Data protection regulation

1. Scope of application

We herewith like to inform you about the handling of your personal data when you visit our website. To provide the functions and services of our website, it is required that we collect your personal data. In the following, we explain you which of your data we collect, the purpose of the collection, and which rights you have in relation to your data. The entity responsible for the processing of personal data on this website is (cf. Company Information): Novem Group S.A. | 19, Rue Edmond Reuter | 5326 Contern, Luxemburg | phone: +352 44 30 64 | email: info(at) If you have any questions regarding how your data is processed, in particular in relation to your statutory rights, you can contact our data protection officer at any time: Dr. Georg Schröder, LL.M., Rechtsanwalt/Datenschutzbeauftragter. legal data Schröder Rechtsanwaltsgesellschaft mbH | Prannerstrasse 1 | 80333 Munich, Germany | phone: +49 89 954 597 520 | email: Georg.Schroeder(at)

2. Data processing

We draw your attention to the fact that data transmission via the internet (e.g. communication by email) can involve security risks. It is not possible to completely protect data against access by third parties. Any use of contact data released within the framework of the duty to publish the company information by third parties in order to send advertisements and information material not explicitly requested, is explicitly objected. The operators of the website expressly reserve the right to take legal action in the case of unsolicited sending of advertising such by virtue of spam messages.

3. Automatic data processing

If you use the website without transmitting any other data to us (e.g. by registration or use of the contact form), we will only collect the technically required data, which are transmitted automatically to our server (e.g. IP address, date and time of the request, browser type and operating system). This is a technical requirement to allow us showing you our website. If personal data are affected in this context, Art. 6 (1) (f) GDPR is the legal basis for the collection.

4. Cookies

We use cookies. Cookies are small files containing information and that are sent by us to the browser of your terminal device when you visit our website and stored there. If third parties process information via cookies, they collect the information directly via your browser. Cookies do not cause any damage to your end device. They cannot execute programs do not contain viruses. Some functions of our website cannot be offered without the use of technically necessary cookies. Other cookies enable us to perform analyses. For example, such cookies can recognise the browser you are using when you visit our website again and transmit various information to us. We use cookies to facilitate and improve the use of our website. Among others, cookies enable us to make our website more user-friendly and effective for you, for example by tracking your use of our website and determining your preferred settings (e.g. country and language settings). The following types of cookies are used on our website:

a. Necessary Cookies

Necessary cookies help to make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

b. Statistics Cookies

In order to further improve our offer and our website, we collect anonymous data for statistics and analysis. With the help of these cookies we can, for example, determine the number of visitors and the effect of certain pages on our website and optimise our content. You can find a complete overview of the cookies and runtimes we use here:
Statistic Cookies Matomo:
_pk_ses: lifetime 30 minutes
_pk_id: lifetime 13 month

5. Matomo

Matomo is an open source software tool for web analysis. Among other things, a web analysis tool collects data about which website you came to a website from (so-called referrer), which subpages of the website you accessed or how often and for how long you viewed a subpage. Matomo sets a cookie. The setting of a cookie enables us to analyse the use of our website. Each time one of the individual pages of this website is accessed, the internet browser is automatically prompted by the Matomo component to transmit data to our server for the purpose of online analysis. As part of this technical process, we gain knowledge of your personal data, such as your IP address, which is used, among other things, to track the origin of visitors and clicks. Personal information such as the access time, the location from which an access originated and the frequency of visits to our website are stored by means of cookies. Each time you visit our website, this personal data, including the IP address of the Internet connection you use, is transferred to our server. These personal data are stored by us and are not passed on to third parties. We use Matomo with the "Automatically Anonymize Visitor IPs" function. This anonymization function truncates your IP address by two bytes so that it is impossible to assign it to you or to the internet connection you are using. The purpose of the Matomo component is to analyse the flow of visitors to our website. Among other things, we use the data and information obtained to evaluate the use of this website. The legal basis of the data processing is your consent in accordance with Art. 6 (1) sentence 1 (a) GDPR. The stored data are deleted as soon as they are no longer needed for the purposes stated above. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do so you may not be able to use the full functionality of this website. You also have the opportunity to object to the collection of data generated by Matomo and relating to the use of this website and to prevent such collection, for example by using the "Do Not Track" program. Further information and the valid data protection regulations of Matomo can be called up under

6. Contact

We include several e-mail addresses on our website which you can use to contact us - depending on the content of your request. In the context of e-mail correspondence, we collect and store the data that you send us in your message as well as the metadata contained therein (e.g. date, time, additional recipients). Data is not passed on to third parties. The legal basis for the processing is Art. 6 (1) (f) GDPR. If your request serves the preparation of a contract conclusion, Art. 6 (1) (b) GDPR is an additional legal basis. Subject to statutory retention obligations, we use the data exclusively to process and respond to your request.

7. Newsletter

a) Type and scope of data processing

On our website you can subscribe to a free regularly e-mail newsletter. In order to be able to send you the newsletter regularly, we need your e-mail address.

In connection with the newsletter distribution, your data is forwarded to our newsletter service provider. This is Mailgun Technologies Inc, 548 Market Street Suite, 43099 San Francisco, CA 94101, USA. Any further disclosure to third parties will not take place.

An adequate level of data protection is guaranteed by the conclusion of the so-called EU Standard Contractual Clauses. Due to US security laws, there is a potential risk for personal data transferred to the USA. For example, the rights of data subjects with regard to their personal data in the USA are restricted.

For the newsletter distribution we use the so-called double-opt-in. This means that we will only send you an e-mail newsletter if you have explicitly confirmed that you consent to receive it.

We will then send you a confirmation e-mail asking you to confirm by clicking on an appropriate link that you wish to receive newsletters from us in the future. This is to ensure that only you as the owner of the specified e-mail address can subscribe to the newsletter. Your confirmation must be sent promptly after receiving the confirmation e-mail, otherwise your newsletter subscription will be automatically deleted from our database.

When you subscribe to the newsletter, we collect and store the information you enter in the input mask (e.g. last name, first name, e-mail address). A disclosure to third parties does not occur. Subscription to the newsletter is only possible with your consent.

When registering for the newsletter, we also store your IP address entered by the internet service provider (ISP) as well as the date and time of registration so that we can trace any possible misuse of your e-mail address at a later point in time. In the case of the confirmation E-mail sent out for checking purposes (double-opt in the e-mail), we also save the date and time of the click on the confirmation link and the ip address entered by the internet service provider (ISP).

We use tracking technology to create statistical evaluations of the opening and reading rate of our newsletter. We cannot see which people read our newsletter and only receive statistical evaluations (e.g. percentage of recipients who have opened our newsletter or followed a link contained therein). We use the tracking tool Mailjet from the provider Mailjet SAS, 13-13 bis, rue de l'Aubrac, 75012 Paris, France, for this purpose. Your personal data, such as your IP address or the date and time, may thereby be processed by the provider within the European Union so that it can create statistical result reports for us.

b) Purpose and legal basis

The data collected by us when registering for the newsletter will be used exclusively for promotional purposes for addressing you in advertising by means of the newsletter.

The processing of your e-mail address for sending newsletters is based on the declaration of consent voluntarily submitted by you below and revocable at any time for the future in accordance with Art. 6(1) lit. a) GDPR and § 7 para. 2 Nr. 3 UWG.

Your consent also includes statistical evaluations of the opening and reading rate of our newsletter.

In addition, the processing is based on Art. 6(1) lit. f) GDPR because of legitimate interests and requires us to document proof of the required consent.

c) Storage period

Your e-mail address will be stored as long as you have subscribed to the newsletter. After you unsubscribe from the newsletter, your e-mail address will be deleted, unless you have expressly consented to the further use of your data.

8. Your rights

You can assert the following rights against Novem in relation to your personal data:

You can withdraw your consent to the processing, storage and use of your data at any time with future effect, with the result that Novem will no longer process your data for the respective purpose. However, the legality of any processing undertaken up to the withdrawal of your consent will not be affected. If you believe that the processing of your personal data by Novem does not meet statutory requirements, you can file a complaint with the competent supervisory authorities.

[as of 01 February 2022]