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Privacy Statement

This Privacy Statement applies to this website and governs the collection, use, and processing of personal data.

In accordance with the provisions of the EU General Data Protection Regulation (GDPR) (EU Regulation No. 2016/679 of 27 April 2016) and other relevant national data protection laws, we are committed to ensuring the privacy and security of your personal data.

As part of our operations, we may collect, store, and process personal data, and we are required to inform you of your rights and how your data is handled.

Who we are

We are LuxProvide SA, a Luxembourg company based at Atrium Business Park, 31, Rue du Puits Romain, L-8070 Bertrange, Luxembourg.

As a data controller, we are responsible for the collection and processing of your personal data in accordance with the GDPR. Our goal is to protect your privacy and safeguard your personal data throughout its lifecycle.

What this website does — and does not — collect

Flinky is an informational website. It does not use cookies, analytics, advertising or tracking technologies, it embeds no third-party content, and it loads no external resources (fonts and assets are served from our own domain). As a result, the site itself does not profile you or build a record of your browsing behaviour.

We only process personal data in the following limited situations:

  • When you contact us by email. If you write to us (for example at info@lxp.lu), we process the contact details and the content of your message in order to handle and respond to your request.
  • Server log data. Like virtually all websites, our hosting provider automatically records technical access data (such as your IP address, browser type, and the date and time of the request). This is used solely to operate the site securely and to diagnose technical problems.

If you provide us with the personal data of third parties, you are required to inform those individuals of the processing of their data and provide them with a copy of this Privacy Statement.

Purposes and legal basis

We process the limited data above for the following purposes:

  • To respond to inquiries, requests, or complaints you send us by email — based on your consent and our legitimate interest in communicating with you;
  • To operate, secure and maintain the website — based on our legitimate interest in providing a reliable, secure service;
  • To protect our legal interests and comply with legal obligations, in case of disputes or legal proceedings.

Your personal data will not be used for purposes that are incompatible with the reasons for which it was collected.

Sharing your personal data

Your personal data is processed by our authorized staff members, all of whom are bound by confidentiality obligations.

We may share your personal data with trusted third-party service providers (“processors”) who act on our behalf under GDPR-compliant contracts — in practice, our website hosting provider. Such processors are located within the European Economic Area (EEA). We do not sell your personal data, and we do not share it with advertisers or other third parties for their own purposes.

Additionally, we may be required to disclose your personal data in response to legal obligations, such as complying with a court order, responding to subpoenas, or cooperating with law enforcement agencies.

Your rights

Under the GDPR, you have several important rights concerning your personal data, including:

  • The right to access your personal data and request a copy
  • The right to rectify inaccurate or incomplete personal data
  • The right to object to the processing of your data (including for marketing purposes, where applicable)
  • The right to request the restriction of the processing of your data in specific circumstances (e.g., if it is inaccurate)
  • The right to request the erasure of your personal data when it is no longer necessary for the purposes for which it was collected
  • The right to request the portability of your personal data, where technically feasible

To exercise these rights, please contact our Data Protection Officer (DPO) at: dpo@lxp.lu. We will respond to your request as promptly as possible, in accordance with applicable data protection laws.

Please note that these rights are not absolute, and there may be situations where we are unable to fulfil a request.

You also have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (CNPD), the Luxembourg supervisory authority, located at 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg.

Data security

We take the security of your personal data seriously and implement appropriate organisational, technical, and physical measures to protect it. These measures include safeguards against unauthorized access, loss, alteration, disclosure, or destruction of your personal data.

Data retention

Email correspondence is retained only for as long as necessary to handle your request and, where relevant, to meet our legal obligations — after which it is securely deleted. Technical server logs are kept for a short period for security and diagnostics, then deleted or anonymized.

In some cases, we may anonymize personal data so that it no longer identifies individuals, in which case it may be kept indefinitely without restriction.

Once your personal data is no longer needed for the purposes for which it was collected, it will be securely deleted in compliance with applicable laws.

Changes to this Privacy Statement

We reserve the right to update or amend this Privacy Statement at any time to reflect changes in our data collection practices or to comply with legal requirements. We encourage you to review this statement periodically to stay informed about how we protect your personal data.

By continuing to use our website, you acknowledge that you have read and understood this Privacy Statement.