Privacy Policy

Last modified: 2020

(applicable to visitors of website)

This Privacy Policy describes the way Docler Holding S.à r.l. (hereinafter, “Docler”, “we”, “our” or “ us”) collects, uses and shares personal information of a visitor (hereinafter “you”) of website (hereinafter “the website ”, “our website”).

If you apply for a job position at the Docler group, this Privacy Policy is not applicable to you. Instead, the policy located at this link is applicable.

Also, this Privacy Policy is not applicable to employees of a Docler company who connect themselves to the Intranet page of our website. This part of our website is not available for you. Any processing of personal information related to it is part of a non-public internal policy applicable to employees.

You can contact us if you have any question about our privacy practices. We will be happy to provide you any assistance you may need.


The company which decides how and why your personal data is processed, and which is called “Data Controller” is Docler Holding S.à r.l., a Luxembourg law governed private limited liability company with registered address at 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg Trade and Companies Register under number B 180726.


We collect, use, share, transfer, and store different types of your personal information as a result of your visit of our website and/or your initiative to call us and/or to contact us by mail at our address 44 Avenue John F. Kennedy, L-1855 Luxembourg, Grand Duchy of Luxembourg or e-mail at

The personal data we collect includes the following categories of data:

Personal Information we get when you visit our website

We collect certain information about you when you navigate on our website:

o Browsing data and device information

When you visit our website, we temporarily store browsing data and information from or about your computer, phone, or other device you use to access or navigate on our site. This includes:

- Your IP address;

- Your time zone;

- The date, time and duration of your visit;

- The type of the device you use (i.e. iPad) at the moment of your visit;

- The type of your device’s operating system (i.e. iOS 3.1) and what type of internet browser you use (i.e., Mozilla Firefox, Opera, etc.);

o Information collected by cookies and other technologies

Like many websites, and web applications, we use cookies and other technologies (such as web beacons and web storage) to collect information about your activity, browser, and device.

Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that blocking cookies may affect your use of our website. To learn more about how we use cookies and your choices, please check out our Cookies Policy.

Personal data you give to us when you contact as by any means

o Content information

We collect any communication data such as telephone conversations, e-mails and letters you send to us. More generally, when you communicate with us in any other way, we will collect whatever information you provide us with.


We use the information we collect for the following purposes:

Website management and optimization

We use the information we collect when you visit our website to manage and optimize our website, and to ensure its proper functioning.

We also use this information to analyze how visitors use our website.

We process this information given our legitimate interest to improve the user experience of our website for all visitors.

Public relationship and communication with you

When you decide to provide us voluntarily with any communication data, we use this information to respond to your requests or inquiries and to communicate your communication to the designated department or service at the group level.

When you contact us via e-mail, our PR department who manages our public relationships receives your communication. When you send us a mail or a fax, our receptionists receive your communication and escalate it afterwards to the designated person/entity.

We process this information given our legitimate interest in improving our public relationships.

Ensure a safe and trustworthy environment

Because we want to create and ensure a safe environment, we use your personal data to detect and prevent fraud and other illegal activities related to the use of our website.

We use your personal information for security purposes and risk assessment.

We process this information given our legitimate interest in ensuring fraud detection and prevention, as well as, information, system, network and cyber security.

Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data, such as to respond to requests of competent authorities or to establish, exercise or defend legal claims.


We implement serious security measures to grant maximum protection to your personal information against unauthorized access, modification, disclosure or deletion. Your data is always protected by our highly sophisticated security systems.

We actively implement data loss prevention systems against leakage, theft and data breach in order to ensure that our website and the entire IT infrastructure related to it are updated against the latest network security vulnerabilities. We periodically test our IT systems and do sophisticated penetration tests. Our website incorporates the most advanced security technologies available in order to ensure maximum safety of our visitors and the safekeeping of their related information.


We share certain details of your personal data with the following parties:

Entities of Docler Group

We never share your browsing data and device information, as well as information collected by cookies and other technologies with any other entity.

We do transfer, however, the communications you send to us, to the respective designated person and/or entity within our group of companies.

Our employees or employees of one of our group company

We share your communication data with the designated employees or employees of one of our group company.

Social media – sharing content via Facebook plugin

You can share the content of our website (i.e., pictures, videos, etc.) on Facebook. For this purpose, we use the Facebook plugins, which can be recognized by the Facebook “Share” and “Like” buttons on our website.

When you choose to share or like a content, a direct connection between your browser and the Facebook server is established via the plugins. This enables Facebook to receive the information that you have shared or liked a content from our website. The plugins we use do not automatically transfer your data to Facebook, but only if you choose to by clicking on the “Share” and/or “Like” button. Please note that, we do not know which content you transmitted to Facebook or how Facebook uses these data. For more information, please see Facebook’s privacy policy.

Law enforcement agencies or governmental authorities

We may also share your information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, and/or (c) protect our rights or defend ourselves against any claims.

Business transfers

Finally, please also note that your information may also be transferred to another company in the following events:

- Sale of the whole or part of our business to a third party;

- Restructuring at the level of our group of companies affecting directly or indirectly our business;

- Mergers and acquisitions at the group level, including third parties involvement, affecting directly or indirectly our business related to booking hotels and other services.


As we are a Luxembourg based company, we comply with the EU Data Protection Regulation commonly called "GDPR" (If you want to learn more you can check: EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ), which provides a high level of protection of your personal data.

In the course of the management of our website, your personal information may be transferred outside of the European Economic Area ("EEA") to our subsidiaries, related or affiliated companies located in the US, for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.


We did our best to explain what your rights are and how you can exercise them. If, despite of our below explanations, you are still unsure about the actions you can take or the conditions of exercise of your rights, do not worry, we will provide you with all the assistance you need when exercising your rights.

Data access and data portability

You have the right to access the personal information about you by requesting us a copy of your personal data free of charge.

Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

Data retention and erasure

We generally retain your personal information for as long as it is necessary for the purposes specified in this Privacy Policy and to comply with our legal obligations.

If you no longer want us to use your information, you can request us to erase your personal information.

Please note that if you request the erasure of your personal information:

- We might retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we ban you from our website for fraud or illegal activities, we may retain certain information about you to prevent you from visiting our website in the future. Such information shall also be kept available in case of ongoing judicial proceedings/and or investigations.

- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.

- In order to protect our website and your personal information from accidental or malicious loss and destruction, we have backup systems. Residual copies of your personal information may not be removed from our backup systems for a limited period.

Right to object

We process your data for a couple of reasons as explained in “4. WHY DO WE PROCESS YOUR PERSONAL DATA?”. Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

Please keep in mind that objecting to the use of your data might affect negatively our public relationship with you.

Right to restriction of processing

You have the right to request that we hold your personal data in “limbo”, while other challenges are resolved. You can ask us to put on hold the use of your data in 4 cases:

- If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.

- You have objected to a processing activity based on legitimate interest(s): in this case, you can require the processing operation to be put on hold while we verify the grounds for processing.

- You consider that the processing is unlawful but you object to erasure and request restriction, instead.

- We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority (in particular in the Member State where you live, place of work or of an alleged infringement of the GDPR).


We do not have any possibility to know if you are a child unless you provide us with a communication on which you state your age. For all types of communications, we will never use personal data of children under the age of 16 without the consent of the child’s parent or legal guardian.


We may occasionally amend this Privacy Policy to reflect any changes to our website and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on our website.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our website, unless we specify a date of entry into force. Your continued visit of our website from that day on will be subject to the new Privacy Policy.


Docler Services S.à r.l. (registered office: 44 Avenue John F. Kennedy, L-1855 Luxembourg, Grand Duchy of Luxembourg, company registration number: B207465, hereinafter: “Data Controller”) has installed three (3) cameras in the parking (-2) of the building. 

The following video surveillance data is processed:

- Real-time image/video monitored by the video surveillance cameras;
- Video recording kept for a maximum period of seven (7) days.

The data controller only monitors/records the image/video and not the audio.

Purposes of the data processing: prevent the theft of information/hacking and the theft/damage of physical goods.

The processing is necessary for the purposes of the legitimate interests pursued by the controller (protection of the goods and data of the company).

Data access/sharing:

-        Only the IT Security team of the Data Controller has access to the system.

-        In case of incident, a committee composed of an employee of the competent departments to deal with the case will have direct access to the recordings of the last seven days.

-        Depending on the incident, the recordings might be provided to the management of Docler Services S.à r.l. (on a need to know basis) and to the police/law enforcement authorities.

Data Subjects Rights:

Any individual whose image is processed through the video surveillance system has the right to access the personal information processed by requesting a copy of the recording free of charge or the erasure of the data, unless specific circumstances apply (e.g. an incident occurred and rendered impossible the erasure of the data until the investigation is closed).

Data subjects also have a right to object (i.e. require the data controller not to process personal information for certain specific purposes where such processing is based on legitimate interest) and a right to the restriction of processing (i.e., in case the data accuracy is contested, the data subject has objected to the processing based on legitimate interest, in case of unlawful processing, or need to establish, exercise, or defend legal claims).

If a data subject considers that the data processing at stake infringes the Regulation EU 2016/679 or any other applicable national laws, he/she has the right to lodge a complaint with a supervisory authority.

Contact details

In case of questions or queries about the data processing through the video surveillance cameras, please contact the data protection officer of Docler Services S.à r.l. at


If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to or via mail to the address indicated below, and we will get quickly back to you. We are always glad to talk about our privacy practices.

Docler Holding S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

We are also happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at: or mail to the following address:

To the attention of the DPO

Docler Holding S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Cookies Policy

Last modified: 2020

Like many websites and applications, our site uses cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) for different purposes. In this policy, we refer to all of these technologies as “cookies.” Through cookies, we are collecting information about your device and your activity, for example your bowser type and browser information, you computer’s operating system, your IP address, the pages you viewed or the features you used.

This policy explains how and why we use cookies and the choices you have.


Cookies are small text files that are placed on your device (e.g. your computer, phone or tablet) when visiting and navigating on certain websites and applications. Cookies track certain of your activities or preferences. Internet cookies are common and will not cause any harm to your device.

Some of our business partners may themselves use cookies. We have no access or control over these cookies. Cookies can either be “first party”, meaning that they are associated with the host domain e.g., or “third party cookies” in case we allow others to place cookies on our site, such as analytics cookies.


  • Ensure the security and the integrity of our site

We use cookies to help us to ensure a safe and trustworthy environment. Cookies help us to fight against security breach on our site, as well as against any activity violating the rules of our site.

  • Analytics and research

Our site uses analytics cookies. We use these cookies to gain insight into how you use our site. This helps us to understand how you interact with our site, what is interesting for you and how we can improve our services, and enhance your user’s experience.


We may also allow certain third party service providers to place cookies on our site for the above-mentioned purposes. For example, in order to help us to understand how you interact with our websites, what is interesting for you and how we can improve our services, we use Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking here.


Most browsers automatically accept cookies, but you can block cookies by modifying your browser or device settings.

Please however note that, if you use your browser or device settings to block all cookies, you may experience reduced functionality on our services.

Privacy policy for candidates

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