Privacy policy

The protection of privacy is a fundamental priority in the face of ongoing technological developments.

This Privacy Policy explains how SECRETIMMO (hereinafter referred to as “SECRETIMMO”, “we”, “us”, “our”) collects, uses, and processes your personal data (“Personal Data”) in the context of your interactions with us.

For the purposes of this Policy, Personal Data refers to any information relating to an identified or identifiable natural person and includes all data that can be directly or indirectly associated with an individual.

SECRETIMMO is committed to complying with applicable data protection laws, in particular Regulation (EU) 2016/679 – the General Data Protection Regulation (GDPR), effective since 25 May 2018. We act as the “Data Controller” within the meaning of the GDPR, as we determine the purposes and means of processing your Personal Data.

1. Personal Data We Collect

SECRETIMMO processes your Personal Data only when legally permitted or justified by an appropriate legal basis.

We collect in particular:

Information you enter via our contact form: name, surname, email address, telephone number, message content.
Data provided to subscribe to our newsletter or to use our property valuation tool: email address, property-related data.
Data related to a physical property valuation request: name, surname, email, phone number, property details.
Information exchanged through any other communication channel (email, phone, etc.).
Automatically collected data during your navigation on our website: IP address, MAC address, device ID, operating system, pages visited, requests made, date and time of connection.

The Personal Data we collect includes:

Identity and contact information.
Information related to your real estate assets.

By providing this information, you expressly consent to its processing by SECRETIMMO for the purposes described below. Any additional purposes will be clearly indicated during collection.

2. Purposes of Data Processing

Your Personal Data is processed for specific, explicit, and legitimate purposes, namely:

a) To provide you with requested information or services (e.g., responding to a contact request).
b) To provide the result of your property valuation via our online tool.
c) To improve our website, products, and services.
d) To contact you regarding SECRETIMMO events, updates, or customer support.
e) To send marketing communications or newsletters, if you have consented.

If your data needs to be processed for a different purpose, we will inform you, unless the new purpose is compatible with the original purpose.

3. Legal Bases for Processing

Depending on the purpose, processing of your Personal Data is based on:

a) Legitimate interest (including customer relationship management and commercial offers).
b) Contractual necessity.
c) Legitimate interest (e.g., anonymized statistical analysis).
d) Consent.
e) Consent (e.g., for marketing communications).

4. Sharing of Personal Data

SECRETIMMO shares your Personal Data only with trusted third parties and only when required by law or necessary for the provision of our services. These third parties operate under contractual obligations.

All data processing takes place exclusively in the Grand Duchy of Luxembourg. If data is transferred outside the EU/EEA, this will only occur where the destination offers adequate protection as recognized by the European Commission or where appropriate safeguards are in place (standard contractual clauses, binding corporate rules, etc.).

5. Data Security

We implement appropriate technical and organizational measures to ensure the security, integrity, and confidentiality of your Personal Data, including:

SSL protocol (Secure Sockets Layer)
Restricted access to authorized individuals
Regular backups
Firewalls and network security

Despite our efforts, no Internet transmission is entirely secure and some residual risk may remain.

6. Data Retention

Your Personal Data is retained for a duration proportional to the purposes pursued:

Contact data: for the duration of the relationship or until objection/unsubscription.
Newsletter data: until unsubscription (via a link in each message).

7. Your Rights

You have the following rights:

Right of access
Right to rectification
Right to erasure
Right to restriction of processing
Right to object
Right to data portability

To exercise these rights, contact us at: privacy[at]secretimmo.lu

Your request will be processed within 30 days of identity verification. If the request is excessive or clearly unfounded, we may charge a fee or refuse the request.

You also have the right to lodge a complaint with the CNPD (Commission nationale pour la protection des données) if you believe your rights are not being respected.

8. Cookies

Our site does not use cookies that can identify you.

9. Partners

SECRETIMMO works with technical service providers in compliance with the GDPR:

Matomo: a locally hosted audience analysis solution.
Brevo: newsletter email delivery platform.

None of these services process your Personal Data without your explicit consent.

10. Updates

This policy may be modified at any time. The updated version will always be available on our website.

11. Data Protection Officer (DPO)

Rudolphe Aben, Managing Director of SECRETIMMO S.A.