PRIVACY POLICY

This policy applies to the processing of personal data carried out on the website of Alzette sàrl, whose registered office is located at 3, Côte d’Eich, L-1450 Luxembourg, Luxembourg.

GDPR contact: [email protected].

Your data may be processed to:

• respond to requests submitted through contact forms;
• manage commercial requests, the client relationship, and the preparation of management services;
• process incoming or outgoing telephone calls, including through an AI voice assistant;
• enable access to the site’s technical areas and functionalities;
• ensure the security, maintenance, and improvement of the service;
• detect and prevent fraud, abuse, or security incidents;
• produce traffic statistics (only with consent).

Data is processed on the basis of:

• performance of the service relationship (Art. 6(1)(b) GDPR);
• consent (Art. 6(1)(a) GDPR), in particular for non-essential cookies;
• legitimate interest (Art. 6(1)(f) GDPR) for security and technical stability;
• applicable legal obligations, including accounting and tax obligations where relevant.

Depending on your interaction with the site, we may collect:

• name, first name, email address, phone number, message;
• login identifiers, IP addresses, technical logs;
• browsing data (cookies and technical identifiers);
• content/voice data if you use artificial intelligence features, voice transcription, or automated messaging;
• recordings, transcripts, summaries, call metadata, and routing data when you use an Alzette phone line or voice assistant.

When you call an Alzette line handled by an AI voice assistant, or when Alzette calls you through this system, the call may be recorded, transcribed, and summarised in order to process your request, ensure operational follow-up, document necessary actions, and improve service quality.

The data concerned may include your phone number, name, the relevant building, the content of your request, transcripts, summaries, technical metadata, and actions carried out by the assistant.

If you do not wish to continue a recorded or transcribed voice exchange, you can say so during the call and use another contact channel, including email or the website form.

Call recordings and transcripts are retained for up to 12 months, unless longer retention is necessary for a client file, incident, evidence, legal obligation, or the defence of rights.

Data may be transmitted to processors strictly to the extent necessary for the operation of the service:

• Hetzner (hosting and technical infrastructure);
• Google Vertex AI (AI services, data processed in accordance with contracts and EU settings);
• ElevenLabs (audio/voice processing depending on usage);
• Twilio (communications, notifications, SMS/voice depending on usage);
• technical maintenance and security providers.

Where transfers outside the EEA may occur, they are carried out only with the safeguards required by applicable law.

Data is retained for the period strictly necessary for the purposes pursued and, where applicable, for the relevant legal obligations, and is then deleted or anonymised.

You have the following rights: access, rectification, erasure, restriction, objection, portability, and withdrawal of consent.

To exercise your rights: [email protected].

You may also lodge a complaint with the CNPD (Luxembourg).

The site uses cookies necessary for its basic operation. Non-essential cookies (audience measurement, improvement of advanced functionality, advertising) are activated only with your consent.

Appropriate technical and organisational measures are implemented to protect data (access control, secure communications, logging, permissions management, backups).

In the event of a serious security incident likely to affect your data, Alzette implements the remediation measures required by applicable regulation, including documentation and any required notification.

This policy may be amended. The applicable version is the one published at the time you consult the site.

This policy is governed by Luxembourg law.

Any dispute is subject to the exclusive jurisdiction of the courts of the Grand Duchy of Luxembourg.