Privacy and Data Protection

Protecting your personal data, and complying with relevant data protection legislation, is something we take very seriously. This statement is intended to give you an overview of how we ensure this protection, what kinds of data we collect and why, and how we deal with it.

Who is responsible?

Responsibility for data processing and in connection with this website rests with SANZARU Initiatives SARL, 31b, Rue de Canach, Schuttrange L-5368, Luxembourg (together with its affiliated entities referred to as “SANZARU Group”).

Why do we collect, process and use data?

SANZARU Group uses the Internet to present general information about our company and what we do. There are some areas of our websites or individual pages which serve more specific purposes.

We collect, process and use data for the reasons above, unless there are more specific reasons, which we will give when collecting that data (e.g. for applicants). We do not use data other than for its intended purpose in each case.

What data do we collect?

Some data is collected automatically

When you visit our websites, your IP address is recorded, along with the data you requested from the website, how much data you downloaded, the server reply code on the request from your browser, what browser you used, the date you visited, and for how long.

SANZARU Group cannot attribute this data to any specific person as a general rule (unless you log in). We do not combine this data with data from any other sources.

We statistically analyze this data constantly so we can keep our websites optimized at all times.

Some information you provide

We record and process information you enter on our websites or send us otherwise. This includes data you enter in forms or contact fields, or select from lists or menus.

There are some points in our websites where you can send us information by uploading documents via those websites to our servers. That is what happens when you apply online, for example.

We also record and process personal information when you e-mail someone at SANZARU Group. This concerns the contents of your e-mails as such, but also data obtained from queries to our e-mail server, such as sender and addressee IDs, time stamp, errors or grounds for refusal if mail doesn’t get through.

Profile and login information for access-protected areas

There are some access-restricted areas of the website for which you need to register before you can use them, like the recruiting/applicant and alumni areas in particular. When registering, there are some details you have to enter that the registration form itself requires, particularly your e-mail address, a password, and some information about yourself. Any other details you enter are voluntary. We process and save this data.

In some areas of our websites, some of your registration data or contributions you make can be seen by other users once they log in. It’s up to you to decide whether you want other registered users of this site to see your information and, if so, what. You can change these settings at any time.

Newsletters and information services

There are many points on SANZARU Group’s websites where we offer newsletters or comparable information services. If you’d like to use these, we’ll need a working e-mail address for you and details to enable us to verify that this e-mail address is really yours, or that the person whose address it is agrees to receive the newsletter. That’s the only information we gather.
You can withdraw your consent to your data and e-mail address being recorded and used to send newsletters and object to the use of your personal data for marketing purposes at any time.

Other matters

We will never record any of your personal details otherwise without your express consent.

Who do we send data to?

Where does data go once it reaches SANZARU Group?

Once you send data, or it is collected on our websites, we transmit it within SANZARU Group to the recipients that need to know it. Applications, for instance, go to our human resources department and the department for which the position is advertised.
Data can also be accessed in purely technical terms by service providers and contract partners we use to operate our website. They act as our commissioned data processors.

Sending data to third parties

As a fundamental rule, we do not disclose, transfer, sell or otherwise market personal data to third parties, such as other companies or organizations, without your express consent, or as required to meet our contractual obligations between SANZARU Group and you, the website user, which make it necessary to transfer such data.

Transfer of data to countries outside the EU/EEA

We do not transfer any personal information to anyone in countries outside the EU or EEA, nor do we have any plans to do so, except in the cases below:

If you’re applying for positions advertised in countries outside the EU/EEA or which are closely connected to our offices in those countries.

If you’re registering for events organized outside the EU or EEA.

In any other cases where data evidently has to be sent to recipients in countries outside the EU/EEA.

We will generally ask you for your consent before transferring data in these cases.

How long can we store data before we have to delete it or block it?

The law is quite detailed when it comes to what data we can and must store and for how long. Once these terms expire, we routinely delete this data or block it, following data protection rules.
Where data is not subject to specific terms, we delete it or block it once the reasons we collected it for cease to apply.
If you have agreed to a longer duration for storing, processing and using your data, we will delete or block your data after this duration expires or should your revoke your consent.

What are “cookies”, and how do we use them?

SANZARU Group’s websites use “cookies” in different places. These are small text files which are downloaded onto your computer and are saved in your browser. Cookies do not harm your computer, and do not contain viruses. For instance, we use cookies to help you navigate our website.
Most browsers are initially set to accept cookies. You can disable cookies, delete cookies that have been accepted or have your browser notify you every time a cookie is set through the settings of your browser. Please note that you may not be able to use all functions of this website if you disable cookies entirely.

Session Cookies

Most cookies we use are “session cookies”. We use these to enable your use of the website and to remember your settings throughout your visit to avoid that you have to reenter your choices several times. Session cookies are deleted automatically at the end of your visit.

Web Analytics Cookies

This Website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, to help the website analyze how users use the site. As a rule, the information generated by the cookie about your use of this website will be transmitted to a Google server in the USA and stored there. On this website IP anonymization was activated, so Google will truncate the IP address of users from Member States of the European Union and the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity and providing us with other services relating to the use of the website and the internet. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google about you. You can prevent the collection of data generated by the cookie about your use of the website (including your IP address) and its processing by Google by downloading and installing the browser plug-in available under

Your right to know

Subject to the relevant legal provision, we’ll be happy to tell you what personal details we store on you, to correct your personal details or delete them unless we are obliged to keep your data for legal reasons. If there’s anything you’d like to know, please get in touch with SANZARU Group’s data protection officer. And please remember, you’ll need to prove who you are before we can give you any information.


The security of your data is important to us: so all the areas of our website where you can actively input data use encryption systems such as SSL (Secure Socket Layer) to protect your data against being accessed by unauthorized third parties.
If you register to use access-protected areas of SANZARU Group’s websites, you should keep the login details you receive carefully and protected against access by third parties. If you log in on a computer that is used by more than one person, please don’t forget to log off properly at the end of each session and close the browser window you were using.
SANZARU Group takes extensive technical and organizational security precautions to protect your personal data against being manipulated, either accidentally or deliberately, or being lost, destroyed or accessed by unauthorized third parties. We are constantly improving these precautions as technology develops.