Privacy Notice

by Unicoeding Sarl

November 2, 2025

This document is written as simply as possible so hopefully most people can understand it. If you have any questions about the content you are about to read, please do not hesitate to contact us. Also, if you wish to exercise any of your data protection rights, do not hesitate to contact us.

We, Unicoeding SARL, are the data controller in terms of personal data that you either give to us or we receive via third parties (such as for example in the case of employees the social security authority). Our contact details: Unicoeding SARL 18A/D Rue de la Cimenterie, L-1337 Luxembourg Hello ( at ) unicoeding.com

We currently do not have a DPO (yes, the shoemaker’s children go barefoot). This does not mean we would not take our responsibilities seriously or do our best to succeed. Your request will be managed confidentially and answered by a senior member of the personnel. You may reach us via the mentioned contact information with your questions regarding processing we may do with your personal data. Reaching us by email is more effective than physical post (which can be sometimes notoriously slow).

What do we process, what is our justification for processing it and why?

For employment:

• Identity information (eg ID card or other identification), to be able to identify you and fulfill the employment contract with the correct person
• Your contact details (address), to be able to send you your salary slips and other employment related documentation as required by law
• Bank account information, to be able to pay you for your employment and to fulfill the employment contract with you
• Tax authority provided tax files (including for example tax class, payment and calculation details and social security number), to be able to fulfill our legal obligations towards the local government and to fulfill our contract with you
• Your CV and application to be able to create and fulfill our contract with you
• Visa/Work permit information to be able to fulfill our legal obligations with the local government
• We need to process some social and health data to fulfill our legal obligations as required by local legislation § CNS/CCSS/CNAP required documentation for illness, or workplace health obligations and social security (CNS is the local health insurer, CCSS the social security institution and CNAP the pension fund) § Any adjustments we legally have to provide in case of disability or illness (We will provide adjustments based on preference as well, as much as we legally can)
• Data created during employment such as emails etc is discussed further in our internal policy. Note that we do not read our employee’s emails etc. unless there is a lawfully defined need, such as court order or a police notice to do so, and even then you will be notified unless explicitly forbidden by the authorities. However, we recommend separating work and personal accounts and devices as much as possible, also to protect your own well-being during your time off. Any on-call is organized contractually to follow local law and to for example protect you from any adverse tax implications (especially concerning cross-border workers).

For freelancers:

• Identity information, to be able to identify and fulfill the freelancing contract with the correct person
• Depending on the format of your enterprise, we may need to process your personal banking data to be able to fulfill the contract with you
• Details of your mission to be able to fulfill the contract with you
• Data created during your mission will be managed similarly as that of employees. However we can agree to a contractual storage period and other specifics, as long as they respect the requirements of Luxembourgish law.

Who do we share your data with and why:

• Identity, bank and tax information: Our accounting and payroll service located in Luxembourg to be able to pay you your salary and to maintain employment records as required by law. This service provider is a data processor, and governed by a service agreement defining also personal data processing. The details of the processor are provided to those who either work with us or for us. If you do not work with or for us, we do not process this data about you.
• Our banking service provider to be able to pay you. The details are provided to those who either work with us or for us. If you do not work with or for us, we do not process this data about you.
• Visa or work permit information, with the police or other local authorities (Ministry of work and immigration agency) to fulfill our legal obligations. If you do not work with or for us, we do not process this data about you.
• Health data: CNS, CCSS and CNAP required information will be sent to them to fulfill our legal obligations. If you do not work with or for us, we do not process this data about you.

For our customers:

• Your contact information and details about your request, to be able to fulfill our contract with you or to answer your questions

On the website:

• We do not collect or store cookies
• We automatically anonymize user agents and IPs on country level

On social media:

• Please note that we do not actively use social media
• Please remember to check the privacy notice of any social media you use, so you can be informed of how they process your personal data

If you contact us via email or other means for any reason:

• The content and contact details of your message to be able to process any request you may have sent us (legitimate interest)

Shamefully, we do not really do any marketing. We have a blog on our website, and some old posts on social media. We don’t collect any data on the blog. Please remember if you reach out to us on social media, to check the relevant information about that service. Each service will have their own approach to how they process your data.

How do we store your data?

We work with a European cloud provider, called Infomaniak that is located in Switzerland. (You can find more information about them here: https://www.infomaniak.com/en), both for storage, hosting and our productivity tools. Some documents that have to be stored physically (copies of contracts for example), are stored in a locked storage, and a physical key required. Any data is only accessible to those who are permitted to see and process it for their work tasks. We require use of MFA, and following of local laws in our work as well as tasks and responsibilities listed in our contracts. Confidentiality is a requirement in our employment contracts and service contracts.

Employment related data is stored as required by local law for 10 years, except for data created during employment. Your inbox and personal folders will be deleted within three months of your departure, unless you request otherwise. CVs are deleted after 2 years if your application does not lead to a contract with us. Freelance, payment and tax related data is stored as required by local tax law for 10 years.

We do not use cookies on our website. Technical data is purged automatically on a continuous basis. Contractual data (customers) is stored as required by local tax law for 10 years.

What can you do?

Remember that you have rights to your personal data, and you should not be afraid to use them. Details about your rights can be found at: https://cnpd.public.lu/en/professionnels/obligations/Respect-droits.html

If you feel like we did not answer to your requests in a way that respects your rights, you can contact the CNPD (the Luxembourgish data protection authority, “National Commission for Data Protection”): National Commission for Data Protection 15, Boulevard du Jazz L-4370 Belvaux Tél. : (+352) 26 10 60 -1

Thanks for getting this far, I am curious if anyone reads this, so here is a duck 🦆 as a present for those who got this far.