Privacy policy
1. The controller (Art. 13(1)(a) GDPR)
The controller responsible for the processing of personal data within the meaning of the GDPR and other national data protection laws of the Member States and other data protection regulations is:
Me Yann Baden (liquidator)
z.a. Gehaansraich 5001
6187 Gonderange
Grand Duchy of Luxembourg
2. Purpose and legal basis of processing (Art. 13(1)(c) GDPR)
As part of the dissolution and liquidation process, we collect and process your personal data for the following purposes:
- Me Yann Baden is the court-appointed liquidator.
- We determine, establish and pay your insolvency claim.
- You are involved in a legal dispute with us to determine your insolvency claim.
We process the data collected so that we can fulfil our legal and regulatory obligations in this regard. The legal basis for this processing is Art. 6(1)(c) GDPR (compliance with a legal obligation). Insofar as we process special categories of personal data, the legal basis is Art. 9(2)(f) GDPR. Processing is limited to what is necessary for these purposes, in accordance with the principle of data minimisation.
3. Categories of personal data (Art. 14(1)(d) GDPR)
Personal data is any information relating to a natural person that can be used to identify that person. This includes, among other things:
- Name, date of birth and age, gender, place of birth, marital status, address, nationality, email address.
- Telephone number, etc.
- Tax number, tax identification number, etc.
- Bank details, credit information, etc.
- Contractual relationships
- Financial circumstances
In addition, special categories of personal data may be collected and processed to ensure the proper execution of procedures. This may include information about health or disability. This applies in particular when we collect and process your personal data to determine insolvency claims arising from the insurance relationship.
4. Origin / Duty to provide information
In the context of the settlement and liquidation proceedings, we initially receive your personal data from the insolvency debtor. We also collect your personal data directly from you. In certain cases and only with your consent, we collect special categories of personal data, such as health data, from doctors.
5. Recipients
In order to fulfil our legal obligations, we may in certain cases disclose personal data to third parties, in particular in extrajudicial or judicial proceedings initiated by you against us. These include, in particular, external lawyers, insurance brokers and/or courts. Personal data will only be disclosed to insurance brokers if required by a court or if the insurance broker has signed a non-disclosure agreement (NDA) obliging them to use the personal data exclusively for the purpose of defence in extrajudicial or judicial proceedings. We also transfer personal data to the competent insolvency court.
Should there be any changes regarding the recipients, an updated list of recipients will be published on our website: baden.lu.
6. Processing time / storage period
We initially store your personal data until the dissolution and liquidation proceedings have been completed. This storage is necessary so that we can fulfil our legal obligations during this period. Beyond that, we only store personal data for as long as we are required to do so by law.
7. Customer portal (cp.fwulifelux.com)
The Customer Portal (cp.fwulifelux.com) is a web-based tool hosted in Luxembourg. It serves to ensure the transparent handling of the liquidation proceedings and enables you to view the status of your claim and upload the necessary documents.
- Security: Access to the Customer Portal (cp.fwulifelux.com) is protected by two-factor authentication using a username, password and one-time password. Communication between your web browser and the Customer Portal (cp.fwulifelux.com) is secured with SSL encryption.
- Email notifications: You will receive an automatic email notification when there are new messages or updates in the Customer Portal (cp.fwulifelux.com). This email does not contain any personal data other than your email address in the header.
8. Website, cookies and local storage
The following provisions apply to visits to the websites: fwulifelux.com, baden.lu and cp.fwulifelux.com. Personal data is only collected, stored and processed to the extent that this is absolutely necessary for the provision of a functional website and its content and services.
Log files: Each time our website is accessed, data and information from the computer system of the accessing computer is automatically collected. This includes: the user's IP address, date and time of access, name and URL of the file accessed, website from which access is made (referrer URL), browser used and, if applicable, the operating system of your computer and the name of your Internet access provider.
The data is stored in log files to ensure the functionality and security of the website. The data is deleted as soon as it is no longer required for the purpose for which it was collected. This data is used for system security and statistical analysis and does not allow any direct conclusions to be drawn about your person.
We use technical storage mechanisms (cookies, LocalStorage) whose storage or access to your terminal equipment is absolutely necessary in accordance with Art. 5(3) of Directive 2002/58/EC (ePrivacy Directive) in order to provide you with the "Customer-Portal" (cp.fwulifelux.com) service you have expressly requested. Consent is not required for this. The subsequent processing of the data collected in this way is based on the legal grounds of the GDPR specified in the following table.
| Technology / Name | Purpose of storage and processing (Art. 13(1)(c) GDPR) | Classification (ePrivacy Directive) | Legal basis (Art. 13(1)(c) GDPR) | Legitimate interest (Art. 13(1)(d) GDPR) | Storage period (Art. 13(2)(a) GDPR) |
|---|---|---|---|---|---|
| Session cookie (Keycloak) | Maintaining your authenticated user session (login status) and storing your status. | Absolutely necessary (provision of the desired "login" service). | Art. 6(1)(f) GDPR (legitimate interest). | Fulfilment of the specific user request to ensure the desired "login" service. | Duration of the browser session (deleted when the browser is closed). |
| LocalStorage (language) | Storage of the language setting you have actively selected in order to provide the website in the desired language. | Absolutely necessary (provision of the desired service in the requested form). | Art. 6(1)(f) GDPR (legitimate interest). | Fulfilment of the specific user request to retain the "language" configuration. | Until manually deleted by the user in the browser. |
The data listed in the table is technically necessary for the provision of the "Customer Portal" service (cp.fwulifelux.com) you have requested. Without the storage of this information, the functionality of the service cannot be guaranteed (necessity of providing the data (Art. 13(2)(e) GDPR)).
9. Your rights
When we process your personal data, you as the data subject have the following rights:
- In accordance with Art. 15 GDPR, you have the right to request information about your personal data processed by us.
- In accordance with Art. 16 GDPR, you have the right to request the immediate correction of inaccurate or incomplete personal data stored by us.
- According to Art. 17 GDPR, you have the right to request the erasure of your personal data stored by us, provided that one of the reasons specified in Art. 17 GDPR applies.
- In accordance with Art. 18 GDPR, you have the right to request the restriction of the processing of your personal data, provided that the legal requirements for this are met.
- In accordance with Art. 20 GDPR, you have the right to have the personal data you have provided to us transferred to you or, if you expressly request it, to another controller in a structured, commonly used and machine-readable format.
- Pursuant to Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority, without prejudice to other administrative or judicial remedies, if you consider that the processing of your personal data infringes the GDPR. As a rule, you can contact the supervisory authority of the Member State of your habitual residence or the place of the alleged infringement. The competent supervisory authority in Luxembourg is:
Commission Nationale pour la Protection des Données (CNPD)
15, Boulevard du Jazz
4370 Belvaux
Grand Duchy of Luxembourg
10. Changes to the privacy policy
We reserve the right to amend this privacy policy at any time in accordance with the applicable data protection regulations. The amendments will be published on the following websites: fwulifelux.com, baden.lu and cp.fwulifelux.com
11. Contact
If you have any questions about data protection, please contact:
Mr Yann Baden(liquidator)
c/o FWU Life Insurance Lux S.A. (in liquidation)
17, Rue de la Poudrerie
3364 Leudelange
Grand Duchy of Luxembourg
Telephone: +352 26 26 11 11
Email: [email protected]