Privacy Policy

At {{Company name}}, we attach great importance to protecting your privacy and aim to be transparent about how we use your personal data.

This Privacy Policy explains what personal data we collect when you use this website, why we use it, with whom it may be shared, how long it is retained and what your rights are.

I. Who are we?

Data controller

{{Company name}}

{{Address}}, {{Postal code}} {{City}}, {{Country}}

Email: {{Email address}}

Telephone: {{Telephone}}

II. What personal data do we collect?

We only collect the information necessary to respond to your requests and ensure the operation of this website. Depending on the features you use, we may in particular process:

your identification data, such as your first and last name;
your contact details, such as your email address and telephone number;
the information you provide in a form or in a message sent to the agency;
information relating to the property that is the subject of your request;
in connection with a valuation request, information relating to the property you wish to have valued, such as its address, type, surface area and the characteristics you provide;
technical data relating to your use of the website, such as your IP address, browser, device type and information necessary for the security and proper operation of the website;
data relating to your browsing activity that may be collected through Google Analytics, where this service is used on the website and you have consented to the use of analytics cookies.

Where certain fields in a form are marked as mandatory, this information is necessary to process your request. If you choose not to provide it, we may be unable to respond to your request.

III. How do we use your personal data?

We use your data for the following purposes:

Responding to your contact requests

When you contact us via the website’s general contact form, we use the information you provide to understand your request, respond to you and follow up on your request.

Responding to your enquiries about a property

When you contact the agency from a property page, we use your contact details, the reference of the relevant property and the information provided to process your request and contact you.

Processing your valuation requests

When you submit a valuation request, we use the information relating to the property and your contact details to assess your request and contact you.

Ensuring the operation and security of the website

We may process certain technical data to ensure the proper operation of the website, detect errors, prevent misuse and protect the website against unauthorised access.

Measuring website usage

The website may use Google Analytics to understand how visitors use the website, compile audience statistics and improve its content and performance. Where Google Analytics is used, it is only activated after you have consented to analytics cookies.

Complying with our legal obligations and protecting our rights

We may also process certain data where necessary to comply with a legal obligation or to establish, exercise or defend our rights.

Legal bases for processing

Responding to a general contact request: our legitimate interest in responding to requests addressed to us.
Processing an enquiry about a property: taking pre-contractual steps at your request and, where applicable, our legitimate interest in responding to your request.
Processing a valuation request: taking pre-contractual steps at your request.
Ensuring the operation and security of the website: our legitimate interest in ensuring the security, stability and proper operation of the website.
Measuring audience using Google Analytics, where this service is used: your consent.
Complying with our legal obligations: compliance with a legal obligation.
Establishing, exercising or defending our rights: our legitimate interest in protecting our rights and interests.

IV. With whom do we share your personal data?

To protect your privacy, only authorised persons may access your data to the extent necessary for the performance of their duties. Where necessary, certain data may also be accessible to:

authorised employees of {{Company name}};
IT and technical service providers involved in hosting, operating, maintaining or securing the website, or in processing and transmitting requests submitted through the website;
Google, as the provider of Google Analytics, where this service is used and you have consented to analytics cookies;
public or judicial authorities where required by law;
our advisers and the courts where necessary to establish, exercise or defend our rights.

Some of our service providers may be located outside the European Economic Area (EEA) or may process data outside the EEA. Where such transfers take place, they are carried out in accordance with applicable data protection law, in particular on the basis of an adequacy decision by the European Commission or appropriate safeguards such as the Standard Contractual Clauses approved by the European Commission.

V. How long do we retain your data?

We retain your data only for as long as necessary for the purposes for which it was collected and, where applicable, for any additional periods required by our legal obligations.

data relating to contact requests and enquiries about a property is retained for the time necessary to process and follow up on the request;
data relating to valuation requests is retained for the time necessary to process and follow up on the request and, where applicable, any resulting business relationship, subject to retention periods required by law;
data collected through Google Analytics is retained in accordance with the retention periods defined for that service and the choices you have made through the cookie management tool;
certain data may be retained for longer where required by a legal obligation or where necessary for the establishment, exercise or defence of legal claims.

VI. What are your rights and how can you exercise them?

Under applicable data protection law, you have the following rights, depending on the circumstances:

right of access: to obtain confirmation as to whether personal data concerning you is being processed and, where applicable, to access that data;
right to rectification: to have inaccurate data corrected or incomplete data completed;
right to erasure: to request the deletion of your data where the legal requirements are met;
right to restriction of processing: to request that the use of your data be temporarily restricted in certain circumstances;
right to object: to object, on grounds relating to your particular situation, to processing based on our legitimate interests;
right to data portability: where provided for by law, to receive the data you have provided to us in a structured, commonly used and machine-readable format;
right to withdraw your consent: where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal.

You may exercise your rights free of charge by contacting us at {{Email address}} and specifying the right you wish to exercise. Where necessary to verify your identity, we may ask you to provide additional information.

If you believe that the processing of your personal data does not comply with applicable law, you may also lodge a complaint with the Luxembourg National Commission for Data Protection (Commission nationale pour la protection des données – CNPD).

VII. Data security

{{Company name}} implements appropriate technical and organisational measures to protect your personal data against loss, misuse, alteration, destruction, disclosure or unauthorised access.

VIII. Changes to this Privacy Policy

This Privacy Policy may be amended, in particular to reflect changes to the website, our processing activities or applicable law. The date of the latest update is indicated at the top of this page.