Privacy notice for customers
Last updated: 11 February 2025
General Information
SUDenergie’s commitment
SUDenergie S.A. is committed to protecting your privacy and safeguarding your personal data. We aim to be fully transparent about how we collect, use and protect your personal information. We also want to inform you clearly about your privacy rights and the protection afforded to you under the law.
Scope of application
This privacy policy applies to the personal data collected by SUDenergie S.A. in the course of its regular business operations. This includes data required for the creation and management of gas and/or electricity supply contracts, the installation of gas meters, and the billing of gas and/or electricity supply services.
Changes to the policy
We may update this privacy policy by publishing a revised version. We will provide reasonable notice of any significant changes.
Data Controller
SUDenergie S.A., represented by the Managing Director
150, rue Jean-Pierre Michels, L-4243 Esch/Alzette
Phone (+352) 55 66 55 1 E-mail privacy@sudenergie.lu
Data Protection Officer (DPO)
SUDenergie's Data Protection Officer: Jean-Marc Feiereisen
150, rue Jean-Pierre Michels, L-4243 Esch/Alzette
Phone (+352) 55 66 55 258 E-mail dpo@sudenergie.lu
SUDenergie's privacy principles
SUDenergie takes privacy seriously. The following five principles form the foundation of our approach to protecting your personal data:
- We will always handle your personal data fairly and with integrity.
- You have the right to be clearly informed about how we use your personal data. We will always be transparent about the data we collect and how we use it.
- If you have concerns about how we use your personal data, we will work with you to resolve them promptly.
- We will take all reasonable measures to protect your information from misuse and to keep it secure.
- We comply with all applicable data protection regulations and cooperate fully with Luxembourg’s data protection authority, the CNPD.
SUDenergie’s privacy code of conduct
Obtaining your consent
When collecting personal data that is not required by law or contract, SUDenergie S.A. informs you that providing such data is optional. By submitting this data, you consent to its subsequent digital processing by SUDenergie S.A., in accordance with the terms outlined in this notice.
What are the purposes of data processing?
La collecte et le traitement de vos données à caractère personnel se limitent aux finalités suivantes :
- Fourniture de gaz et d'électricité selon les clauses contractuelles avec les clients.
- Identification unique des clients à l’aide du nom, prénom et identifiant sécurité sociale pour éviter des confusions et dans la communication avec les autorités.
- Justification de la facturation, et prédiction et planification des consommations.
- Établissement des factures aux clients et gestion des impayés.
- Installation des compteurs et maintien du réseau de gaz.
- Information aux clients via le Portail Clients, et collection en ligne des relevés de compteurs.
Who is affected by data processing?
The following individuals are affected:
- Gas and electricity consumers
- Potential customers
- Registered users of the Customer Portal
How do we collect your personal data?
In this privacy notice, “personal data” refers to one or more pieces of information that could identify you. This typically includes details such as your name, address, identifiers, email address and telephone number. We may collect this information from various sources, including:
- Information you provide directly to us
- Information received from another gas or electricity supplier
What types of personal data do we collect?
All personal data we collect is described in the table below.
Before reviewing the table, it’s important to understand that “personal data” refers to information about an individual that allows for direct or indirect identification.
This does not include “anonymous data” (i.e. information where the individual’s identity has been permanently removed).
However, it does include “indirect identifiers” or “pseudonyms” (i.e. information that does not identify an individual on its own, but could do so when combined with other reasonably accessible information).
| Category | Description |
|---|---|
Identification data | Name, surname, title, addresses, email address, telephone numbers |
Personal data | Type of residence, gas and electricity consumption, type of connected equipment, installed capacity |
Communication data | Preferences regarding how you receive information and invoices for gas and electricity |
Financial data | Bank account details, payment method |
Connection data | IP address, login information, browser type and version, operating system and platform of the devices used to access our customer portal “mySUDenergie” |
National identification numbers | Social security number, copy of identity card |
How do we use your personal data and how long do we retain it?
Under the GDPR, we are required to ensure that we have a legal basis for each purpose for which we use your personal data. We will only process your personal data where the GDPR permits us to do so.
More generally, we use your personal data as part of the overall management of our organisation’s operations, including:
- To process gas and/or electricity supply contracts concluded with you
- To offer services such as electronic invoicing and access to the “mySUDenergie” customer portal
- To manage billing and accounting related to your gas and/or electricity supply
- To maintain a customer database
We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by law.
To protect your data from accidental or malicious deletion, residual copies may not be immediately removed from our servers or backup systems when data is deleted from our services.
Who Do We Share Your Personal Data With?
As a general rule, we do not share your personal data outside of SUDenergie. However, in the context of printing and sending your gas/electricity invoices or maintaining our gas network, we may share your data with carefully selected and monitored subcontractors. For more details on our subcontractors, please contact us at: privacy@sudenergie.lu.
We may also share your personal data with authorities if we believe disclosure is legally required in the context of legal proceedings.
Additionally, we may share your data when you request a change of supplier or a service activation with your chosen provider.
We may also share consumption-related data with entities responsible for ensuring and monitoring the balance of all networks involved in the organisation of the natural gas/electricity market. Such data sharing will only occur if these third parties guarantee the highest level of confidentiality.
Do we transfer your personal data to other countries?
We do not transfer your personal data to servers outside the EU and we work with subcontractors who commit to keeping your data within Luxembourg. Should our policy change, any transfer will be carried out in compliance with data protection laws, and you will be informed accordingly.
How do we protect your personal data?
We take all reasonable precautions to store your personal data securely and require any third party handling or processing your data on our behalf to do the same.
If SUDenergie collaborates with other companies, they are selected through a thorough process. Each service provider is carefully evaluated for their technical and organisational capabilities in data protection. This selection process is documented, and a data processing agreement is only signed if the provider meets the identified security requirements, including European and national regulatory standards.
Access to your personal data is restricted to prevent unauthorised access, modification or misuse. It is granted only to employees and staff members who require it for professional purposes. All such individuals are contractually bound by confidentiality obligations.
Use of your data for information and marketing purposes
In addition to providing our services, we may use your personal data to communicate with you about our marketing offers and to recommend other services that may be of interest to you.
Specifically, we may use your personal data to send you:
- Information or requests related to your gas/electricity supply contract, if you have opted for electronic invoicing or the “mySUDenergie” customer portal
- The “SUDgazette” newsletter with updates and news from our company
We always request your prior consent before sending communications by email, and you have the choice to opt in or out.
If you no longer wish to receive information or newsletters from us by email, you can unsubscribe at any time by contacting: privacy@sudenergie.lu.
Specific Use of Your Data
Cookies
Cookies are small text files that may be stored on a website visitor’s computer by their web browser. They allow personalised settings and functionality on the website.
SUDenergie uses cookies to analyse website usage in an anonymous or pseudonymised form and to offer advanced features to users. The website cannot function properly without cookies. Most browsers are set to accept cookies automatically. You can generally prevent cookies from being stored on your hard drive by selecting “Do not accept cookies” in your browser settings. You can also configure your browser to ask for permission before storing cookies, and you may delete previously stored cookies at any time. Please refer to your browser’s instructions for details.
Use of Piwik Pro
Our website uses Piwik Pro, a service that analyses access to SUDenergie’s websites and helps us improve our online presence. Information collected via cookies (IP address, access time, duration of visit) is transmitted to and stored on Piwik Pro servers within the European Union. Reports on user activity are then provided to us.
You have the option to disable tracking by Piwik Pro.
What are your rights and how can you exercise them?
If you have any questions, comments or concerns about how we process your personal data, you can contact the Data Controller directly at privacy@sudenergie.lu or reach out to our Data Protection Officer.
In general, you will not be charged for accessing your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
To ensure your right to access your personal data, we may need to request specific or additional information to verify your identity. This is a security measure designed to ensure that personal data is not disclosed to anyone who is not entitled to receive it.
We aim to respond to all legitimate requests within one month.
You have the right to:
- Request access to your personal data: This allows you to receive a copy of the personal data we hold about you and to verify that we are processing it lawfully.
- Request correction or deletion of your personal data: You may correct, update or delete your personal data in our records. It is important that the personal data we hold about you is accurate and up to date.
- Object to processing: You have the right to object to the processing of your data. Your reasoned request will be carefully reviewed and implemented, provided it does not conflict with other processing purposes such as billing justification or legal obligations.
- Retrieve your data: You have the right to retrieve your data or request its transfer to another gas supplier. SUDenergie will process portability requests after verifying the requester’s identity and will transfer the data via the message exchange platforms used by all Luxembourg gas operators, in accordance with regulation ILR/G22/10 of 22 April 2022 establishing the Natural Gas Distribution Code in the Grand Duchy of Luxembourg.
Complaints
If you wish to make a complaint regarding this privacy policy or our handling of your personal data, please contact us at: privacy@sudenergie.lu.
If you believe your personal data has not been processed in accordance with the law, you may contact the CNPD (Commission nationale pour la protection des données) via www.cnpd.lu or databreach@cnpd.lu.
Please note that this document is a working translation.
In case of discrepancies or interpretation issues, the original French version shall prevail.