Responsible for data processing
cegecom s.a.
3, rue Jean Piret
L-2350 Luxembourg
Tel: +352 26 49 91
E-Mail: info@cegecom.net
Contact Details Data Protection Officer
cegecom s.a.
Data Protection Officer
3, rue Jean Piret
L-2350 Luxembourg
E-Mail: datenschutz@cegecom.net
Purpose of Data Processing and Legal Basis
As part of the Managed Com Business solution (virtual VoIP telephone system), the iOS or Android app allows you to make and receive calls from anywhere using your office phone number. To do this, various types of data are processed for specific purposes and based on different legal grounds. Here is how we handle your data:
User Login
To use the app, you must log in with your personal credentials. This processing is based on contract performance (Article 6(1)(b) of the GDPR).
Session Data / Contact Data
Data transmitted during a session is encrypted, and the controller does not have access to any plain data. Audio and video data are not permanently stored and may only be temporarily cached until the end of the session for technical reasons. This processing is also based on contract performance (Art. 6(1)(b) GDPR).
You may allow the app to access your local contacts stored on your device to simplify usage. This processing is based on your consent (Art. 6(1)(a) GDPR).
Technical Provision of the App
To provide the app’s intended features, certain data is automatically processed and stored in a log file. The app does not use cookies or web analytics tools.
This processing is based on our legitimate interest in ensuring secure and error-free operation (Art. 6(1)(f) GDPR).
Categories of data processed
User Login
To use the app, the following personal data categories are processed:
Username
Session Data / Contact Data
The following categories of personal data may be processed during sessions:
Communication data
If you have given your explicit consent, the app may also access:
Local contact data (name, phone number) stored on your device. This data remains on your device and is not uploaded to any server via the app.
Technical Operation
To ensure secure and smooth app functionality, the following data may also be processed:
App information
Device ID, IP address
Operating system of your device
Date and time of use
Data recipients, service providers, data transfers to third countries
If you download the app through a third-party app store (e.g., Apple, Google), those providers may also process your personal data. They are solely responsible for such processing, and further details can be found in their respective privacy policies.
cegecom may use carefully selected and commissioned service providers (or sub-processors), some of which may be located outside the European Economic Area (EEA) in so-called “third countries” that do not offer an adequate level of data protection. In such cases, standard EU contractual clauses are used to ensure appropriate safeguards.
A copy of these clauses is available online at eur-lex.europa.eu or upon request from our Data Protection Officer.
Other possible recipients may include public authorities (e.g. police, tax authorities, data protection regulators) or third parties such as legal advisors or auditors, in legally justified cases.
Data retention period
We process and store your data only as long as necessary for the specific purpose. After this period, your data will be deleted or anonymised according to legal or contractual retention periods.
Session data is deleted or anonymised according to the retention period required by the Luxembourg Regulatory Institute.
Your data protection rights
In accordance with legal provisions, you have the right to:
Access your personal data
Request rectification or erasure
Restrict or object to processing
Data portability
Withdraw your consent at any time (without retroactive effect)
Withdrawing consent does not entail any additional costs beyond the basic rates.
Questions or Complaints Regarding Data Protection
If you have any questions or complaints, you can contact our Data Protection Officer at: datenschutz@cegecom.net.
You also have the right to lodge a complaint with the supervisory authority:
Commission Nationale pour la Protection des Données (CNPD) – Luxembourg
Obligation to Provide Data
Providing personal data is generally required for using the app. Without it, we may not be able to fulfil the intended purposes described above.
This does not apply to uses based on consent.
Automated Decision-Making and Profiling
No automated decision-making or profiling is carried out.