Privacy Policy
We are very delighted that you have shown interest in our enterprise. 
Data protection is of a particularly high priority for the management of 
the Mkaa Sarl. The use of the Internet pages of the Mkaa Sarl is 
possible without any indication of personal data; however, if a data 
subject wants to use special enterprise services via our website, 
processing of personal data could become necessary. If the processing of 
personal data is necessary and there is no statutory basis for such 
processing, we generally obtain consent from the data subject.
 
The processing of personal data, such as the name, address, e-mail 
address, or telephone number of a data subject shall always be in line 
with the General Data Protection Regulation (GDPR), and in accordance 
with the country-specific data protection regulations applicable to the 
Mkaa Sarl. By means of this data protection declaration, our enterprise 
would like to inform the general public of the nature, scope, and 
purpose of the personal data we collect, use and process. Furthermore, 
data subjects are informed, by means of this data protection 
declaration, of the rights to which they are entitled.
 
As the controller, the Mkaa Sarl has implemented numerous technical and 
organizational measures to ensure the most complete protection of 
personal data processed through this website. However, Internet-based 
data transmissions may in principle have security gaps, so absolute 
protection may not be guaranteed. For this reason, every data subject is 
free to transfer personal data to us via alternative means, e.g. by 
telephone.
 
1. Definitions
The data protection declaration of the Mkaa Sarl is based on the terms 
used by the European legislator for the adoption of the General Data 
Protection Regulation (GDPR). Our data protection declaration should be 
legible and understandable for the general public, as well as our 
customers and business partners. To ensure this, we would like to first 
explain the terminology used.
 
In this data protection declaration, we use, inter alia, the following 
terms:
 
a)    Personal data
Personal data means any information relating to an identified or 
identifiable natural person (“data subject”). An identifiable natural 
person is one who can be identified, directly or indirectly, in 
particular by reference to an identifier such as a name, an 
identification number, location data, an online identifier or to one or 
more factors specific to the physical, physiological, genetic, mental, 
economic, cultural or social identity of that natural person.
 
b) Data subject
Data subject is any identified or identifiable natural person, whose 
personal data is processed by the controller responsible for the 
processing.
 
c)    Processing
Processing is any operation or set of operations which is performed on 
personal data or on sets of personal data, whether or not by automated 
means, such as collection, recording, organisation, structuring, 
storage, adaptation or alteration, retrieval, consultation, use, 
disclosure by transmission, dissemination or otherwise making available, 
alignment or combination, restriction, erasure or destruction.
 
d)    Restriction of processing
Restriction of processing is the marking of stored personal data with 
the aim of limiting their processing in the future.
 
e)    Profiling
Profiling means any form of automated processing of personal data 
consisting of the use of personal data to evaluate certain personal 
aspects relating to a natural person, in particular to analyse or 
predict aspects concerning that natural person's performance at work, 
economic situation, health, personal preferences, interests, 
reliability, behaviour, location or movements.
 
f)     Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner 
that the personal data can no longer be attributed to a specific data 
subject without the use of additional information, provided that such 
additional information is kept separately and is subject to technical 
and organisational measures to ensure that the personal data are not 
attributed to an identified or identifiable natural person.
 
g)    Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural 
or legal person, public authority, agency or other body which, alone or 
jointly with others, determines the purposes and means of the processing 
of personal data; where the purposes and means of such processing are 
determined by Union or Member State law, the controller or the specific 
criteria for its nomination may be provided for by Union or Member State 
law.
 
h)    Processor
Processor is a natural or legal person, public authority, agency or 
other body which processes personal data on behalf of the controller.
 
i)      Recipient
Recipient is a natural or legal person, public authority, agency or 
another body, to which the personal data are disclosed, whether a third 
party or not. However, public authorities which may receive personal 
data in the framework of a particular inquiry in accordance with Union 
or Member State law shall not be regarded as recipients; the processing 
of those data by those public authorities shall be in compliance with 
the applicable data protection rules according to the purposes of the 
processing.
 
j)      Third party
Third party is a natural or legal person, public authority, agency or 
body other than the data subject, controller, processor and persons who, 
under the direct authority of the controller or processor, are 
authorised to process personal data.
 
k)    Consent
Consent of the data subject is any freely given, specific, informed and 
unambiguous indication of the data subject's wishes by which he or she, 
by a statement or by a clear affirmative action, signifies agreement to 
the processing of personal data relating to him or her.
 
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation 
(GDPR), other data protection laws applicable in Member states of the 
European Union and other provisions related to data protection is:
 
Mkaa Sarl
 
26, rue de l´Industrie
 
8069 Bertrange
 
Luxembourg
 
Phone: +491738923514
 
Email: Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser.
 
 
3. Cookies
The Internet pages of the Mkaa Sarl use cookies. Cookies are text files 
that are stored in a computer system via an Internet browser.
 
Many Internet sites and servers use cookies. Many cookies contain a 
so-called cookie ID. A cookie ID is a unique identifier of the cookie. 
It consists of a character string through which Internet pages and 
servers can be assigned to the specific Internet browser in which the 
cookie was stored. This allows visited Internet sites and servers to 
differentiate the individual browser of the dats subject from other 
Internet browsers that contain other cookies. A specific Internet 
browser can be recognized and identified using the unique cookie ID.
 
Through the use of cookies, the Mkaa Sarl can provide the users of this 
website with more user-friendly services that would not be possible 
without the cookie setting.
 
By means of a cookie, the information and offers on our website can be 
optimized with the user in mind. Cookies allow us, as previously 
mentioned, to recognize our website users. The purpose of this 
recognition is to make it easier for users to utilize our website. The 
website user that uses cookies, e.g. does not have to enter access data 
each time the website is accessed, because this is taken over by the 
website, and the cookie is thus stored on the user's computer system. 
Another example is the cookie of a shopping cart in an online shop. The 
online store remembers the articles that a customer has placed in the 
virtual shopping cart via a cookie.
 
The data subject may, at any time, prevent the setting of cookies 
through our website by means of a corresponding setting of the Internet 
browser used, and may thus permanently deny the setting of cookies. 
Furthermore, already set cookies may be deleted at any time via an 
Internet browser or other software programs. This is possible in all 
popular Internet browsers. If the data subject deactivates the setting 
of cookies in the Internet browser used, not all functions of our 
website may be entirely usable.
 
4. Collection of general data and information
The website of the Mkaa Sarl collects a series of general data and 
information when a data subject or automated system calls up the 
website. This general data and information are stored in the server log 
files. Collected may be (1) the browser types and versions used, (2) the 
operating system used by the accessing system, (3) the website from 
which an accessing system reaches our website (so-called referrers), (4) 
the sub-websites, (5) the date and time of access to the Internet site, 
(6) an Internet protocol address (IP address), (7) the Internet service 
provider of the accessing system, and (8) any other similar data and 
information that may be used in the event of attacks on our information 
technology systems.
 
When using these general data and information, the Mkaa Sarl does not 
draw any conclusions about the data subject. Rather, this information is 
needed to (1) deliver the content of our website correctly, (2) optimize 
the content of our website as well as its advertisement, (3) ensure the 
long-term viability of our information technology systems and website 
technology, and (4) provide law enforcement authorities with the 
information necessary for criminal prosecution in case of a 
cyber-attack. Therefore, the Mkaa Sarl analyzes anonymously collected 
data and information statistically, with the aim of increasing the data 
protection and data security of our enterprise, and to ensure an optimal 
level of protection for the personal data we process. The anonymous data 
of the server log files are stored separately from all personal data 
provided by a data subject.
 
5. Contact possibility via the website
The website of the Mkaa Sarl contains information that enables a quick 
electronic contact to our enterprise, as well as direct communication 
with us, which also includes a general address of the so-called 
electronic mail (e-mail address). If a data subject contacts the 
controller by e-mail or via a contact form, the personal data 
transmitted by the data subject are automatically stored. Such personal 
data transmitted on a voluntary basis by a data subject to the data 
controller are stored for the purpose of processing or contacting the 
data subject. There is no transfer of this personal data to third 
parties.
 
6. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the 
data subject only for the period necessary to achieve the purpose of 
storage, or as far as this is granted by the European legislator or 
other legislators in laws or regulations to which the controller is 
subject to.
 
If the storage purpose is not applicable, or if a storage period 
prescribed by the European legislator or another competent legislator 
expires, the personal data are routinely blocked or erased in accordance 
with legal requirements.
 
7. Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European 
legislator to obtain from the controller the confirmation as to whether 
or not personal data concerning him or her are being processed. If a 
data subject wishes to avail himself of this right of confirmation, he 
or she may, at any time, contact any employee of the controller.
 
b) Right of access
Each data subject shall have the right granted by the European 
legislator to obtain from the controller free information about his or 
her personal data stored at any time and a copy of this information. 
Furthermore, the European directives and regulations grant the data 
subject access to the following information:
 
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data 
have been or will be disclosed, in particular recipients in third 
countries or international organisations;
where possible, the envisaged period for which the personal data will be 
stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification 
or erasure of personal data, or restriction of processing of personal 
data concerning the data subject, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory 
authority;
where the personal data are not collected from the data subject, any 
available information as to their source;
the existence of automated decision-making, including profiling, 
referred to in Article 22(1) and (4) of the GDPR and, at least in those 
cases, meaningful information about the logic involved, as well as the 
significance and envisaged consequences of such processing for the data 
subject.
Furthermore, the data subject shall have a right to obtain information 
as to whether personal data are transferred to a third country or to an 
international organisation. Where this is the case, the data subject 
shall have the right to be informed of the appropriate safeguards 
relating to the transfer.
 
If a data subject wishes to avail himself of this right of access, he or 
she may, at any time, contact any employee of the controller.
 
c) Right to rectification
Each data subject shall have the right granted by the European 
legislator to obtain from the controller without undue delay the 
rectification of inaccurate personal data concerning him or her. Taking 
into account the purposes of the processing, the data subject shall have 
the right to have incomplete personal data completed, including by means 
of providing a supplementary statement.
 
If a data subject wishes to exercise this right to rectification, he or 
she may, at any time, contact any employee of the controller.
 
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European 
legislator to obtain from the controller the erasure of personal data 
concerning him or her without undue delay, and the controller shall have 
the obligation to erase personal data without undue delay where one of 
the following grounds applies, as long as the processing is not 
necessary:
 
The personal data are no longer necessary in relation to the purposes 
for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based 
according to point (a) of Article 6(1) of the GDPR, or point (a) of 
Article 9(2) of the GDPR, and where there is no other legal ground for 
the processing.
The data subject objects to the processing pursuant to Article 21(1) of 
the GDPR and there are no overriding legitimate grounds for the 
processing, or the data subject objects to the processing pursuant to 
Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation 
in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of 
information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes 
to request the erasure of personal data stored by the Mkaa Sarl, he or 
she may, at any time, contact any employee of the controller. An 
employee of Mkaa Sarl shall promptly ensure that the erasure request is 
complied with immediately.
 
Where the controller has made personal data public and is obliged 
pursuant to Article 17(1) to erase the personal data, the controller, 
taking account of available technology and the cost of implementation, 
shall take reasonable steps, including technical measures, to inform 
other controllers processing the personal data that the data subject has 
requested erasure by such controllers of any links to, or copy or 
replication of, those personal data, as far as processing is not 
required. An employees of the Mkaa Sarl will arrange the necessary 
measures in individual cases.
 
e) Right of restriction of processing
Each data subject shall have the right granted by the European 
legislator to obtain from the controller restriction of processing where 
one of the following applies:
 
The accuracy of the personal data is contested by the data subject, for 
a period enabling the controller to verify the accuracy of the personal 
data.
The processing is unlawful and the data subject opposes the erasure of 
the personal data and requests instead the restriction of their use 
instead.
The controller no longer needs the personal data for the purposes of the 
processing, but they are required by the data subject for the 
establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of 
the GDPR pending the verification whether the legitimate grounds of the 
controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject 
wishes to request the restriction of the processing of personal data 
stored by the Mkaa Sarl, he or she may at any time contact any employee 
of the controller. The employee of the Mkaa Sarl will arrange the 
restriction of the processing.
 
f) Right to data portability
Each data subject shall have the right granted by the European 
legislator, to receive the personal data concerning him or her, which 
was provided to a controller, in a structured, commonly used and 
machine-readable format. He or she shall have the right to transmit 
those data to another controller without hindrance from the controller 
to which the personal data have been provided, as long as the processing 
is based on consent pursuant to point (a) of Article 6(1) of the GDPR or 
point (a) of Article 9(2) of the GDPR, or on a contract pursuant to 
point (b) of Article 6(1) of the GDPR, and the processing is carried out 
by automated means, as long as the processing is not necessary for the 
performance of a task carried out in the public interest or in the 
exercise of official authority vested in the controller.
 
Furthermore, in exercising his or her right to data portability pursuant 
to Article 20(1) of the GDPR, the data subject shall have the right to 
have personal data transmitted directly from one controller to another, 
where technically feasible and when doing so does not adversely affect 
the rights and freedoms of others.
 
In order to assert the right to data portability, the data subject may 
at any time contact any employee of the Mkaa Sarl.
 
g) Right to object
Each data subject shall have the right granted by the European 
legislator to object, on grounds relating to his or her particular 
situation, at any time, to processing of personal data concerning him or 
her, which is based on point (e) or (f) of Article 6(1) of the GDPR. 
This also applies to profiling based on these provisions.
 
The Mkaa Sarl shall no longer process the personal data in the event of 
the objection, unless we can demonstrate compelling legitimate grounds 
for the processing which override the interests, rights and freedoms of 
the data subject, or for the establishment, exercise or defence of legal 
claims.
 
If the Mkaa Sarl processes personal data for direct marketing purposes, 
the data subject shall have the right to object at any time to 
processing of personal data concerning him or her for such marketing. 
This applies to profiling to the extent that it is related to such 
direct marketing. If the data subject objects to the Mkaa Sarl to the 
processing for direct marketing purposes, the Mkaa Sarl will no longer 
process the personal data for these purposes.
 
In addition, the data subject has the right, on grounds relating to his 
or her particular situation, to object to processing of personal data 
concerning him or her by the Mkaa Sarl for scientific or historical 
research purposes, or for statistical purposes pursuant to Article 89(1) 
of the GDPR, unless the processing is necessary for the performance of a 
task carried out for reasons of public interest.
 
In order to exercise the right to object, the data subject may contact 
any employee of the Mkaa Sarl. In addition, the data subject is free in 
the context of the use of information society services, and 
notwithstanding Directive 2002/58/EC, to use his or her right to object 
by automated means using technical specifications.
 
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European 
legislator not to be subject to a decision based solely on automated 
processing, including profiling, which produces legal effects concerning 
him or her, or similarly significantly affects him or her, as long as 
the decision (1) is not is necessary for entering into, or the 
performance of, a contract between the data subject and a data 
controller, or (2) is not authorised by Union or Member State law to 
which the controller is subject and which also lays down suitable 
measures to safeguard the data subject's rights and freedoms and 
legitimate interests, or (3) is not based on the data subject's explicit 
consent.
 
If the decision (1) is necessary for entering into, or the performance 
of, a contract between the data subject and a data controller, or (2) it 
is based on the data subject's explicit consent, the Mkaa Sarl shall 
implement suitable measures to safeguard the data subject's rights and 
freedoms and legitimate interests, at least the right to obtain human 
intervention on the part of the controller, to express his or her point 
of view and contest the decision.
 
If the data subject wishes to exercise the rights concerning automated 
individual decision-making, he or she may, at any time, contact any 
employee of the Mkaa Sarl.
 
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European 
legislator to withdraw his or her consent to processing of his or her 
personal data at any time.
 
If the data subject wishes to exercise the right to withdraw the 
consent, he or she may, at any time, contact any employee of the Mkaa 
Sarl.
 
8. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing 
operations for which we obtain consent for a specific processing 
purpose. If the processing of personal data is necessary for the 
performance of a contract to which the data subject is party, as is the 
case, for example, when processing operations are necessary for the 
supply of goods or to provide any other service, the processing is based 
on Article 6(1) lit. b GDPR. The same applies to such processing 
operations which are necessary for carrying out pre-contractual 
measures, for example in the case of inquiries concerning our products 
or services. Is our company subject to a legal obligation by which 
processing of personal data is required, such as for the fulfillment of 
tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In 
rare cases, the processing of personal data may be necessary to protect 
the vital interests of the data subject or of another natural person. 
This would be the case, for example, if a visitor were injured in our 
company and his name, age, health insurance data or other vital 
information would have to be passed on to a doctor, hospital or other 
third party. Then the processing would be based on Art. 6(1) lit. d 
GDPR. Finally, processing operations could be based on Article 6(1) lit. 
f GDPR. This legal basis is used for processing operations which are not 
covered by any of the abovementioned legal grounds, if processing is 
necessary for the purposes of the legitimate interests pursued by our 
company or by a third party, except where such interests are overridden 
by the interests or fundamental rights and freedoms of the data subject 
which require protection of personal data. Such processing operations 
are particularly permissible because they have been specifically 
mentioned by the European legislator. He considered that a legitimate 
interest could be assumed if the data subject is a client of the 
controller (Recital 47 Sentence 2 GDPR).
 
9. The legitimate interests pursued by the controller or by a third 
party
Where the processing of personal data is based on Article 6(1) lit. f 
GDPR our legitimate interest is to carry out our business in favor of 
the well-being of all our employees and the shareholders.
 
10. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is 
the respective statutory retention period. After expiration of that 
period, the corresponding data is routinely deleted, as long as it is no 
longer necessary for the fulfillment of the contract or the initiation 
of a contract.
 
11. Provision of personal data as statutory or contractual requirement; 
Requirement necessary to enter into a contract; Obligation of the data 
subject to provide the personal data; possible consequences of failure 
to provide such data
We clarify that the provision of personal data is partly required by law 
(e.g. tax regulations) or can also result from contractual provisions 
(e.g. information on the contractual partner). Sometimes it may be 
necessary to conclude a contract that the data subject provides us with 
personal data, which must subsequently be processed by us. The data 
subject is, for example, obliged to provide us with personal data when 
our company signs a contract with him or her. The non-provision of the 
personal data would have the consequence that the contract with the data 
subject could not be concluded. Before personal data is provided by the 
data subject, the data subject must contact any employee. The employee 
clarifies to the data subject whether the provision of the personal data 
is required by law or contract or is necessary for the conclusion of the 
contract, whether there is an obligation to provide the personal data 
and the consequences of non-provision of the personal data.
 
12. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or 
profiling.
 
This Privacy Policy has been generated by the Privacy Policy Generator 
of the German Association for Data Protection that was developed in 
cooperation with Privacy Lawyers from WILDE BEUGER SOLMECKE, Cologne.