Privacy Policy

Vanguard Luxembourg, a Luxembourg private limited liability company (simplified form) (S.à r.l.-S), trading under the commercial name « WISH & WASH » for its housekeeping and cleaning activities, registered with the Luxembourg Trade and Companies Register under number RCS B309342, with its registered office at 28, route de Capellen, L-8279 Holzem, Grand Duchy of Luxembourg (hereinafter the « Company » or « we »).

The Company attaches particular importance to protecting the privacy and personal data of the individuals with whom it interacts in the course of its activities (the « Data Subjects »).

This privacy policy (the « Policy ») is intended to inform Data Subjects, in accordance with Regulation (EU) 2016/679 of 27 April 2016 (the « GDPR ») and the Luxembourg law of 1 August 2018 on the protection of personal data, of the manner in which their personal data (the « Data ») is collected, processed and protected by the Company.

1.1. The controller for the processing of Data is the Company, whose contact details appear at the head of this document.

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1.2. For any question relating to this Policy, or to exercise their rights, the Data Subject may contact the Company at the following email address: info@wish-wash.lu.

2.1. Depending on the nature of its relationship with the Data Subject, the Company collects the following categories of Data:

– identification data: surname, first name, postal address, email address, telephone number;

– data relating to the order and performance of the Services: intervention address, dates and times of services, specific instructions;

– billing and payment data: bank or payment card details, payment history;

– connection and browsing data, where the Data Subject uses the Company's website or digital tools (IP address, cookie data);

– any other data voluntarily provided by the Data Subject, in particular in the course of an exchange with customer service.

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2.2. This Data is collected directly from the Data Subject, in particular when an order for Services is placed, a client account is created, or an exchange takes place with the Company.

3.1. The Data is processed by the Company for the following purposes:

(i) managing the business relationship and performing Service contracts, on the basis of the performance of a contract (Article 6(1)(b) GDPR);

(ii) managing billing and accounting, on the basis of the Company's compliance with its legal obligations (Article 6(1)(c) GDPR);

(iii) commercial prospecting and sending communications relating to the Services, on the basis of the Data Subject's consent or the Company's legitimate interest (Article 6(1)(a) or (f) GDPR), subject to the right to object set out in clause 8 of this Policy;

(iv) improving the quality of the Services and handling complaints, on the basis of the Company's legitimate interest (Article 6(1)(f) GDPR);

(v) complying with the legal and regulatory obligations to which the Company is subject, in particular accounting and tax obligations (Article 6(1)(c) GDPR).

4.1. The Data is intended for the Company's internal departments authorised to process it by virtue of their functions.

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4.2. The Data may also be disclosed, within the limits of their respective duties, to the Company's processors and service providers (in particular payment providers, management and billing tools, and data hosting providers), which are bound by contractual confidentiality and security obligations compliant with the GDPR.

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4.3. The Data may finally be disclosed to the competent administrative or judicial authorities, where such disclosure is required by law.

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4.4. The Company does not sell or rent the Data to third parties for commercial purposes.

5.1. The Data is retained for the period necessary to achieve the purposes for which it was collected, extended, where applicable, by the applicable statutory limitation periods.

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5.2. As an indication, data relating to the contractual relationship is retained for the duration of the business relationship, extended by ten (10) years from the end thereof for accounting and tax purposes, in accordance with Luxembourg law. Data collected for commercial prospecting purposes is retained for three (3) years from the last contact initiated by the Data Subject.

6.1. The Data is, in principle, processed and stored within the European Union or the European Economic Area.

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6.2. Should a transfer of Data to a third country prove necessary, in particular due to the use of a service provider established outside the European Union, the Company ensures that such transfer is governed by appropriate safeguards within the meaning of Articles 44 et seq. of the GDPR, such as the standard contractual clauses adopted by the European Commission.

7.1. The Company implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in particular to protect the Data against loss, destruction, alteration, disclosure or unauthorised access.

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7.2. In the event of a Data breach likely to result in a high risk to the rights and freedoms of Data Subjects, the Company notifies the breach to the National Commission for Data Protection (CNPD) and, where applicable, to the Data Subjects concerned, in accordance with Articles 33 and 34 of the GDPR.

7.1. The Company implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in particular to protect the Data against loss, destruction, alteration, disclosure or unauthorised access.

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7.2. In the event of a Data breach likely to result in a high risk to the rights and freedoms of Data Subjects, the Company notifies the breach to the National Commission for Data Protection (CNPD) and, where applicable, to the Data Subjects concerned, in accordance with Articles 33 and 34 of the GDPR.

8.1. In accordance with Articles 15 to 22 of the GDPR, every Data Subject has the following rights with respect to their Data:

– right of access;

– right to rectification;

– right to erasure, in the cases provided for by the applicable regulations;

– right to restriction of processing;

– right to data portability;

– right to object to processing, in particular for commercial prospecting purposes;

– right to withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing based on consent given before its withdrawal;

– right to set guidelines for the fate of their Data after death.

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8.2. These rights may be exercised with the Company at the following email address: info@wish-wash.lu, accompanied by proof of identity.

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8.3. The Company undertakes to respond to any request within one (1) month of receipt, a period which may be extended by a further two (2) months in the case of a complex request.

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8.4. Every Data Subject also has the right to lodge a complaint with the National Commission for Data Protection (CNPD), 15, boulevard du Jazz, L-4370 Belvaux, Grand Duchy of Luxembourg (www.cnpd.public.lu).

9.1. When the Data Subject visits the Company's website, cookies or similar tracking technologies may be placed on their device, subject to their consent where required, in particular to ensure the proper functioning of the website, to compile visitor statistics, or to offer tailored content.

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9.2. The Data Subject may at any time configure their browser to refuse or delete cookies, it being specified that certain website features may be affected as a result.

10.1. The Company's Services are not directed at minors. The Company does not knowingly collect Data relating to minors without the consent of their legal representatives.

11.1. The Company reserves the right to amend this Policy at any time, in particular to comply with any legislative, regulatory, case-law or technical developments.

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11.2. The applicable version is the one published on the Company's website or communicated to the Data Subject on the date of the relevant processing.

12.1. This Policy is governed by Luxembourg law.

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12.2. Any question or complaint relating to this Policy may be addressed to the Company at the following email address: info@wish-wash.lu, or lodged with the National Commission for Data Protection (CNPD).