This Privacy Statement explains how KLEYR GRASSO may use, process and store your personal data.


1. How we acquire your data

KLEYR GRASSO obtains your personal data in different ways


  • Personal data provided to KLEYR GRASSO directly.
    We collect personal data directly from clients, prospective clients, business partners, beneficial owners, service providers, contracting parties, potential candidates and intermediaries within the framework of our activities, which include legal assistance, advice and other services.
  • Personal data obtained from third parties
    KLEYR GRASSO also collects and processes personal data from publicly accessible sources such as internet, social networks or commercial registers. Furthermore KLEYR GRASSO may receive personal data from third parties as part of the services KLEYR GRASSO provides to you or in connection with legal requirements that are applicable to KLEYR GRASSO


2. Why and how we process your personal data

The present section refers to data processing executed by KLEYR GRASSO as a data controller, e.g. where KLEYR GRASSO defines the purpose of the processing and is not acting in the name and for the account of another data controller.


KLEYR GRASSO processes personal data for the purposes of providing legal services and to comply with legal and regulatory obligations. KLEYR GRASSO furthermore processes personal data for marketing purposes, to improve its website, and for social media activities.


When KLEYR GRASSO processes personal data for its legitimate business interests, it will consider and balance any potential impact on the data subject and its rights under the relevant data protection laws. Whenever KLEYR GRASSO processes personal data for these purposes the data subject has the right to object to this way of processing.


In this context, KLEYR GRASSO operates a camera surveillance of its premises located in L-2361 Strassen, 7, rue des Primeurs, whereby the cameras are located on the outside of the building and may record movements of third parties when they enter or leave the building, or next to the immediate surroundings of the building. The processing of the collected personal data is justified due to the legitimate interest to protect the company’s property and to ensure the security of the individuals within the building. Surveillance cameras are flagged with pictograms. KLEYR GRASSO will process such data exclusively for the previously mentioned purpose and by complying with the applicable legislation. The data is stored on a hard disc and automatically erased after 8 days. The access to the server is limited to the company’s IT personnel (which is bound by a confidentiality obligation) and partners. Except if necessary to safeguard its legitimate interests, KLEYR GRASSO will not disclose the collected data to third parties. In case of criminal wrongdoing, the data may however be transferred to the authorities. The server is protected against physical and IT intrusion, deterioration or modification, distortion or destruction.


If the processing is solely based on consent, the data subject has the right to withdraw its consent. In this case KLEYR GRASSO will cease any processing (except if legal obligations applying to KLEYR GRASSO require a limited processing such as the storage of the data). The withdrawal of consent will not impact any processing executed in the past.


The following list, which is not exhaustive, provides an overview of the personal data that KLEYR GRASSO processes:

  • name (including initials), address, email address, telephone number, mobile number and other contact information;
  • date and place of birth;
  • nationality;
  • gender;
  • employment details (position or profession, company or organization);
  • interest areas;
  • marital status;
  • copies of identity documents (passport, national ID card, driver’s license, social security identification numbers);
  • source of wealth;
  • utility bill, bank statement.


KLEYR GRASSO may also collect and process other personal data when it is useful or necessary for the provision of its legal services.


When executing mandates conferred by clients, KLEYR GRASSO may act as a data processor with respect to data received from the client. In such cases, the processing to be executed by KLEYR GRASSO will be regulated by the Terms & Conditions of KLEYR GRASSO which take into account the requirements listed under article 28 of the GDPR.


3. Retention period

KLEYR GRASSO will process and store the relevant personal data for the duration of its legal services or for the duration of the business relationship. KLEYR GRASSO may also store the data for as long as it is necessary or required in order to fulfil legal, contractual or statutory obligations, or for the establishment, exercise or defense of legal claims, and in general where it has a legitimate interest to do so. With regard to the time limitations provided for by article 2276 of the Luxembourg Civil Code, KLEYR GRASSO may retain, but has no obligation to do so, the relevant personal data for a period of five (5) years after the termination of the services or the business relationship.


4. Your rights

You have the following rights:

(i) Access to your information: you have the right to access the personal information that KLEYR GRASSO holds about you at any time.

(ii) Data portability: you may ask KLEYR GRASSO to provide you with a copy of the personal information that KLEYR GRASSO holds about you.

(iii) Correction of your personal information: you have the right to ask KLEYR GRASSO to update and correct any out-of-date or incorrect personal information that we would hold about you.

(iv) Deletion of your personal information (the right to be forgotten): subject to article 2276 of the Luxembourg Civil Code, you have the right to ask KLEYR GRASSO to delete your personal information, to the extent that KLEYR GRASSO has no legal and/or regulatory obligations to keep such personal information.

(v) Restriction of processing of your personal information: you have the right to ask KLEYR GRASSO to restrict the processing of your personal information in case:

  • You disputed the accuracy of the personal information held by KLEYR GRASSO;
  • The processing is unlawful but you objected to the deletion of the personal data and request the restriction of the use instead;
  • KLEYR GRASSO no longer needs the personal data for the purposes of the processing, but you require them for legal reasons;
  • You objected to processing and KLEYR GRASSO is investigating whether there are legitimate grounds to override your objection.

(vi) Automatic decision making: KLEYR GRASSO generally does not make decisions by purely automatic means, but if we do, you have the right to object.

(vii) Object
You have the right to object at any time to the processing of your personal data for any direct marketing (and related profiling) by KLEYR GRASSO. At the end of each digital mailing that you receive from KLEYR GRASSO, you can always change your mailing preferences via the ‘unsubscribe’ or ‘subscribe’ link. In short, you can always withdraw your consent.

If you wish to exercise any of the above rights, you can contact KLEYR GRASSO using the below contact details.

In addition you have the right to make a complaint with the local supervisory authority with respect to the way KLEYR GRASSO is processing your personal data or the way KLEYR GRASSO is handling your rights.


5. Your personal data and third parties

KLEYR GRASSO may disclose or transfer personal data collected by KLEYR GRASSO to other companies or subcontractors, located within or outside of the European Economic Area, for the purpose of the proper performance of the legal services KLEYR GRASSO provides to its clients. KLEYR GRASSO may, for example, disclose or transfer such personal data to bailiffs and notaries, but also to third party service providers who provide administrative, computer, payment, data processing, debt collecting, translations or other services. KLEYR GRASSO enters into data processing agreements with such subcontractors to ensure that they process your data, on our behalf, with the same level of security and confidentiality as applied by KLEYR GRASSO. KLEYR GRASSO may furthermore disclose or transfer personal data when we have received your consent to do so.

In addition, KLEYR GRASSO may disclose or transfer personal data for compliance purposes and/or to protect its rights or those of its clients and/or to prevent fraud. KLEYR GRASSO can also be obliged to disclose or transfer personal data to competent authorities in order to comply with its legal and/or regulatory obligations.

Except as described in this paragraph, KLEYR GRASSO will not disclose, transfer or sell your personal data to any third party unless you have consented to this.


6. Protection of your personal data

KLEYR GRASSO has taken appropriate technical and organisational measures to protect your personal data against loss or any form of unlawful processing.


7. Website

KLEYR GRASSO is the controller of the data collected through its website (the “Website”).

Visitors are not required to disclose their personal data as a condition of using the Website. However, when visitors register, request publications or other information, sign up for newsletters and/or conferences and events, apply for jobs, KLEYR GRASSO collects personally-identifiable information. The personally-identifiable information collected may consist of information that you provide, such as names, mailing addresses, e-mail addresses, telephone and fax numbers, and, for recruiting purposes, any other personally-identifiable information on your resume.

KLEYR GRASSO stores technical data about every visit to the Website in the logfiles of the web-server. This data may include the IP-address, the name of the internet service provider, the operating system and the type of browser used by the visitors, date and time of the visit, the name(s) of the visited page(s), the amount of transferred data. KLEYR GRASSO analyses the data for statistical purposes and to administer and improve the Website. In no case KLEYR GRASSO will generate individual visitor profiles from the collected data, so that the anonymity of each individual visitor is maintained. The data will not be transmitted to third parties.


8. Changes to this Privacy Statement

KLEYR GRASSO reserves the right and is entitled to change this Privacy Statement at any time and for any reason whatsoever. We advise you to periodically review this Privacy Statement available on the website to be informed about how KLEYR GRASSO is protecting your privacy.


9. Contact

If you have any questions, comments, concerns or complaints in relation to this Privacy Statement, KLEYR GRASSO’s processing of your personal data or if you wish to exercise any of your rights, please contact our Data Protection Officer via the following email: