Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

2. Data We Collect

We collect the following categories of personal data:

• Contact data: Name, email address, company name, country — collected when you submit the contact form or book a call.
• Usage data: Pages visited, time on site, browser type — collected via Umami Analytics (EU-hosted, no cookies, no personal data).
• Communication data: Content of emails or messages you send us.
• Business data: Company size, industry, and challenges — provided voluntarily in the contact form.

3. Legal Basis for Processing

We process your personal data on the following legal bases under GDPR Article 6:

• Contractual necessity (Art. 6(1)(b)): To respond to your inquiry and provide the services you requested.
• Legitimate interests (Art. 6(1)(f)): To improve our services and website, and to conduct business development activities.
• Consent (Art. 6(1)(a)): For analytics cookies and marketing communications, where you have given explicit consent.
• Legal obligation (Art. 6(1)(c)): Where required by Luxembourg or EU law.

4. How We Use Your Data

• Responding to your inquiries and booking discovery calls
• Preparing and delivering AI consultancy proposals
• Sending service-related communications (not marketing without consent)
• Improving our website and services through anonymised analytics
• Complying with legal and regulatory obligations

5. Data Storage and Transfers

All personal data is stored and processed within the European Union. We use EU-hosted infrastructure (OVHcloud, Scaleway) for all AI solutions and data processing. We do not transfer personal data outside the EEA without appropriate safeguards.

6. Data Retention

We retain personal data only as long as necessary:

• Contact form submissions: 3 years from last contact
• Client project data: 7 years (Luxembourg accounting obligations)
• Analytics data: 13 months (anonymised)
• Marketing consent records: Until consent is withdrawn

7. Your Rights

Under GDPR, you have the following rights:

• Right of access (Art. 15): Request a copy of your personal data
• Right to rectification (Art. 16): Correct inaccurate data
• Right to erasure (Art. 17): Request deletion of your data
• Right to restriction (Art. 18): Limit how we process your data
• Right to portability (Art. 20): Receive your data in a machine-readable format
• Right to object (Art. 21): Object to processing based on legitimate interests
• Right to withdraw consent: At any time, without affecting prior processing

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the CNPD (Commission Nationale pour la Protection des Données), Luxembourg's data protection authority.

8. Cookies

We use minimal, privacy-respecting cookies. See our cookie consent banner for details. We use Umami Analytics, which is EU-hosted, cookie-free, and does not collect personal data. You can manage your cookie preferences at any time via the cookie settings link in the footer.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email (if you have provided one) or by posting a prominent notice on our website. The "Last updated" date at the top of this page indicates when it was last revised.

10. Contact

For any privacy-related questions or to exercise your rights:

Email: [email protected]

Post: CFO Digital Europe SARLS, 7 Avenue John F. Kennedy, L-1855 Luxembourg