Update of this privacy policy
We examine this privacy policy at regular intervals and – when necessary – add any updates, also depending on the evolution or our services and the use of personal data. If we wish to use your personal data for a reason, for which we have not previously asked your permission, we will contact you to explain the context and – if necessary – ask for your permission.
FR 
EN