Privacy Policy

Last updated: 1st January 2026

Introduction

boldpathorium SARL ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website boldpathorium.pro or use our restaurant waste management services.

Data Controller Information

The data controller for your personal information is boldpathorium SARL, registered in Luxembourg with registration number RCSB314697. Our registered address is Rue Aldringen 79, 4236 Differdange, Luxembourg.

Data Collection

We collect information that you provide directly to us and information that is automatically collected when you use our website and services. The data we collect may include:

• Personal identification information (name, email address, phone number)
• Business information (restaurant name, address, service requirements)
• Communication records (emails, phone calls, service enquiries)
• Website usage data (IP address, browser type, pages visited)
• Service usage information (waste collection schedules, volumes, compliance data)

How We Use Your Information

We use the information we collect for various purposes, including how we use your information to provide and improve our restaurant waste management services:

• To provide, operate, and maintain our waste management services
• To process service requests and manage customer relationships
• To communicate with you about our services, including customer support
• To comply with legal obligations and regulatory requirements
• To improve our website and services through analytics
• To send you marketing communications (with your consent)

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please see our Cookie Policy.

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contract performance: To provide our waste management services
• Legal obligation: To comply with waste management and environmental regulations
• Legitimate interests: To improve our services and website functionality
• Consent: For marketing communications and non-essential cookies

Data Sharing and Disclosure

We may share your information in the following circumstances:

• With regulatory authorities as required by waste management laws
• With service providers who assist in delivering our services
• With legal authorities when required by law or to protect our rights
• In connection with a business transfer or acquisition

Your Rights

Under GDPR and Luxembourg data protection law, your rights include:

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent

Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations. Service records are typically retained for 7 years in accordance with Luxembourg business record requirements. Marketing data is retained until you withdraw consent or for 3 years from last interaction, whichever is sooner.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, and regular security assessments.

International Data Transfers

Your data is primarily processed within the European Union. If we transfer data outside the EU, we ensure appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses.

Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Complaints

If you believe we have not handled your personal data in accordance with this policy, you have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) or your local data protection authority.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.