1. Purpose and Scope
This policy describes how Thermal Design Solutions Sàrl (“TDS”, “we”, “us”, “our”), with its registered office at 13, rue du Canal, L-4050 Esch-sur-Alzette, Luxembourg, collects, uses, shares, and protects your personal data through its website www.tds.lu, its Microsoft 365 services, and any other online services.
TDS is the data controller (“responsible person”) and complies with Regulation (EU) 2016/679 (“GDPR”) and applicable Luxembourg regulations.
Website hosting management, maintenance and technical support are provided by Styx Consulting. The website is hosted on the Netlify platform. Contact form submissions are processed through Netlify Forms, and access to the publication management area is authenticated through Netlify Identity.
2. Definitions
- Personal Data: Any information relating to an identified or identifiable natural person.
- Processing: Any operation performed on personal data (collection, recording, storage, use, disclosure, erasure).
- Controller: The entity that determines the purposes and means of the processing.
- Processor: The entity that processes data on behalf of the controller.
3. Categories of Personal Data We Collect
Depending on your relationship with TDS, we may collect:
- Identification & Contact: name, job title, address, email, phone number.
- Professional Data: position, department, CV, diplomas.
- Account Data: login credentials, connection logs, IP addresses.
- Financial Data: billing information, payment details.
- Technical Data: device type, browser, cookies, analytics.
- Communication Data: exchanges via forms, emails.
- Other Data: any information you voluntarily provide.
4. How We Collect Personal Data
- Directly from you: web forms, emails, contracts, phone calls.
- Automatically: technical cookies, browser storage and hosting logs, including IP addresses and information needed to operate and secure the website.
- From third parties: business partners, authorities, service providers.
5. Purposes and Legal Basis for Processing
| Purposes | Data Concerned | Legal Basis |
|---|---|---|
| Provision and management of the site and portals | Identification, account, technical data | Performance of a contract (Art. 6(1)(b) GDPR) |
| Microsoft 365 and cloud services | Identification, account, communications | Performance of a contract (Art. 6(1)(b)) |
| Billing and legal obligations | Financial data, identification | Legal obligation (Art. 6(1)(c)) |
| Customer support & communication | Communications, contact, technical | Legitimate interest (Art. 6(1)(f)) |
| Recruitment and HR management | Identification, professional, background | Performance of a contract & legal obligation (Arts. 6(1)(b),(c)) |
| Marketing & newsletters (with consent) | Contact, communications | Consent (Art. 6(1)(a)) |
| Site analysis and improvement | Technical data | Legitimate interest (Art. 6(1)(f)) |
6. Data Recipients
- Styx Consulting (styxconsulting.be): website hosting management, maintenance and technical support on behalf of TDS.
- Netlify, Inc. (netlify.com): website hosting and delivery, server functions, contact form processing (Netlify Forms) and publication administrator authentication (Netlify Identity).
- Other processors: Microsoft Ireland (Microsoft 365 and appointment booking), Amazon Web Services (publication media storage), payment providers, consultants and auditors, where relevant to the services used.
- TDS Group Members: HR, finance, IT services on a need-to-know basis.
- Public Authorities: CNPD, courts, in case of a legal obligation.
Styx Consulting and the technical providers process website personal data on TDS’s behalf for the services entrusted to them. Access is limited to the data needed for those services. TDS remains responsible for the purposes of processing and for responding to requests to exercise your data protection rights.
7. Data Transfer Outside the EU
Service providers, including Netlify and Microsoft, may process certain data outside the European Economic Area (EEA), including in the United States. International transfers are subject to the safeguards applicable to the provider and service concerned, including:
- Adequacy decisions of the European Commission, including the EU–US Data Privacy Framework where applicable;
- Standard contractual clauses approved by the Commission and included in the relevant data processing agreements, where applicable.
Netlify’s processing of customer data is described in its Data Processing Agreement. Further information is available in its Privacy Statement.
8. Your Rights
In accordance with Articles 15 to 21 of the GDPR, you can:
- Access your data;
- Rectify or complete inaccurate data;
- Request erasure (“right to be forgotten”);
- Restrict processing;
- Obtain data portability;
- Object to processing on legitimate grounds;
- Withdraw your consent at any time.
To exercise these rights, contact Dr. Fadil Ayad at info@tds.lu. You can also file a complaint with the CNPD.
9. Cookies
The website uses technical cookies and browser storage for the following functions:
- Authenticate publication administrators and maintain their sessions through Netlify Identity;
- Remember your language preference in your browser’s local storage.
You can delete cookies and local storage through your browser settings. Disabling technical cookies may prevent access to the publication management area; deleting the language preference resets your language selection.
10. Security Measures
- TLS encryption in transit and encryption at rest;
- Access controls and role-based permissions;
- Regular security audits and staff training;
- Notification to the CNPD within 72 hours in case of a data breach.
11. Data Retention Period
| Data Category | Duration |
|---|---|
| Job Applications | 1 year after the last contact |
| HR Files | 10 years after the end of the contract |
| Invoices & Business Relations | 10 years after the end of the relationship |
| Technical logs | For the period needed to operate and secure the services, subject to the applicable hosting provider’s retention settings and legal obligations |
| Authentication cookies | Until session expiry or logout |
| Language preference | Until you change the preference or clear your browser’s local storage |
12. Contact Details
Thermal Design Solutions Sàrl
13, rue du Canal, L-4050 Esch-sur-Alzette, Luxembourg
Tel.: +352 27380155
Email: info@tds.lu
Publication Director & Legal Representative: Dr. Fadil Ayad
13. Policy Changes
We may update this policy at any time. The “Last Updated” date will be changed accordingly. We invite you to consult it regularly.
Terms of Use for www.tds.lu
Last updated: September 30, 2026
1. Acceptance of Terms
By accessing or using www.tds.lu (the “Site”), you agree to these Terms of Use and our Privacy Policy. If you do not agree, please do not use the Site.
2. Use of the Site
- You must be at least 16 years old.
- You agree not to use the Site for illegal purposes.
- You will not post viruses or malicious code.
3. Intellectual Property
All content (text, images, logos, software) is protected by copyright and trademarks. Any reproduction, distribution, or modification is prohibited without our written permission.
4. User-Generated Content
Any comments or contributions you post become our property and may be used freely by TDS. You warrant that you hold the rights to them.
5. Disclaimers and Limitation of Liability
The Site is provided “as is” without warranty of any kind. TDS is not liable for indirect or consequential damages resulting from your use of the Site.
6. External Links
The Site may contain links to third-party sites. TDS is not responsible for their content or privacy policies.
7. Modification of Terms
We reserve the right to modify these Terms at any time. Changes take effect upon their publication. Your continued use constitutes your acceptance.
8. Applicable Law and Jurisdiction
These Terms are governed by Luxembourg law. Any dispute falls under the exclusive jurisdiction of the Luxembourg courts.
9. Contact
For any questions regarding these Terms, contact:
Thermal Design Solutions Sàrl
Email: info@tds.lu
Last updated: September 30, 2026