Privacy Policy

Last Updated: September 29, 2025

nosliW iT SARL-S ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services in compliance with the General Data Protection Regulation (GDPR) and Luxembourg data protection laws.

1. Data Controller

nosliW iT SARL-S
Rue de Strasbourg, 2
L-2560 Luxembourg
Luxembourg
Email: wilson.martins@nosliwit.com
Phone: +352 621 711 642
Company Registration Number: B298207

Note: nosliW iT SARL-S does not have a designated Data Protection Officer (DPO) as our data processing activities do not meet the mandatory DPO appointment criteria under Article 37 of the GDPR. For all data protection inquiries, please contact us directly using the information above.

2. Information We Collect

2.1 Personal Data You Provide

When you contact us through our website, we collect:

2.2 Automatically Collected Data

3. Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds under Article 6 of the GDPR:

4. How We Use Your Information

We use your personal data for the following purposes:

5. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy:

Data Type Retention Period Legal Basis
Contact Form Submissions (Non-Clients) 2 years from last contact Legitimate interest
Client Data Duration of service + 7 years Legal obligation (tax/accounting laws)
Marketing Consent Until consent is withdrawn Consent
Technical/Usage Logs 12 months Legitimate interest (security)

After the retention period expires, your data will be securely deleted or anonymized in accordance with our data deletion procedures.

6. Data Sharing and Disclosure

We do NOT sell, rent, or trade your personal data.

We may share your data with the following categories of recipients:

6.1 Service Providers (Data Processors)

We work with trusted third-party service providers who process data on our behalf under strict data processing agreements (DPAs):

6.2 Legal Requirements

We may disclose your data when required by Luxembourg or EU law, court orders, or governmental authorities.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred. You will be notified of any such change and your rights will be maintained.

7. International Data Transfers

Your data is primarily stored and processed within the European Economic Area (EEA). When data is transferred outside the EEA, we ensure appropriate safeguards:

US Data Transfers: For services hosted in the US (e.g., Netlify), we rely on Standard Contractual Clauses and ensure compliance with the EU-US Data Privacy Framework where applicable.

8. Your Rights Under GDPR

You have the following rights regarding your personal data under the GDPR:

How to Exercise Your Rights

Contact us at: wilson.martins@nosliwit.com or +352 621 711 642

We will respond to your request within 30 days (extendable to 60 days for complex requests with notification).

Free of charge: Exercising your rights is free unless requests are manifestly unfounded or excessive.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

Technical Measures:

Organizational Measures:

Important: No method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. We will notify you and the CNPD of any data breach within 72 hours if required by law.

10. Data Processing Activities Record

In accordance with Article 30 of the GDPR, we maintain an internal record of our data processing activities. This record includes:

This record is available to the CNPD upon request during inspections or investigations.

11. Cookies and Tracking

Our website uses cookies to enhance your browsing experience and analyze website usage.

What are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us remember your preferences and understand how you use our site.

Types of Cookies We Use:

Cookie Type Purpose Duration Consent Required
Essential Cookies Enable basic website functionality, security, and navigation Session/1 year No (strictly necessary)
Analytics Cookies Understand visitor behavior, page views, and site performance (Google Analytics 4) 2 years Yes
Preference Cookies Remember your language and region preferences 1 year No (functionality)

Managing Cookies

You can control and delete cookies through your browser settings:

Note: Disabling essential cookies may affect website functionality. You can withdraw consent for analytics cookies at any time through our cookie banner or browser settings.

Cookie Consent: When you first visit our website, you will see a cookie banner allowing you to accept or reject non-essential cookies. Your consent choices are stored for 12 months.

12. Third-Party Links

Our website may contain links to third-party websites, social media platforms, or external services. We are not responsible for the privacy practices or content of these external sites.

Recommendation: Please review the privacy policies of any third-party sites you visit. Our Privacy Policy applies only to data collected through nosliwit.com.

13. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children.

If we become aware that we have inadvertently collected data from a child under 18 without parental consent, we will take immediate steps to delete such information from our systems.

If you believe we have collected data from a child, please contact us immediately at wilson.martins@nosliwit.com.

14. Data Protection Impact Assessments (DPIA)

In accordance with Article 35 of the GDPR, we conduct Data Protection Impact Assessments (DPIAs) when our processing activities are likely to result in high risk to individuals' rights and freedoms.

Currently, our standard business operations (contact forms, customer relationship management) do not require DPIAs. However, we continuously monitor our processing activities and will conduct DPIAs if we introduce new technologies or processing methods that may pose higher risks.

15. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or technological developments.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

16. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal data:

nosliW iT SARL-S
Rue de Strasbourg, 2
L-2560 Luxembourg
Luxembourg
Email: wilson.martins@nosliwit.com
Phone: +352 621 711 642
Response Time: Within 30 days of receipt

17. Right to Lodge a Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Luxembourg supervisory authority:

Commission Nationale pour la Protection des Données (CNPD)
15, Boulevard du Jazz
L-4370 Belvaux
Luxembourg
Phone: (+352) 26 10 60 - 1
Email: info@cnpd.lu
Website: https://cnpd.public.lu

You also have the right to lodge a complaint with the supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

Version History: This Privacy Policy (Version 2.0) was last updated on September 29, 2025, to enhance GDPR compliance and provide clearer information about our data processing activities.