Spuerkeess's personal data protection policy applies to all the automated or non-automated processing of personal data carried out by Spuerkeess and sets out the principles and guidelines pertaining to its obligations as a "Data Controller" (person who determines the purposes and means of processing personal data) arising from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, which entered into force on 25 May 2018 (hereinafter the "Regulation"). 

Spuerkeess processes the personal data of natural persons and legal entities with which it has, had or may have a direct or indirect relationship, namely: 

• existing or potential customers who express an interest in Spuerkeess's services and products, 
• assignees, attorneys and any natural persons acting as representatives of Spuerkeess customers,
• guarantors,
• external service providers and subcontractors, and their employees, representatives and contact people,
• visitors,
• users of Spuerkeess's websites and mobile applications,
• legal representatives, officers and authorised persons of Spuerkeess's corporate customers,
• beneficial owners and shareholders of Spuerkeess's corporate customers,
• principals and/or beneficiaries of transactions carried out by Spuerkeess customers,
• job applicants as part of the recruitment process,
• persons involved in transactions or contracts with Spuerkeess or its customers,
• any other natural persons who contact Spuerkeess. 

The personal data collected is restricted to the data required for the purposes identified by Spuerkeess. 

Different categories of personal data are collected: 

• personal identification data (e.g. surname, first name, gender, date and place of birth, identity card/passport number, nationality, place of residence, tax domicile, social security number, identity photo, vehicle registration number, identity of legal representatives, offices held, etc.); 
• private or business contact data: postal address, email address, telephone number; 
• family situation (e.g. family composition, marital status, inheritance status, marital property regime, number and age of children); 
• employment-related data (e.g. name of employer, position held, employment status, career history and qualifications, place of work, employment contract); 
• banking, financial and tax identification data (e.g. customer number, bank account number, portfolio number, credit card number, tax identification number, tax status and data relating to the products and services that you have subscribed for); 
• data on financial transactions (e.g. transfers, direct debits, transactions in transferable securities and financial instruments, amounts, currencies, exchange rates, payment descriptions, beneficiaries including their names and addresses); 
• asset situation (e.g. income, expenses, loans, assets, taxes, investments, inheritances);
• data, ratios and ratings relating to the investor or borrower profile and other data necessary for sound risk management by Spuerkeess in accordance with the law (e.g. loan repayment capacity, creditworthiness, photos needed to assess real estate collateral for mortgage loans, knowledge and experience of investing); 
• connection and digital usage data: IP address, login details and country of connection, technical characteristics relating to the device (computer, mobile phone, tablet, etc.) and operating system used (type, language, resolution, technical version), browser type, access logs and activity logs; 
• habits and preferences:
  • data linked to the use of our products and services (banking, financial and transactional data, payment habits and behaviour, marketing preferences, communication preferences, credit history, needs and interests); 
  • data collected in the course of our exchanges in our branches, on our websites, via our mobile apps, via our social media accounts, in meetings, during telephone calls, during chats, in emails and during interviews, or collected in user experience (UX) optimisation panels; 
  • geographical location data (e.g. automated teller machines used and branches visited); 
  • data on your behaviour and preferences when browsing our websites. Additional information is available in our cookie policy which is available at www.spuerkeess.lu; 
• data relating to your use of the S-Net banking application: 
  • data specific to the mobile device (e.g. technical identifiers, connection data); 
  • financial data (e.g. consultation of account balances and movements, payment data when you carry out financial transactions online); 
  • data relating to payment accounts held with other banks accessed via S-Net under the revised EU Payment Services Directive ("PSD2"); 
  • data relating to your purchases of banking products and services via S-Net; 
  • contact details, images, and messages, including any digitalised documents exchanged with us via S-Net; 
  • data relating to simulations (e.g. loans, Speedinvest); 
  • data relating to the MIA tool, a Personal Finance Manager-type tool for day-to-day financial management; 
  • data relating to the use of the Payconiq service integrated in S-Net (e.g. scans of QR codes via your camera, list of contacts in your mobile device). S-Net requests your authorisation to access your list of contacts and shares with Payconiq the phone number of the contact you select in order to carry out a payment); 
  • behavioural and technical data enabling us to detect unusual use of our services; 
  • geolocation when searching for the nearest ATM or Spuerkeess branch. 
• authentication data (e.g. handwritten and electronic signature, the biometric data characterising the signature on a signing pad); 
• video and video surveillance (CCTV) recordings made inside and outside our buildings and facilities; 
• recordings of certain telephone conversations; 
• recordings of face-to-face meetings, chat sessions and video conversations; 
• any paper or electronic correspondence; 
• the data you have asked us to collect for you (e.g. data on bank accounts and assets held with other banks shared under PSD2); 
• the information that Spuerkeess needs to comply with its legal and regulatory obligations (e.g. information processed for the detection of any suspicious or fraudulent activity and data required in connection with anti-money laundering and counter-terrorist financing controls); 
• data used to assess a job applicant's aptitude for a position (e.g. diplomas, professional experience and education).  

This data is collected at the following times: 

• when entering into and during the business relationship (e.g. contact with our advisers, customer data updates, use of our banking products and services, participation in competitions, surveys or user experience (UX) optimisation panels, etc.); 
• on receipt of a payment from a third party using our services, who provides us with information for the proper execution of the transfer; 
• when using our applications (e.g. S-Net, S-Net mobile) or browse our websites; 
• when subscribing for a service or publication produced by Spuerkeess in any form whatsoever (e.g. newsletters); 
• when replying to invitations to events organised by Spuerkeess; 
• when being filmed by our CCTV cameras during a visit to our branches or offices and when using an automated teller machine; 
• when adding payment accounts held with other banks to S-Net (in accordance with PSD2); 
• when submitting a job application to Spuerkeess;
• in connection with our use of publicly available sources of information (e.g. data made public in the media, press, search engines, official publications and/or when you publish information on Spuerkeess's social media; 
• when we consult third parties in accordance with applicable laws (e.g. public authorities or institutions, establishments operating professional databases, other financial institutions, national registers of natural persons, cadastral registers, commercial registers, registers of associations, fraud prevention bodies, research providers, partners, subcontractors).   

The personal data you disclose to us about third parties (family members, employers, agents, representatives, beneficial owners, etc.) is processed in the same way as your personal data, in line with the corresponding purposes and services. It is your responsibility to inform the data subjects and invite them to read this data protection policy.  

If you choose to spontaneously provide us with unsolicited personal data, you authorise Spuerkeess to process it if necessary for the management of your request and in accordance with the legislation in force.  

To fulfil Spuerkeess's obligations, and to the extent necessary, Spuerkeess may process "special categories of data", such as data on health, convictions and offences and on the holding of a public office.  

Spuerkeess collects and processes personal data for specific purposes. It ensures in all cases that personal data is only processed where necessary in relation to the purpose pursued. All processing of personal data carried out by Spuerkeess is based on at least one of the following conditions for lawful data processing: 

• legal and regulatory obligations, e.g. processing for the purposes below: 
  • the fight against money laundering and the financing of terrorism, including the keeping of Know-Your-Customer (KYC) files, which is outsourced to i-Hub SA (Luxembourg); 
  • regulatory reporting and automatic exchange of information (e.g. under the Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard (CRS), Central Electronic System of Payment Information (CESOP), Central Electronic Data Retrieval System (CEDRS), the Directive on Administrative Cooperation (DAC), etc.);  
  • compliance with the requests and requirements of local or foreign authorities; 
  • laws on international sanctions and embargoes; 
  • the detection of abnormal, unusual or erroneous transactions and the fight against payment fraud and market abuse; 
  • strong authentication of the customer for payment services; 
  • verification that the payee name entered by the ordering party for a credit transfer matches the name of the holder of the IBAN account registered with the payee bank; 
  • determining your credit risk score and repayment capacity; 
  • the recording of communications (letters, telephone calls, etc.) relating to customer orders in accordance with the regulations on markets in financial instruments; 
  • establishing your investor profile;
  • account-keeping.
• the performance of a contract, including pre-contractual measures, e.g. processing for the purposes below: 
  • the provision of services and products; 
  • the execution and recording of your financial transactions and cash withdrawals; 
  • the granting and management of loans; 
  • the management of S-Net and S-Net mobile. 
• Spuerkeess's legitimate interests, e.g. processing for the purposes below: 
  • the provision of services and products; 
  • the management of business relationships with customers, prospective customers, suppliers, subcontractors, partners and other third parties; 
  • the detection and prevention of fraud and abusive transactions; 
  • the protection of your assets against fraudulent activities; 
  • analysis of the use of your account and your use of our services; 
  • conducting competitions, satisfaction and other surveys;  
  • the production of internal statistical studies and models with the aim of optimising risk management and improving our product and service offering through commercial actions such as direct marketing, advertising and the management of events for customers; 
  • improving our websites and mobile apps;  
  • the management of our operational needs and risk management; 
  • the application of security measures for property and persons; 
  • ensuring service continuity and IT security;  
  • the management of any disputes or legal claims and the protection of our rights; 
  • debt collection; 
  • recruitment management; 
  • providing offers and promoting products and services that correspond to your situation or profile: If you are a customer and without any objection from you, Spuerkeess uses your personal data to offer you products and services that best meet your needs. To do this, Spuerkeess analyses your personal data to improve the range of products and services, including the data you have directly provided to us, internal ratings, client segmentations, regulatory classifications as well as data from your use of our products and services such as, for example, account balances and movements and automatically categorised transactions. You have the right to object, without justification, to the categorisation of your transactions and the sending of commercial offers (see chapter "Right to object to certain types of processing (Opt-Out)").   
• consent, e.g. when:
  • collecting the biometric data which characterises your signature on a signing pad; 
  • adding your payment accounts held with other banks to S-Net (in accordance with PSD2). Unless you object, the accounts imported are also subject to the data processing generally applied to your Spuerkeess accounts, including the categorisation of your transactions (see chapter "Right to object to certain types of processing (Opt-Out)" below); 
  • participation in customer panels organised by Spuerkeess; 
  • any other specific processing to which the data subject has consented. 

This processing takes account of your interests and fundamental rights. 

In some cases, you may have expressed a wish not to have your personal data used but Spuerkeess may nevertheless be obliged to process it and/or retain it for various reasons. In such circumstances, Spuerkeess will continue to process and/or retain the personal data if (i) it is obliged to do so by a law or regulation, (ii) required to do so under an agreement or (iii) Spuerkeess has a legitimate interest in doing so.  

As a general rule, Spuerkeess does not use decision-making processes based solely on automated processing within the meaning of article 22 of the Regulation. In the event that Spuerkeess occasionally uses such a process, you will be informed in advance and will have the right to ensure that a human is involved in the decision-making.  

Spuerkeess may use automated processing so that it can quickly offer you services and products suited to your needs. For example, in the case of an online loan application or an application to amend your credit card limit via S-Net, the system can only approve the application automatically (if pre-defined criteria are met), but any application that cannot be approved in such a way (automatically) will be processed manually if the applicant so wishes. 

Spuerkeess may use profiling, i.e. any form of automated processing of personal data that involves using this data to assess certain personal aspects relating to a physical person, including to search for or identify relatively homogeneous categories of persons, in terms of products held and/or banking behaviour, who may be interested in a new product or personalised commercial offering. 

In this context, your personal data may be subject to profiling, including in the following circumstances: 

• MiFID II has introduced improved investor protections; your investor profile is determined on the basis of a questionnaire that aims to assess your knowledge of financial instruments and market experience, on the basis of which Spuerkeess may offer you investments suited to your profile;
• if you subscribe for the Speedinvest product, your investor profile is determined on the basis of a questionnaire that aims to measure your knowledge of financial instruments and market experience. Investments are then made automatically based on the profile determined;
• when categorising your transactions, calculating your available balances and sending you the commercial recommendations and proposals that are most likely to meet your needs. Such processing makes it possible, for instance, to use the MIA tool, a Personal Finance Manager-type tool designed to help you with the day-to-day management of your finances. MIA analyses income and expenses and puts them into different categories;
• when promoting banking products and services which complement the products and services for which you have already subscribed and as part of marketing actions (newsletters, commercial and informational mailings, invitations to events, participation in competitions, etc.);
• in order to comply with its anti-fraud, anti-money laundering and counter-terrorist financing obligations;
• when assessing your creditworthiness and banking behaviour. This scoring system allows Spuerkeess to determine, for example, the likelihood that a customer will meet his/her loan repayment obligations. The scoring system is based on a defined and proven mathematical and statistical model. It is affected by the customer's income, expenses, current commitments, profession, employer and loan repayment history, an assessment of the business relationship and information in the public domain. It helps us to make decisions with a view to selling services (e.g. personal loan applications or changes to credit card limits) and to manage risks. With regard to joint online loans, the co-borrower's expenses/income are also taken into account for the creditworthiness assessment and scoring. 

You have the right to opt out of some of the processing described above, without having to give a reason: 

"Banking services" category: 

• Opt-out regarding the categorisation of transactions. Please note, however, that proceeding with this opt-out will prevent you from using certain services, including MIA and online loan applications. This Opt-Out also applies to the categorisation of transactions in any payment accounts you have chosen to import from other banks into S-Net, pursuant to PSD2. Marketing communications are not affected by this Opt-Out. 

"Commercial communication" category: 

S-Net, postal mail and telephone communications: 

• Opt-Out regarding the sending of mailings, newsletters, invitations to events and prize draws by S-Net and by postal mail, as well as telephone contact to ensure optimal follow-up of the business relationship by offering you the services and products best suited to your needs and situation. In this context, your socio-demographic, transactional and behavioural data, data relating to the products subscribed and your interactions with Spuerkeess may be used. Communications by email are not covered by this Opt-Out. 

Email communications: 

• Opt-Out regarding the use of your email address to keep you informed of Spuerkeess news (special offers, invitations to events, news and useful information). Notwithstanding this objection, Spuerkeess may continue to use your email address in a strictly non-marketing context to provide you with essential information (e.g. security notices, alerts regarding the services you have subscribed to, contractual, administrative and legal information). Communications via S-Net, postal mail and telephone are not covered by this Opt-Out. 

This right to object may be exercised at a branch or by sending an S-Net message, e-mail or letter to the following address: 

To the extent that certain personal data processing requires your consent, such processing will not take place until your explicit consent has been obtained. Any consent you give may be withdrawn at any time, on the same terms as those specified for opt-outs.  

For example, your consent is required in the event that: 

• biometric data is collected, such as when you sign on a signing pad in a bank branch;
• you participate in customer panels organised by the Bank.

In accordance with PSD2, your consent will be requested before you import payment accounts held with other banks into S-Net.  

The lawfulness of processing based on consent granted prior to its withdrawal will not be affected.  

Within the limits of its activity and in compliance with applicable laws and regulations, Spuerkeess may transfer personal data to third parties, including: 

• the financial institutions and financial professionals with which we cooperate on domestic and international payment transactions, credit transactions and transactions in financial instruments, such as specialised banks and financial companies, brokers, payment and credit card issuers and intermediaries, providers of online or in-store payment solutions, clearing houses, stock exchanges, subcustodians, distributors, paying agents, investment product managers, trading and transaction platforms, market counterparties and issuers of the financial instruments that you hold through Spuerkeess, etc.; 
• subcontractors, suppliers, counterparties and service providers used by Spuerkeess to optimally provide you with the services that you have subscribed for, such as specialised financial sector providers, insurance companies (in particular when you subscribe for insurance policies via Spuerkeess or in the event that insurance companies are called upon to take into consideration the implementation of an insurance service related to a Spuerkeess offer, banking product or contract), tax reporting providers, as well as suppliers who help us with the design and maintenance of our IT solutions, the organisation of events, the management of communications with customers and the development and/or management of our products and services, mail services, printing services, proxy voting service providers, payment card manufacturing and customisation providers, identification and electronic certification bodies, companies whose financial instruments you hold through Spuerkeess, etc.; 
• subcontractors, suppliers, counterparties and service providers used by Spuerkeess to comply with its legal obligations, such as the bank's account certification entities and customer reporting entities used when onboarding customers remotely (digital onboarding), administrators of Know-Your-Customer files (in particular i-Hub S.A. Luxembourg), MiFIR legal reporting providers, professionals specialising in the search for heirs, providers specialising in the identification and prevention of fraud, online search service providers, etc.; 
• third-party entities that have a connection with our customers, such as entities that carry out banking transactions on our customers' behalf, beneficiaries, principals, assignees, successors, agents, submanagers, managers and investment advisers, etc.; 
• any entity carrying on a regulated profession and acting within the scope of the tasks entrusted to it, such as auditors, lawyers, bailiffs, notaries, etc.; 
• credit reference agencies, debt collection agencies and investigative agencies; 
• persons involved in any disputes concerning specific transactions; 
• some partners such as innovators or universities, which process it in connection with their research. Steps are taken to ensure that personal data is transmitted in pseudonymised, aggregated form and the results of the research are anonymous; 
• tax, judicial, police, regulatory and administrative authorities, regulators and control and supervisory authorities; 
• cloud-computing service providers. Steps are taken to ensure that the data centres used are located within the European Economic Area and that appropriate data encryption is in place for data in transit and at rest;  
• other parties with your authorisation or in accordance with your instructions. With your consent and at your request, Spuerkeess may send your personal data to third parties. 

Such third parties will themselves be required to comply with legal or contractual personal data protection obligations as data controllers or data processors. 

In some jurisdictions, the laws and regulations applicable to (transactions in) financial instruments and similar rights require that the identity of the (in)direct holders or beneficial owners of those instruments and their positions in such instruments be disclosed. 

Special cases: 

• Data transmission as part of mobile payment functionalities 

If you wish to use mobile payment features, you can register one or more payment cards issued by Spuerkeess in the digital wallet of a mobile payment application. In this context, it is necessary to transmit the data of your transactions to our processor who will share the data with the mobile payment application provider you have selected (Apple Pay and/or Google Pay). The personal data and information communicated to this service provider, acting as an independent data controller, are governed by the provider's own confidentiality policy and by the contractual terms and conditions that you accepted when activating the service with the service provider of your choice. 

• Taking out an insurance policy at a Spuerkeess branch 

If you take out an insurance policy offered by our insurance partner LA LUXEMBOURGEOISE via a Spuerkeess branch, some of your KYC data may be transmitted to it for the purposes of documenting and verifying your identity in accordance with the applicable legal and regulatory requirements.  

Spuerkeess is legally obliged to identify account holders' place of residence for tax purposes, and that of any beneficial owners, as applicable, and to make the required annual disclosures to the Luxembourg tax authorities relating to the reportable accounts of persons who are not tax resident in Luxembourg (including US persons as determined by the FATCA (Foreign Account Tax Compliance Act) of 24 July 2015. 

The Luxembourg tax authorities will forward this information to the tax authorities of the country of tax residence of the reportable account holder, or the beneficial owner, as applicable, if the regulations concerning the automatic exchange of information so require. 

In accordance with the laws and regulations that may be applicable to them under the FATCA regulations and the Common Reporting Standard (CRS), customers are required to provide Spuerkeess with a form on their FATCA and/or CRS status (or any other equivalent forms) as well as any updates to those forms.  

Without this tax information, Spuerkeess cannot establish or maintain a business relationship with customers. 

Your personal data will only be transferred by Spuerkeess outside the European Economic Area (“EEA”) if a legal or regulatory provision so requires, if the transfer is necessary for the performance of an agreement or if you have given your explicit consent thereto. Pursuant to the Regulation, for the non-EEA countries in question, Spuerkeess will ensure that an adequacy decision has been issued by the European Commission or that appropriate guarantees (e.g. standard contractual clauses) have been put in place.

For example:

• In the context of fund transfers and transactions in financial instruments, the data required in order for the transactions to be executed is processed by third parties involved in the transaction (e.g. correspondent banks, stock exchanges, financial messaging service providers, etc.), which may be based outside the EEA.

Spuerkeess will store your personal data in accordance with its legal obligations and only for as long as is necessary for the purposes pursued by Spuerkeess.  

The retention period for your data varies and depends on the nature of the data, the purposes of the processing and the retention periods imposed by applicable legal and regulatory provisions, in particular anti-money laundering and counter-terrorist financing regulations. 

Spuerkeess will retain your data for the longest period required by applicable regulations. 

Accounting data is stored for a period of ten years from the end of the financial year to which it relates, in accordance with applicable regulations. 

The majority of customer data (including your identity, contact, financial and transactional data) is retained for up to ten years after the end of the business relationship, without prejudice to specific legal provisions which may require longer retention periods.  

For legitimate reasons and depending on the circumstances, Spuerkeess may store data for a longer period as permitted by applicable laws and regulations. In particular in the event of legal proceedings, personal data may be retained until the end of the legal proceedings and then archived according to the applicable statutory limitation periods. 

Spuerkeess undertakes to protect and secure your personal data to ensure that it remains confidential and to prevent its destruction, loss, alteration or disclosure. 

It has introduced physical, technical, organisational and procedural protective measures to this end: 

• Spuerkeess employees are educated about personal data protection through internal training sessions, regular memos, the dissemination of best practices, etc.; 
• Spuerkeess guarantees that all the necessary measures to protect personal data are taken from the design phase onwards ("Privacy by Design"), whether in relation to new technological or commercial applications or to existing applications whose functionalities are being expanded, replaced or modified; 
• Spuerkeess guarantees, by default, the highest possible level of protection for the personal data that it processes ("Privacy by Default"). By default, only data that is likely to actually be used may be collected and stored. This rule extends to the quantity of personal data, the scope of processing, the data retention period and data accessibility. Special categories of personal data (sensitive data) are subject to enhanced security measures; 
• Spuerkeess restricts access to your personal data to members of staff and third parties who strictly need to know it to be able to carry out their professional activities. They will only process your personal data on our instructions and are subject to an obligation of confidentiality; 
• In the event that the processing of personal data is outsourced, Spuerkeess contractually requires its Data Processors to offer the same personal data security guarantees as it imposes on itself; 
• Spuerkeess's Security Policy guarantees a level of personal data protection that is consistent with the Regulation. 

All these measures are regularly reviewed and updated. 

The confidentiality and security of personal data is also based on best practices adopted by all person involved. We therefore recommend vigilance and precautions, such as installing anti-virus and anti-spyware software, using strictly confidential complex passwords, erasing your online browsing history and, finally, immediately informing Spuerkeess in the event of the loss or theft of your bank cards.   

In the event of a personal data breach, Spuerkeess shall notify the Luxembourg data protection authority (National Commission for Data Protection - CNPD) as soon as possible and, if possible, no later than 72 hours after becoming aware of it, unless the breach in question is not likely to result in a risk to the rights and freedoms of natural persons. In the event that this breach concerns your personal data and if the incident is likely to result in a high risk to your rights and freedoms, Spuerkeess will inform you as soon as possible. 

Spuerkeess reserves the right to use video surveillance inside and outside its buildings and facilities (branches, car parks, automated teller machines, etc.), to ensure your safety and the safety of its employees, and to protect its property and facilities. Video recordings and photos are retained, to serve as proof of an offence or damage, or for the purpose of identifying people (witness, victim, etc.). 

For more information on video surveillance (CCTV), please see the "Information Notice on Video Surveillance" published on our website www.spuerkeess.lu. 

Spuerkeess will record and retain the telephone conversations that you have with its agents (e.g. at the "Spuerkeess Direct" Service Centre), to monitor commercial communications and as evidence thereof, to ensure the security of financial transactions, and to comply with certain legal obligations that require such steps to be taken (e.g. MiFID II). These recordings will be retained for a period of 10 years. 

It is understood that these recordings will remain protected by professional confidentiality obligations and that they may only be used for the above-mentioned purposes. 

The Regulation grants you a number of rights over your personal data processed by Spuerkeess: 

• the right to access your personal data and, where applicable, obtain a copy of that data; 
• the right to request that your personal data be rectified or updated if you believe that it is incomplete, inaccurate or obsolete; 
• the right to have your personal data deleted, unless there is a legitimate reason to justify it being stored; 
• the right to object at any time to the processing of your personal data based on the legitimate interest of Spuerkeess, unless a legitimate reason prevails over your interests and your rights and freedoms; 
• the right to request restrictions on the processing of your personal data; 
• the right to the portability of certain personal data, i.e. the right to receive it in a structured, commonly used, readable format so that it may be sent to another data controller; 
• the right not to be subject to a decision based exclusively on automated processing (see chapter "Decisions based exclusively on automated processing, including profiling"). In such circumstances, you may ask for a decision to be reviewed by directly contacting your branch. 

If you wish to exercise any of the above-mentioned rights, you may submit a request by sending an S-Net message, e-mail or letter to the following address:  

If you have any questions about the protection of your personal data, you may contact the Data Protection Officer by sending an S-Net message, e-mail or letter to the following address: 

This policy is reviewed regularly and is adapted as soon as required by practices or the regulations or in the event of technological advances. We invite you to read this document on our website to ensure that you have the most recent version at all times.