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Who is responsible for your personal data?

This Privacy Policy applies to the personal data of drivers under contract with SLA that SLA collects and uses when drivers use the SL Pad.

References made in this Privacy Policy to either “SLA”, “the Company”, “we”, “us” or “our” mean “SLA” S.A. (a company registered in Luxembourg with registration no. B0049878 and registered office at 4, rue Laangwiss Hautcharage).

We determine the ways your personal data are collected and the purposes for which your personal data are used by SLA as we are the “data controller” for the purposes arising from Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter « the Regulation »).

SLA is part of a corporate group of companies (« our Group »), which includes:

– Autocars Sales-Lentz S.A. with headquarters located at 4, rue Laangwiss, Hautcharage L-4940 (LU) with registration no. B0007475

– SLA S.A. with headquarters located at 4, rue Laangwiss, Hautcharage L-4940 (LU) with
registration no. B0049878

– Bartholmé Clervaux Autocars S.A. with headquarters located at Op der Hei, Hosingen L-9809 (LU) with registration no. B0095160

– Frisch Rambrouch Autocars S.A. with headquarters located at zone industrielle Riesenhof L-8821 (LU) with registration no. B0098665

– Ross Troine Autocars S.A. with headquarters located at maison 1A, Allerborn L-9631 (LU) with registration no. B0095215

– Transports Huberty S.A. with headquarters located at 325 route de Longwy, Rodange
L-4831 (LU) with registration no. B18182

Note that each legal entity within our Group is to be considered the local “data controller” for personal data processing activities that are directly related to its functions.
 
Privacy Policy
 
How your personal data will be used. 
 
The use of the SL Pad is regulated by the General Data Protection Regulation (GDPR), and the Luxembourgish Data Protection Act of 1 August 2018. Please note that this device stores personal data that is necessary to undertake your job duties. When you undertake your driving duties with the SL PAD, we process the following categories of personal data:
 
Your contact details as a driver:
Name, First name, ID number, Workday details

Contact details of your passengers (non-ADAPTO):
Name, first name, address, telephone number, children if a child seat is required

Contact details of your passengers (ADAPTO):
If there is a passenger with a wheelchair or a visually impaired person (without medical details)

Geolocation of the Tablet (Door2Gate program), only for van drivers:
Manual activation and deactivation of the Geolocation for the proper functioning of the program.

Pictures or videos stored on the Tablet, only for van drivers when using the “Fleet Lab Driver” :
Pictures and other information from your device’s camera and photo library
 
 
While using our application “Fleet Lab Driver”, in order to provide certain features, we may collect:
 
•        Information regarding your location (background and foreground)
•        Pictures and other information from your device’s camera and photo library
 
We use this information to provide features of our service, and to improve and customise our service. The information may be uploaded to the company’s servers and/or a service provider’s server or it may be simply stored on your device. We collect and process personal data for the purpose of connecting passengers with drivers to help them move around cities more efficiently. Geolocation and driving routes are processed to analyse the geographical area and give suggestions to the drivers. If you do not want to disclose your geolocation you can change the permissions granted in the settings of your device. You can enable or disable access to this information at any time, through your device settings.
 
The personal data that is stored in the SL PAD, particularly that of your passengers, is sensitive and valuable. Therefore, if your SL PAD is lost or stolen, or if the personal data on this device is accessed without your authorisation, you must immediately inform your line manager.
 
This information will be retained for as long as necessary to carry out the activities in question and in accordance with the minimum legal retention periods. You have the right to request access to, rectification or deletion of your personal data.
 
For more information on respecting your personal rights, we encourage you to contact
– Your line manager
– The data protection team at rgpd@slg.lu
 
If you would like to receive the revised version of our GDPR Privacy Policy, we encourage you to send a simple request to rgpd@slg.lu
 
If you are not satisfied with the processing of your data, you can file a complaint with the National Commission for Data Protection (information available at www.cnpd.public.lu)
 
Updates to our Privacy Policy
We may periodically update this Privacy Policy to reflect changes in our data protection practices or applicable laws.
This Privacy Policy was last updated on: 23.02.2022
 
Contact Information
Questions, comments, and requests regarding this Privacy Policy should be addressed to our Data Protection Officer using the following email address: gdpr@slg.lu