This Privacy Policy explains how Reiffers Sarl ("EUINCS", "we", "us") collects, processes and protects personal data when you visit www.euincs.com, sign up to our waitlist, or interact with our AI and human consultants. We process personal data in accordance with Regulation (EU) 2016/679 ("GDPR") and the Luxembourg Data Protection Act of 1 August 2018.
1. Data Controller
Reiffers Sarl, a société à responsabilité limitée (Sarl) incorporated in Luxembourg. Contact: privacy@euincs.com. Full company details are available in our Impressum.
2. Personal data we collect
- Waitlist data: email address, optional name, country, company name, referral code.
- Consultant interactions: the questions you submit to the AI Consultant and any messages you send when booking a call with our human consultant.
- Technical data: IP address, browser type, device, pages visited, timestamps, referrer.
- Cookies & local storage: strictly necessary cookies for session and security. We do not use advertising cookies.
Where you sign up via a referral link, we also process the referral code of the person who invited you in order to credit their queue position. Providing the data marked as required on our forms is necessary to join the waitlist or use the consultant; without it we cannot provide the service. Providing optional data is, as the name suggests, optional and has no negative consequence.
3. Purposes and legal bases
- Operate the waitlist and notify you at launch — Art. 6(1)(b) GDPR (pre-contractual measures).
- Provide the AI Consultant and respond to questions — Art. 6(1)(b) GDPR.
- Service improvement, security, fraud prevention — Art. 6(1)(f) GDPR (legitimate interests).
- Marketing communications about EUINCS — Art. 6(1)(a) GDPR (consent, opt-out at any time).
- Legal and tax obligations — Art. 6(1)(c) GDPR.
4. Recipients and processors
We share data only with processors acting on our instructions under Art. 28 GDPR:
- Hosting & database infrastructure (EU region).
- AI model providers used to power the AI Consultant.
- Email delivery providers for transactional and waitlist messages.
- Analytics providers configured to anonymize IP addresses.
We do not sell personal data and do not share it with third parties for their own marketing purposes. Disclosure to public authorities only takes place where required by law.
5. International transfers
Where a processor is located outside the EEA, transfers are protected by Standard Contractual Clauses (Commission Decision 2021/914) and supplementary measures where required.
6. Retention
- Waitlist data: until launch + 24 months, or until you unsubscribe.
- AI Consultant transcripts: up to 12 months for quality and safety review.
- Server logs: up to 90 days.
- Accounting records: 10 years (Luxembourg Commercial Code).
7. Your rights
Under the GDPR you have the right to access, rectify, erase, restrict, and port your data, and to object to processing based on legitimate interests. You may withdraw consent at any time. To exercise these rights contact privacy@euincs.com.
You also have the right to lodge a complaint with the Luxembourg supervisory authority, the Commission Nationale pour la Protection des Données (CNPD), cnpd.public.lu.
8. Security
We apply industry-standard technical and organizational measures including encryption in transit (TLS), encryption at rest, role-based access controls, and audited backups.
9. Cookies and similar technologies
On your first visit, a consent banner lets you accept or decline non-essential cookies. Strictly necessary cookies and local storage entries (including the record of your cookie choice) are always set, as they are required to operate the site and remember your preference. You can change your choice at any time by clearing your browser storage for this domain; the banner will then be shown again.
10. Automated decision-making and AI
The AI Consultant generates responses using third-party large language models. It is an informational tool and does not produce legal, tax, or accounting decisions that have legal or similarly significant effects on you within the meaning of Art. 22 GDPR. We do not carry out automated profiling for marketing.
11. Children
Our services are directed at professionals and are not intended for children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact privacy@euincs.com and we will delete it.
12. Data Protection Officer
We have not appointed a Data Protection Officer as we are not required to do so under Art. 37 GDPR. For all privacy matters please contact privacy@euincs.com.
13. Changes
We may update this policy from time to time. Material changes will be announced on this page and, where appropriate, by email.