Privacy Policy

Privacy Policy


Clarity Consulting (collectively “Clarity”) understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits Our website which includes the websites of our respective offices. We will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the applicable data privacy laws for your region/country.

As a company located in the European Union, we are committed to protecting your privacy in accordance with EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”).

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

  • “Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall incorporate the definitions provided in the General Data Protection Regulation (“GDPR”).
  • “We/Us/Our/Clarity” means Clarity Consulting S.à r.l as the company that is relevant for processing your data through your use of Our Site. Refer to “Information About Us” for information on Our registered office.
  • The “Data Controller” is the legal entity or individual who determines the purposes and means of the processing of personal data.
  • “Joint data controllers” are two or more entities that together determine the purposes and means of processing personal data. They share responsibility for compliance with data protection obligations.
  • A “Data Subject” is any identified or identifiable natural person whose personal data is collected, held or processed by the Data Controller. In the context of this website, Data Subjects include any visitors, users, or individuals who communicate with us through the site.

‍

Information About Us


The table below outlines the identifying details of the Data Controller and its respective designated Data Protection Officer (DPO) that own and operate our Site.
‍

Joint Data Controllers or Contact Local Data Protection Officer or Contact
Clarity Consulting S.à r.l, Société à Responsabilité Limitée registered in Luxembourg.
Address: 48 rue de Bragance - L-1255 Luxembourg – Luxembourg.
Ms. Alexandra Da Silva
Email: data.protection@clarityconsulting.lu



What Does This Policy Cover?


This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

=
‍

What Data Do We Collect?

‍

Depending upon your use of Our Site, we may collect some or all of the following personal data:
‍

  • Identity information (first name, surname, business/company name, date of birth, gender);
  • Contact information (postal address, postal code, email address, telephone numbers);
  • Invoice data (amount and due date of invoices, reminders, receipts);
  • Payment information (bank or postal details);
  • Our correspondence (email exchanges, telephone reports, letters);
  • Technical data (Cookie, IP address, MAC address, timestamp, web browser type and version, operating system).
    ‍


What is the Purpose and Legal Basis of Processing Your Personal Data?

‍

‍

Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
‍

‍

1. Communications (by way of phone, emails, contact forms where applicable):

‍

  • respond to your enquiries about our services;
  • contact you if you have any questions;
  • offer our services and help;
  • providing customer service and support;
  • register complaints.
    ‍

2. Contract:

‍

  • determine whether and how we enter into a contract with you;
  • enter into a contract;

‍

3. Market research and product development:

‍

  • to improve our services, products and commercial activities through market research and satisfaction surveys;
  • Produce internal statistics.

‍

4. Compliance with legal requirements:

‍

  • check that our activities comply with applicable legislation;
  • answer your questions and requests relating to data protection;
  • cooperate with the judicial, criminal or administrative authorities where there are objective grounds or legal obligations.


‍

When data processing is not covered by one of the aforementioned justifications, We will require your free and informed consent. This will be the case in particular if We are required to process sensitive data concerning you. You are free to withdraw your consent at any time.


‍

Do We share your data?


In the context of our contractual relations and the other purposes mentioned under “Purpose and Legal Basis of Processing Your Personal Data”, we may communicate all or part of your data to the following recipients:

‍

‍

  • Contractual partners: We may work with partners in order to provide you with the services stipulated in the contracts that bind us to you, such as companies commissioned to carry out work. We therefore only provide them with the personal data concerning you that is absolutely necessary for the provision of their services.
  • Service providers: We may work with various service providers who enable us to carry out certain data processing and other activities (e.g., IT service providers, address verification services, debt collection services, transport companies, and financial service providers).
  • Authorities: In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data (e.g., legal proceedings, complying with legal obligations, a court order, or a governmental authority).
    ‍

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, and other information. Principles of anonymisation, data minimisation, and purpose limitation are duly respected in data sharing.

Your personal data is mainly processed in the local jurisdiction of which you have submitted your information to. If your data must be transferred abroad, it will be transferred within the countries of the European Economic Area and/or countries offering an adequate level of protection. Where this is not the case, your data will be transferred to partners and service providers committed to respecting the contractual data protection clauses, if necessary, with additional measures.

Your data will be stored in the respective locations of which you have submitted your data to. If necessary, there may be transfer of certain personal data between and/or amongst Our group of companies in “Information About Us”, for the purposes described in “Purpose and Legal Basis of Processing Your Personal Data” if the applicable legal requirements are met.

‍

Your Rights


As a data subject, you have the following rights under your respective data privacy law, which this Policy and Our use of personal data have been designed to uphold:
‍

  • The right to be informed about Our collection and use of personal data.
  • The right of access to the personal data We hold about you. Under the respective data privacy laws, no fee is payable, and We will provide all information in response to your request free of charge. For more details, please contact the local Data Protection Officers as per “Information About Us”.
  • The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in “Information About Us”).
  • The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in “Do We Share Your Data” but if you would like Us to delete it sooner, please contact Us using the details in “Information About Us”).
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to withdraw your consent to the processing of your data for which your consent has been requested.
  • The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation).
  • The right to object to Us using your personal data for particular purposes; and
  • Rights with respect to automated decision making and profiling.
    ‍

Please contact Us using the details provided in “Information About Us”,
‍

  • If you have any cause for complaint about Our use of your personal data;
  • If you have any questions or wish to exercise your data protection rights.


If you are not satisfied with our response, you may contact your respective local regulatory authority.



How and Where Do We Store Your Data?


We only keep your personal data for as long as We need, and/or for as long as We have your permission to keep it. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
‍
Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

  • All personal data, depending on its nature, may be retained for 5 years.
  • Your data will be stored in the respective locations of which you have submitted your data to


Data security is very important to Us, and to protect your data We have taken suitable technical and organizational measures to safeguard and secure data collected through Our Site. These measures are taken according to the data processed, the means of processing and the purpose of the data. Our contractual partners and employees have limited access to the personal data required to perform their services and are required to comply with data protection provisions.


‍
‍

What Happens If Our Business Changes Hands?


We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

‍

How Can You Control Your Data?


In addition to your rights under the respective data privacy laws, set out in Privacy Policy statement, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes


‍

Changes to Our Privacy Policy


We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.

Last update: March 2026
‍
‍

CLARITY CONSULTING

‍

Cookie Policy

‍

COOKIE POLICY


This website www.clarityconsulting.lu (“Our Site”) uses Cookies and similar technologies in order to distinguish you from other users. By using Cookies, We are able to provide you with a better experience and to improve Our Site by better understanding how you use it. Please read this Cookie Policy carefully and ensure that you understand it. Your acceptance of Our Cookie Policy is deemed to occur if you continue using Our Site. If you do not agree to Our Cookie Policy, please stop using Our Site immediately.

Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

  • “Cookie” means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site;
  • “Cookie Law” means the relevant parts of the General Data Protection Regulation (“GDPR”).
  • “Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. incorporate the definitions provided in the General Data Protection Regulation (“GDPR”).
  • “We/Us/Our/Clarity” means Clarity Consulting S.à r.l. as the company that is relevant for processing your data through your use of Our Site. Refer to “Information About Us” for information on Our registered offices.

    ‍

Information About Us


Our Site is owned and operated by:
‍

Joint Data Controllers or Contact Local Data Protection Officer or Contact
Clarity Consulting S.à r.l, Société à Responsabilité Limitée registered in Luxembourg.
Address: 48 rue de Bragance - L-1255 Luxembourg – Luxembourg.
Ms. Alexandra Da Silva
Email: data.protection@clarityconsulting.lu

‍
‍

What are Cookies?

‍

‍

Cookies are small files that get saved on your computer or device when you visit certain websites.


Cookies are useful because they allow us to recognize your device. They serve many different purposes, like allowing you to navigate between pages more efficiently, remembering your preferences, and generally improving your overall experience of our websites.

There are two main types of cookies:

  • First-party cookies, which come from the website you are visiting.
  • Third-party cookies, which come from other companies that provide services through the website, like advertisers or analytics tools.

‍


Cookies can last for different lengths of time:

  • Session cookies last only while you’re on the website and are deleted when you leave.
  • Persistent cookies stay on your device for a set time and help the website remember you on future visits.

‍

‍
‍

How Does Our Site Use Cookies?


Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and always respected.

‍
All Cookies used by and on Our Site are used in accordance with relevant Cookie Laws. We may use some or all of the following types of Cookie:

‍

1. Strictly Necessary/Technical Cookies
‍

  • A Cookie falls under this category if it is essential to the operation of Our Site, supporting functions such as responding you by email if you contact us.

‍

‍

2. Performance/Analytics Cookies
‍

  • It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.

‍

‍

3. Functionality/Personalisation Cookies

‍

  • Cookies that fall under this category enables Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.

‍

‍

4. Target Cookies
‍

  • It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to improve the experience of our website.

‍

‍

5. Third Party Cookies

‍

  • Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you.

‍

‍

6. Persistent Cookies

‍

  • Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.

‍


For more details of the personal data that We collect and use, the measures we have in place to protect personal data, your legal rights, and our legal obligations, please refer to our Privacy Policy.
‍

‍

Cookies do not collect personal information or reveal anything about you or your family. They also can’t be used by others to access your data or harm your device. We don’t use cookies to contact you for marketing.
‍

‍

What Cookies Does Our Site Use?

‍

‍

The following first party Cookies may be placed on your computer or device:
‍

Name of Cookie Purpose & Type Strictly Necessary Expiry
ASP.NET_Session Id Preserves the visitor's session state across page requests. Yes Session length
cookiepopup Manages a popup to notify the user of our Cookie usage No Session length

‍
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

If you do not wish your data to be collected via Google Analytics, you can also install the official Google opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout.
‍


The analytics service(s) used by Our Site use(s) the following analytics Cookies:

‍

Name of Cookie Purpose & Type Strictly Necessary Expiry
_ga Registers a unique ID that is used to generate statistical data on how the visitor uses the website. No 12 months
_gat Used by Google Analytics to throttle request rate No Session length
_gid Registers a unique ID that is used to generate statistical data on how the visitor uses the website. No Session length
collect Used to send data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels. No Session length


Consent and control


Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to accept those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. By continuing to use Our site then you consent to the usage of these cookies.

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

The links below provide instructions on how to control Cookies in all mainstream browsers:

‍


Managing Your Cookie Preferences


You have the right to decide whether to accept or reject non-essential Cookies. Upon your first visit to Our Site, a cookie banner will appear, allowing you to:

  • Accept all Cookies;
  • Refuse all non-essential Cookies;
  • Manage your preferences by selecting which types of Cookies you accept (e.g., Analytics, Marketing, Functional).


You can modify your preferences at any time via the “Cookie Settings” link available at the bottom of each page.
‍
If you refuse Cookies, only strictly necessary Cookies will be placed on your device, and no data will be collected for statistical or marketing purposes.
‍
‍

Changes to this cookie policy


We may alter this Cookie Policy at any time. Any such changes will become binding on you on your first use of Our Site after the changes have been made. You are therefore advised to check this page from time to time.

In the event of any conflict between the current version of this Cookie Policy and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.

‍

Further Information


If you would like to know more about how We use Cookies, please contact Us by email or post at the contact information provided in “Information About Us”.

Last update: March 2026

Download PDF button.