The privacy policy (hereafter the “Privacy Policy”) governs the manner according to which LEO S.A., a Luxembourgish company having its registered office at 9, bd Roosevelt, L-2450 Luxembourg, registered with the Luxembourg Trade and Companies Registry under number B 92845 and/or its affiliated companies (collectively designated as “LEO”) belonging to the Encevo Group, collect, use, process and/or communicate personal data of natural persons (such as “Prospect”, “Customer” or “User”) in relation to the supply of energy and/or the usage of its websites, mobile applications, and digital services (together designated the “Services”). The supply of energy includes additional energy related services like the access and management to the customer portal, the customer account, the organization of commercial and marketing operations and the management of Users’ and Customers’ feedback. Within the framework of the Privacy Policy, Leo acts as data controller (“Data Controller”). The Privacy Policy aims to provide transparency about your personal information either collected directly from you or throughout our interactions with you. Some information may also come from publicly available sources. We share information with service providers (“Data Processors”) in relation to our supply activities and/or with third parties like supervisory authority to comply with legal and regulatory obligations but also to prevent fraud and to handle in the best manner Customer’s requests, complaints and any possible disputes. We inform you that we recently updated our Privacy Policy concerning the concept of legitimate interests, the type of data collected, for which purposes and on which legal basis (cf. the Schedule below), the retention periods and concerning the usage of artificial intelligence. Leo acknowledges and undertakes to comply with the national laws and regulations applicable to the protection of personal data (the “Law”), including but not limited to the 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 (the “GDPR”). As Data Controller, Leo considers the protection of your personal data to be of great importance and has appointed a data protection officer (hereafter the “DPO”) that you can contact for any questions you may have. The main role of our DPO is to ensure that personal data of our employees, Prospects, Customers and Users are processed by Leo or by our Data Processors in compliance with the Law and the GDPR. For any questions about the processing of your personal data carried out by Leo, please feel free to contact our customer service centre or the DPO at the following addresses: Leo S.A.
We invite you to read this Privacy Policy. If you are already a Customer of Leo, please also check the contracts between us because they may contain further details on how we collect and process your data. Whatever is the method used to collect personal data, either directly from you or from third parties, please note that we will use these personal data only for the specific reason for which it was provided to us. By contracting with us or by using the Services, you acknowledge and accept the treatment of your personal data in accordance with the Privacy Policy. As from your first interaction with us or with third parties, personal data are collected through various digital channels (by email, by navigating on our web sites or through social media) and also by correspondence in writing (letter, messages) or verbally (during a physical meeting or by telephone). The Privacy Policy is applicable regardless of the communication channel or the method used to collect your data. The Schedule below provides more details about the type of data we collect, for which purposes and the legal basis on which we process your personal data. In the framework of our activities, we collect and process several types of personal data depending on the offers and services you have subscribed to and the forms you have filled-in on our websites. This processing is based on one of the following legal bases: We process your personal data within the extent it is necessary to execute the contract you have entered with us and/or for the needs of the pre-contractual relationships. We process your data on the basis of a clear and explicit consent (by ticking the box or clicking) that you have given to us for a specific purpose. You can change your mind! If you have previously given consent to the processing of your personal data, you can freely withdraw such consent at any time or update any of your opt-in marketing preferences by logging on your account. You can also contact us by email at serviceline@leoenergy.lu. If you withdraw your consent, and if we do not have another legal basis for processing your information, then we will stop processing your personal data. If we have another legal basis for processing your information, we will limit our processing to what is strictly necessary with regard to the purpose of the concerned treatment. In the following cases, we process your data on the basis of our legitimate interests within the limits of what you can reasonably expect in the interactions with us and as long as there is no other legal basis for such processing. Our legitimate interests are: In each case, we ensure to find a balance between your rights and our legitimate interests. For more information about such balancing, you can contact us by email at the following address : dpo@leoenergy.lu We process your personal data in accordance with the Law, relevant government instructions and energy sector industry practices as applied by the Courts and supervisory authorities. In the schedule below, you will find the detail of (i) the categories of personal data that we collect, (ii) the purposes for which we process such data, (iii) the legal basis associated with each purpose. When collecting information, we indicate which information is mandatory or necessary for the conclusion of the contract. Failure to provide such information will prevent us from entering into a contract with you. Optional information is indicated as “optional”. [1] The details of each category of data (Customer Name Data, Customer Communication Data, Point of Delivery Data, etc.) are defined by Encevo Group internal policies. [2] According to the Electricity Law dated June 9th, 2023, an active client is an end-customer or a group of end-customers acting jointly, which consumes, or stores electricity produced on its/their premises, or which sells its/their self-produced electricity and/or participates in flexibility or energy efficiency programs provided such activities are not its main commercial or professional activity. At Leo, we are dedicated to using Artificial Intelligence (AI) transparently, responsibly and in compliance with the GDPR, the Regulation (EU) 2024/1689 of June 13th, 2024 (AI Act) and the principles set out in this privacy policy to ensure that the use of this technology –respects your fundamental rights and freedoms. More specifically, as part of the continuous improvement of our services, we are using AI as an assistant to the Customer Service Center (CSC) agents. This AI helps to manage the flow of requests by analysing the content, categorizing according to the nature and assessing the level of criticality of your requests. AI can generate a response proposal which is systematically reviewed and modified, if necessary, by a human agent. This tool aims to provide preliminary, accurate and rapid responses to your requests, while guaranteeing systematic human control. It is essential for Enovos to ensure that the impact of the use of AI on the processing of your personal data is limited and controlled by ensuring that the following principles are applied: If you have any questions about the use of AI regarding the CSC and the management of your personal data, you can contact our Data Protection Officer (DPO) at the following address: dpo@leoenergy.lu. We don’t collect any sensitive data as defined by the RGPD (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences). You have personal rights regarding your data that you can exercise in accordance with the Law and the GDPR, including a right of access, right to correct, right to erasure, a right to restrict a treatment, right to oppose (right to be forgotten), and a portability right. If you want to exercise or get more explanation about any of these rights, please contact the Data Protection Officer at the following address: dpo@leoenergy.lu. We will answer you within a reasonable delay, not exceeding one month as from the date of your request. Such right can be exercised to the extent it does not adversely affect the rights and freedoms of others. Under certain circumstances, some rights such as the right to be forgotten or the portability right can be exercised subject to conditions, for example, they shall not prevent the execution of ongoing contracts or prevent us from complying with our obligations or obstructing any possible legal proceedings. In such cases, we will provide you with any further explanation which might be relevant to you. We provide several channels to exercise your rights so that you can choose the more convenient to you. For any questions/concerns, please contact us at the following addresses so that you have a chance to address your request in the best delay : Leo S.A.
Leo has implemented appropriate physical, technical and organizational security measures to protect your personal data against unauthorised access, alteration, disclosure, theft, destruction or other accidental or unlawful forms of processing in accordance with the Law, GDPR and generally accepted standards of technology and operational security. We have set-up internal security policies and we require our Data Processors to comply with the Law and GDPR. They are bound by contractual obligations related to confidentiality, processing and security measures to prevent unauthorised access, use, theft, destruction and disclosure of personal data. Security issues being a general matter concerning everyone, we advise you to remain vigilant and take any useful or necessary precaution to guarantee the confidentiality of your password and your access code to the customer account. Your personal data are stored with the European Union either by our organization or by our service providers (Data Processors). In the event a transfer of personal data outside the European Union or outside the European Economic Area (EEA) is contemplated, such transfer will only take place provided the appropriate safeguards provided by articles 44 to 47 of the GDPR are in place, i.e. :
Leo takes all reasonable measures to ensure that your personal data are processed for the minimum period of time necessary for the purposes set out in this Privacy Policy. The criteria to determine the duration during which we retain your personal data in connection with the Services are as follows: The main retention periods are the following (for Luxembourg): Despite these retention periods, your data may be archived with restricted access for a further period for limited reasons as permitted by law (default payment, warranty, disputes, etc.). Leo undertakes to delete or to anonymise your personal data upon expiry of the retention period as described above. We communicate some data to our technical partners, such as the network operator and to authorized third parties like state authorities, including the authority responsible for regulating the energy markets (ILR), where necessary and in compliance with the Law. We share personal data with Data Processors within the limit of what is necessary for the performance of the services entrusted to them. In accordance with the terms of the contracts, Data Processors process data in compliance with GDPR on the basis of our instructions in relation to defined purposes and ensure to implement appropriate technical and organisational security measures. We use the following categories of recipients to provide Services (a list of contracting entities can be shared upon request) : The data may be transmitted to third parties where this is required or expressly authorised by the Law, to enforce a provision of the law, or further to a judicial/regulatory decision if such disclosure is necessary in the context of an investigation or a legal proceeding and to protect the rights and interests, properties, safety and security of Leo, our clients or other persons. The Privacy Policy will be updated regularly to consider legal, regulatory and operational changes. In case of important changes (e.g.: type of data collected, how we use it or for which purposes), we will highlight such change at the top of the Policy. You are invited to read the Privacy Policy regularly to be informed about its evolution and modifications. The continued use of the Services following the posting of any changes to this Privacy Policy will be deemed as an acceptance of those changes. Version 3.0 du 20/03/2025What is Leo’ role in your privacy ?
Our commitment to comply with data protection Law
Your points of contact
9, bd Roosevelt
L-2450 Luxembourg (Luxembourg)
How to stay involved in the treatment of your personal data ?
When and how we collect data ?
What are our “legal bases” for processing your data ?
Contract
Consent
Legitimate interests
Law
How and why we process your data?
Context
Type of personal data 1
Purposes of the processing
Legal basis
Browsing on our websites and using our digital spaces
Request an offer/ Enter into an energy supply contract
Execution of the energy supply contract
Exchange and communication with our services
Commercial activities
What about usage of Artificial Intelligence (AI) ?
What about really sensitive data?
What are your privacy rights?
Such right can be exercised to the extent it does not adversely affect the rights and freedoms of others. In such case, we will provide you with any further explanation which might be relevant to you.
To the attention of the DPO
9, bd Roosevelt
L-2450 Luxembourg (Luxembourg)
How we secure the data we collect?
How do we store and transfer your personal data?
How long do we retain your data?
To whom your data are shared ?
Changes to this Privacy Policy
