Blacktrack - Data Protection Statement
Udpate : 17th March 2021
The respect of your privacy is an essential point of our engagements.
The purpose of our confidentiality policy is to inform you with transparency on the process that we put in place in order to carefully treat the personal information that you entrust to us.
Our confidentiality policy intend to respect the following legislations:
The General Data Protection Regulation (GDPR) of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of these data.
Any legislation applicable to BLACKTRACK regarding the protection of personal data.
Note on minors under 15:
The company BLACKTRACK doesn't treat voluntary datas from minors under 15 years old. Any personal data on a minor under 15 will be immediately deleted.
Any user of the website is required to ensure that no minor under 15 years old transmits any personal data.
The people in charge of the data processing
What personal data is processed? For what purpose? Who is concerned by the processing of personal data? What is the legal basis for the processing? How long is the data kept?
What are the rights of a person concerned by the processing of his/her personal data by BLACKTRACK?
Can the company BLACKTRACK refuse the application of a person's right?
How can a person concerned by the processing of his or her data exercise his or her rights?
Are cookies used by BLACKTRACK?
Who are the recipients of the personal data?
Where is the personal data hosted and are they kept safely?
Is the data transferred outside the European Union?
Our confidentiality policy applies on all personal data processed by the responsible of the data processing: the company BLACKTRACK, as part of the use of the services provided by it, notably through its website:
2-The people in charge of the data processing
BLACKTRACK is the entity responsible for handling personal data collected with a registered capital of 31 000 €. BLACKTRACK has its head office in 1 Rue de l'Alzette, 7210 Helmsange, Luxembourg and is registered at the Registre du Commerce et des Sociétés of Luxembourg under the number LU 2828 5816.
Phone number: +352 24 84 00 59
3-What personal data is processed? For what purpose? Who is concerned by the processing of personal data? What is the legal basis for the processing? How long is the data kept?
The company BLACKTRACK, which is responsible for processing, minimizes the gathering of all personal data and ensures that it only processes personal data that is strictly necessary for the purposes for which it is collected.
The main characteristics of the personal data processing activities are as follows:
Why are personal data processed?
What is the legal basis for the processing?
What categories of personal data are concerned by the processing?
Who is concerned by the processing of personal data?
How long is the data kept?
In order to respond to requests made via the contact form.
Legitimate interest of BLACKTRACK to respond to requesters.
-Name and first name
-Phone number (not required)
-Subject of the message
Users of the website who have made a request via our contact form.
6 months from the last contact
In order to send our emailing campaigns to people who have subscribed to our newsletter.
User's consent to receive our email campaigns.
-Frequency of emailing desired
Website users who have subscribed to our newsletter.
36 months maximum
In order to send our commercial offers to people who have agreed to receive our commercial offers when they register for a customer account on our website, or when they subscribe to our newsletter.
Consent of the user to receive our commercial offers.
Legitimate interest of BLACKTRACK to carry out prospecting (only to offer similar products or services to people who have already placed orders).
-First and last name
-Date of consent / Date of last purchase
Users of the website who have accepted to receive our commercial offers via their registration to our newsletter, or via their registration to a customer account on our website.
Customers who have placed an order on
36 months maximum from the last contact or the last order placed
13 months maximum
Ensure the monitoring of data security vulnerabilities.
Legal obligation to ensure compliance with applicable data protection provisions.
-Name and first name
Data subjects whose personal data have been subject to a security breach
12 months maximum
Ensure the effectiveness of the rights of the persons concerned and ensure the identity of the persons concerned who exercise the rights resulting from the applicable regulations on the protection of personal data.
Legal obligation to ensure compliance with applicable data protection provisions.
-Name and first name
-Customer account credentials if there is one
-Copy of an ID if necessary
Persons exercising one of their rights under the GDPR
Maximum 13 months
*except for ID card: 1 month maximum
In order to publish the comment left by the user on the site's corporate blog of
Legitimate interest of the company BLACKTRACK to operate the company blog (freedom of expression).
-Nom et prénom
-Date et heure du message laissé
Internet users who comment on the blog
In order to publish the testimonial left by an adopter on the site
Legitimate interest of the company BLACKTRACK to operate the company's guestbook.
-First and last name
-Date and time of the message left
Adopters who leave a testimonial
5 years from the last testimony left, except with the express consent of the person concerned.
When the processing is based solely on the consent of the person concerned, the latter may at any time withdraw his consent by simple request sent to BLACKTRACK according to the modalities detailed in the Article 2.
The company BLACKTRACK does not process sensitive data within the meaning of the applicable regulations on the protection of personal data without legal authorization or the express consent of the person concerned.
When a person enters personal data directly (in particular by means of a digital or online form) or by sending emails, the information concerning him/her is provided with full knowledge of the facts and under his/her responsibility as to its content and accuracy.
Fields with an * in any digital or online form are personal data that must be provided. Lack of response to the data indicated with an * in any form may not allow BLACKTRACK to respond to the request made.
4-What are the rights of a person concerned by the processing of his/her personal data by BLAKCTRACK?
4.1. The right of access
The person concerned has the right to obtain from the company BLACKTRACK the confirmation that personal data concerning him/her are or are not processed and, when they are processed, access to those personal data as well as the following information:
Purposes of the treatment;
The categories of personal data concerned;
The recipients or categories of recipients to whom the personal data has been or will be communicated, in particular recipients who are established in third countries or international organizations;
Whenever possible, the length of time the personal data is to be retained or, when this is not possible, the criteria used to determine this length of time;
The existence of the right to request from the data controller the rectification or deletion of personal data, or a limitation on the processing of personal data relating to the data subject, or the right to object to such processing;
The right to submit a complaint to a supervisory authority;
Where personal data is not collected from the person concerned, any information available as to its source;
The existence of automated decision support, including profiling, as referred to Article 22(1) and (4) of Regulation (EU) 2016/679 "General Regulation on Data Protection", and, at least in such cases, useful information concerning the underlying logic, as well as the importance and the expected consequences of such processing for the data subject.
When personal data is transferred to a third country or to an international organization, the data subject has the right to be informed of the appropriate guarantees, in accordance with Article 46 of Regulation (EU) 2016/679 "General Regulation on Data Protection", with respect to such transfer.
In case of exercise of the right of access, the company BLACKTRACK will provide a copy of the personal data being processed, unless this copy infringes copyright or the rights of third parties.
The Company BLACKTRACK may charge a reasonable fee based on administrative costs for any additional copies requested by the individual.
4.2. A right of rectification
The person concerned has the right to obtain from the company BLACKTRACK, as soon as possible:
The rectification of inaccurate personal data.
In consideration of the purposes of the processing, that incomplete personal data must be completed, including by submitting an additional declaration.
4.3. A right to be forgotten
The data subject has the right to obtain from the company BLACKTRACK the erasure, as soon as possible and except in the cases referred to in Article 17.3 of Regulation (EU) 2016/679 "General Regulation on Data Protection", of personal data concerning him/her, where one of the following grounds applies:
Personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
The data subject withdraws the consent on which the processing is based, in accordance with Article 6(1)(a) of Regulation (EU) 2016/679 "General Data Protection Regulation", or Article 9(2)(a) of Regulation (EU) 2016/679 "General Data Protection Regulation", and there is no other legal basis for the processing;
The person concerned objects to the processing pursuant to Article 21(1) of Regulation (EU) 2016/679 "General Data Protection Regulation", and there are no compelling legitimate reasons for the processing, or the person concerned objects to the processing pursuant to Article 21(2) of Regulation (EU) 2016/679 "General Data Protection Regulation";
Personal data has been processed unlawfully;
Personal data must be erased in order to comply with a legal obligation laid down by Union law or by the law of the Member State to which the controller is subject;
The personal data have been collected within the context of the offer of information society services referred to in Article 8, paragraph 1 of Regulation (EU) 2016/679 "General Regulation on Data Protection".
The right to be forgotten does not apply if the processing is or continues to be necessary:
To the exercise of the right to freedom of expression and information;
To comply with a legal obligation which requires processing in accordance with Union law or the law of the Member State to which the controller is subject, or to fulfil a task carried out in the public interest or in the exercise of official authority vested in the controller;
For reasons of public interest in the field of public health, in accordance with Article 9(2)(h) and (i) of Regulation (EU) 2016/679 "General Regulation on Data Protection" and Article 9(3) of Regulation (EU) 2016/679 "General Regulation on Data Protection";
For archival purposes in the public interest, for purposes of scientific or historical research or for statistical purposes in accordance with Article 89(1) of Regulation (EU) 2016/679 "General Data Protection Regulation", insofar as the right referred to in paragraph 1 is likely to render impossible or seriously jeopardize the achievement of the purposes of such processing;
The recognition, exercise or defence of legal rights.
4.4. A right to limitation of treatment
The person concerned has the right to obtain from the company BLACKTRACK the limitation of the processing when one of the following applies:
The accuracy of the personal data is contested by the data subject for a period of time that allows the data controller to verify the accuracy of the personal data;
The processing is unlawful and the person concerned opposes their deletion and demands instead the limitation of their use;
The data processor no longer needs the personal data for the purpose of processing, but they are still necessary for the data subject to establish, exercise or defend his rights in court;
The person concerned has opposed the processing on the basis of his right to, during the verification as to whether the legitimate grounds pursued by the controller prevail over those of the data subject.
4.5. A right of opposition
THE DATA SUBJECT HAS THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO HIS OR HER PARTICULAR SITUATION, TO THE PROCESSING OF PERSONAL DATA RELATING TO HIM OR HER WHERE:
- THE PROCESSING IS NECESSARY FOR THE PERFORMANCE OF A TASK CARRIED OUT IN THE PUBLIC INTEREST OR IN THE EXERCISE OF OFFICIAL AUTHORITY VESTED IN THE CONTROLLER;
- PROCESSING IS NECESSARY FOR THE PURPOSES OF THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY, UNLESS THE INTERESTS OR FUNDAMENTAL RIGHTS AND FREEDOMS OF THE DATA SUBJECT WHICH REQUIRE THE PROTECTION OF PERSONAL DATA PREVAIL, IN PARTICULAR WHERE THE DATA SUBJECT IS A CHILD;
- PROCESSING IS NECESSARY FOR THE PURPOSES OF THE LEGITIMATE INTERESTS PURSUED BY THE DATA PROCESSOR OR BY A THIRD PARTY, UNLESS THE INTERESTS OR FUNDAMENTAL RIGHTS AND FREEDOMS OF THE PERSON CONCERNED WHICH REQUIRE THE PROTECTION OF PERSONAL DATA PREVAIL, IN PARTICULAR WHERE THE PERSON CONCERNED IS A CHILD;
- PROCESSING IS CARRIED OUT FOR COMMERCIAL PROSPECTING PURPOSES AT ANY TIME, INCLUDING PROFILING INSOFAR AS IT IS RELATED TO SUCH PROSPECTING.
THE DATA PROCESSOR WILL NO LONGER PROCESS PERSONAL DATA, UNLESS IT CAN DEMONSTRATE THAT THERE ARE LEGITIMATE AND COMPELLING REASONS FOR THE PROCESSING THAT PREVAIL OVER THE INTERESTS AND RIGHTS AND FREEDOMS OF THE PERSON CONCERNED, OR FOR THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL RIGHTS, EXCEPT IN THE CASE OF COMMERCIAL PROSPECTING.
WHEN PERSONAL DATA ARE PROCESSED BY BLACKTRACK FOR THE PURPOSES OF SCIENTIFIC OR HISTORICAL RESEARCH OR FOR STATISTICAL PURPOSES, THE DATA SUBJECT HAS THE RIGHT TO OBJECT, FOR REASONS RELATING TO HIS OR HER PARTICULAR SITUATION, TO THE PROCESSING OF PERSONAL DATA CONCERNING HIM OR HER, UNLESS THE PROCESSING IS NECESSARY FOR THE PERFORMANCE OF A TASK CARRIED OUT IN THE PUBLIC INTEREST.
4.6. A right to data portability
The person concerned has the right to receive the personal data concerning him/her that he/she has provided to BLACKTRACK, in a structured, commonly used and machine-readable format, and has the right to transmit such data to another controller without BLACKTRACK to whom the personal data have been communicated, when :
The processing is based on consent pursuant to Article 6(1)(a) of Regulation (EU) 2016/679 "General Data Protection Regulation" or Article 9(2)(a) of Regulation (EU) 2016/679 "General Data Protection Regulation", or on a contract pursuant to Article 6(1)(b) of Regulation (EU) 2016/679 "General Data Protection Regulation";
The treatment is carried out using automated processes.
4.7. For concerned persons living in France, a right to define guidelines on the fate of the data after his death.
The person concerned by the processing of his or her data has the right to define guidelines for the storage, deletion and disclosure of his or her personal data after his or her death.
4.8. Absence of any automated individual decision making, including profiling
The company BLACKTRACK does not carry out any decisions based exclusively on automated processing, including profiling, which produce legal effects with respect to the person concerned by the processing of his/her data or significantly affect him/her in a similar way.
5- Can the company BLACKTRACK refuse the application of a person's right?
The company BLACKTRACK can refuse the exercise of its rights by a person concerned when:
- The person concerned does not allow BLACKTRACK to be able to ensure the identification of the person concerned;
- The requests made by a data subject are manifestly disproportionate or excessive due to their repetitive or systematic character.
6- How can a person concerned by the processing of his or her data exercise his or her rights?
The rights can be exerted by a simple letter sent to 1 Rue de l'Alzette, 7210 Helmsange, Luxembourg or by e-mail to firstname.lastname@example.org.
In case of reasonable doubt(s) as to the identity of the person concerned, the Company BLACKTRACK may request a copy of a piece of identification in order to ensure the exact identity of the person making any request and to avoid the disclosure of data to an illegitimate third party.
If the response provided by BLACKTRACK does not satisfy the data subject, the data subject is informed by this policy that he or she may file a complaint with the regulatory authority of the place of his or her habitual residence, place of work or the place where the violation was allegedly committed by mail or directly at the site of the regulatory authority, namely:
In France: Commission Nationale de l'Informatique et des Libertés 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 or
In Deutschland: die bundesbeauftragte für den datenschutz und die informationsfreiheit, Graurheindorfer Str. 153, 53117 Bonn, Allemagne or https://www.bfdi.bund.de/DE/Home/home_node.html
In the United Kingdom: Information Commissioner's Office, Wycliffe House, Water Ln, Wilmslow SK9 5AF, United Kingdom or https://ico.org.uk/
In Italia: Garante per la protezione dei dati personali, la Piazza Venezia 11, 00187 Roma, Italia ou https://www.garanteprivacy.it/
In Spain: Agencia Española de Protección de Datos, Jorge Juan 6, 28001 Madrid, Espagne or https://www.aepd.es/es
In Portugal: Comissão nacional de proteção de dados, Ave. D. Carlos I 134-1°, 1200-151 Lisboa, Portugal or https://www.cnpd.pt/
In Belgium: Autorité de protection des données Rue de la Presse 35 - 1000 BRUXELLES, or www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plaint
In Luxembourg: Commission nationale pour la protection des données, Service des réclamations- 15, Boulevard du Jazz, L-4370 Belvaux or https://cnpd.public.lu/fr/particuliers/faire-valoir/formulaire-plainte.html
In Switzerland: Préposé fédéral à la protection des données et à la transparence, Feideggwerg 1, 3003 Berne, Switzeland or https://www.edoeb.admin.ch/edoeb/fr/home.html
In the Netherland: Dutch Data Protection Authority, Postbus 93374, 2509 AJ, DEN HAAG, the Netherland or https://www.autoriteitpersoonsgegevens.nl/
In the United States: Federal Trade Commission 600 Pennsylvania Ave, NW, Washington, DC 20580, USA or
In México: Instituto Federal de Acceso a la Información y Protección de Datos, Av. Insurgentes Sur #3211 Col. Insurgentes Cuicuilco, Delegación Coyoacán, C.P. 04530, Distrito Federal, Mexico or https://home.inai.org.mx/
In Australia: Office of the Australian Information Commissioner, GPO Box, 5218 Sydney NSW 2001, Australia, or https://www.oaic.gov.au/
In Canada: Commissariat à la Protection de la vie privée au Canada, 30 rue de Victoria, Gatineau, Québec, K1A 1H3, Canada or https://www.priv.gc.ca/fr/
In Japon: Personal Information Protection Commission, 1-9-13, Akasaka Minato-Ku, Tokyo 107-0052, Japon, or https://www.ppc.go.jp/en/
In South Korea, Personal Information Protection Commission, 209 Sejong-ro, Jongno-gu, Seoul, 110-760, Corée, or http://www.pipc.go.kr/cmt/main/english.do
7- Are cookies used by BLACKTRACK?
8- Who are the recipients of the personal data?
The company BLACKTRACK only communicates personal data to authorized and determined recipients. The recipients can be the following:
9- Where is the personal data hosted and are they kept safely?
The company BLACKTRACK applies all appropriate measures to prevent, to the extent possible, any alteration or loss of personal data or unauthorized access to it.
The company BLACKTRACK pays particular attention to the storage of personal data and requests from its service providers a commitment of compliance with applicable data protection provisions. It thus endeavours, as far as possible, to store data in France or in a member country of the European Union, unless the data entered by the person concerned has been entered by him or her in a third country. The data is currently hosted at:
The individuals and legal entities hosting the personal data
What categories of processed personal data are affected by the hosting?
All data mentioned in article 3
Data collected via the newsletter registration form, via the contact form
Data collected via the newsletter registration form
Data collected through cookies.
See the CookieS Policy
E-mail exchanges between Internet users and the company BLACTRACK
E-mail exchanges between Internet users and the company BLACKTRACK
E-mail exchanges between Internet users and the company BLACKTRACK
On the other hand, it is the responsibility of the person concerned to ensure the confidentiality of his/her login and password to access the site operated by BLACKTRACK, which cannot be held responsible if a third party has illegitimately accessed this data due to the fault or negligence of the person concerned.
10- Is the data transferred outside the European Union?
Personal data processed by the company BLACKTRACK are not transferred outside the EU.