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Privacy Policy1. Personal Data Collected and Purpose of Collection2. Website Usage and Traffic Analysis3. Access to Personal Data4. Data Security Measures5. Data Retention6. Data Subject Rights 7. Data Breach Notification8. Data Controller9. Changes to This Privacy Policy

Privacy Policy

AP LUX S.A. is committed to protecting the privacy, confidentiality, and security of personal data processed through its website. This Privacy Policy explains how and why personal data is collected, used, stored, and protected, in accordance with applicable data protection legislation, including the General Data Protection Regulation (GDPR – EU 2016/679). 


1. Personal Data Collected and Purpose of Collection

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1.1 Sensitive Personal Data

AP LUX S.A. does not intentionally collect sensitive personal data, such as information relating to racial or ethnic origin, political opinions, religious beliefs, trade union membership, health, sexual life, or criminal records.

Such data is processed only when:

  • It is voluntarily provided by the individual, or
  • It is required or permitted by applicable law or professional standards

Individuals are strongly advised not to provide sensitive personal data unless strictly necessary and with explicit consent for its use and storage for legitimate business purposes.

For any uncertainty, you may contact us at contact@ap-lux.lu before submitting such information.

1.2 Recruitment and Applications

When you submit a résumé, cover letter, or other application materials via our website, the information provided is used exclusively for:

  • Assessing your application
  • Identifying suitable job opportunities
  • Managing the recruitment process

Only data strictly required for these purposes is collected. Where optional or additional information is requested, this is clearly indicated at the point of collection.

2. Website Usage and Traffic Analysis

Like many websites, AP LUX S.A. uses web analytics tools to understand how visitors interact with its website and to improve performance and usability.

These tools collect anonymized technical data, such as:

  • Approximate geographic location
  • Browser type and version
  • Device and operating system
  • Pages visited and navigation paths

This data does not allow AP LUX S.A. to directly identify individuals. IP addresses are processed in a way that prevents direct identification. Analytics providers act solely as data processors on behalf of AP LUX S.A.

Users may disable cookies via their browser settings; however, this may affect certain website functionalities.

3. Access to Personal Data

Personal data is accessed strictly on a need-to-know basis.

Depending on the purpose, access may be granted internally to:

  • Human Resources and recruitment teams
  • Interviewers involved in the recruitment process
  • Relevant managers
  • IT personnel, where access is required for system maintenance or security

Personal data may be shared with third parties only when necessary and in accordance with applicable laws and contractual safeguards.

4. Data Security Measures

AP LUX S.A. applies appropriate technical and organizational measures to protect personal data against:

  • Unauthorized access
  • Loss or destruction
  • Accidental disclosure or misuse

Access to personal data is restricted to authorized personnel and subject to internal confidentiality obligations.

5. Data Retention

Personal data is retained only for the duration necessary to fulfill the purpose for which it was collected.

  • Unsuccessful recruitment applications: data is retained for 12 months after the end of the recruitment process.
  • Successful recruitment applications: data is transferred to the employee’s personnel file and retained for the duration of employment, in accordance with legal requirements.

6. Data Subject Rights

In accordance with GDPR, individuals have the right to:

  • Access their personal data
  • Request correction of inaccurate or incomplete data
  • Request deletion or restriction of processing, where applicable
  • Object to processing based on legitimate interest

Requests may be sent to: contact@ap-lux.lu

If you believe your data protection rights have not been respected, you have the right to lodge a complaint with the competent National Data Protection Authority.

 7. Data Breach Notification

In the event of a personal data breach that poses a risk to individuals’ rights and freedoms, AP LUX S.A. will notify the relevant authorities and affected individuals within 72 hours, in accordance with legal obligations.

8. Data Controller

The data controller for this website is:

AP LUX S.A.

Company number: B302037

Registered office:

6, rue Heine

L- 1720 Luxembourg

Grand Duchy of Luxembourg

Email: contact@ap-lux.lu

9. Changes to This Privacy Policy

This Privacy Policy may be updated periodically to reflect legal, regulatory, or operational changes. The most recent version will always be available on this website. Users are encouraged to review it regularly.