Privacy policy

To cope with technological change, it is necessary to pay attention to privacy issues.

This Privacy Policy explains how Secretimmo (hereinafter “Secretimmo”, “we”, “us”, “our”) collects, uses and otherwise processes your personal data (“Personal Data”) in connection with your relationship with us.

For the purpose of this Policy, Personal Data means any information that relates to an identified or identifiable person and includes all data which are or can be assigned to a person in any kind of way.

Secretimmo is committed to acting in accordance with applicable data privacy laws and regulations, which include the General Data Protection Regulation 2016/679 (“GDPR”) which is applicable as of 25 May 2018.

We control the ways your Personal Data is collected and the purposes for which it is used acting as “data controller” for the purposes of the GDPR.

1. Personal Data we collect about you

Secretimmo processes your Personal Data if and to the extent applicable law provides a lawful basis to do so.

• When you fill in the contact form on our website, we collect data such as name, surname, e-mail address, telephone number or the content of messages sent to us. Similarly, when you wish to subscribe to our newsletter or use our estimation tool, we need to collect your e-mail address.
• When you use our estimation tool and wish to request a physical estimation by one of our agents, we collect your name, first name, e-mail address, telephone number and the characteristics of the property to be estimated.
• In addition, we collect your data when you contact us directly through any communication channel (e.g. when you send us an e-mail with a comment or feedback).
• By providing this information, you expressly agree to your data being processed by SECRETIMMO for the purposes indicated in section 2 below. If there are other purposes than those indicated in point 2, they will be communicated at the end of each form.

Finally, some information is collected automatically. For example, when you access our site, we may automatically collect certain information from your device through log files, such as IP address, MAC address, device ID, operating system of your device, pages visited, requests made, and the day and time of the connection. The use of these files allows us to improve our site and to collect statistical data.

The Personal Data we collect may include:

• Personal identification information and
• Property criteria.

2. How do we use your Personal Data?

We only process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose.

Secretimmo processes your Personal Data in order:

• a) to provide you with the information or services you have requested (for example, responding to a contact request);
• b) to inform you of the result of the valuation of your property when you use our pocket appraisal;
• c) to improve our site, products and services;
• d) to contact you about various Secretimmo events, including product updates and customer support;
• e) to send you marketing information or our newsletter any time you subscribe or unsubscribe and to offer you tailored content.

We will only use your Personal Data for the purposes for which we collected it and which we informed you about, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis for processing it.

3. Legal basis for processing your Personal Data

For the purposes explained under point 2.:

• a) Legitimate interest (including sending a commercial offer or a replay to a contact request);
• b) Contractual execution.
• c) Legitimate interest (log-based anonymized navigation data);
• d) Consent.
• e) Consent (including the newsletter sending).

4. Sharing your Personal Data

We may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with applicable law and regulations.

We may therefore share your Personal Data with certain trusted third parties in accordance with our contractual arrangements. None of these third parties is based or process your Personal Data outside of Luxembourg. If a third-party service provider process Personal Data outside the UE/EEA in the course of our business, transmission shall only take place if an appropriate data protection level has been confirmed for the third country by the EU Commission or if other appropriate data protection guarantees (binding internal data protection provisions or EU standard contractual clauses) exist.

5. Security of your Personal Data

We are committed to protecting your personal information and implementing appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction or damage.

The personal information we collect is stored in a secure environment. Secretimmo employees are required to respect the confidentiality of your information. To ensure the security of your personal information, we use the following measures:

• SSL Protocol (Secure Sockets Layer)
• Access management — authorized persons
• Backups
• Firewall

We are committed to maintaining a high level of confidentiality by integrating the latest technological innovations to ensure the confidentiality of your data. However, as there is no mechanism for maximum security, there is always a risk of using the internet to transfer personal information.

6. Retention period

Your personal data is stored by Secretimmo only for the time in relation with the purpose of our communication exchanges (e.g. when you contact via our contact form) or until you unsubscribe from our newsletter (you can do so by clicking the link available at the bottom of each newsletter sent).

7. Your rights in relation to your Personal Data

You have a number of rights as an individual that you can exercise in certain circumstances in relation to your Personal Data.

These rights include the right to:

• Request access to your Personal Data;
• Request rectification of your Personal Data;
• Request the erasure of your Personal Data;
• Request the restriction of processing of your Personal Data;
• Object to the processing of your Personal Data;
• Request the transfer of your personal information on your behalf or on behalf of another processing manager in an electronic and structured format (right to data portability).

If you want to exercise one of these rights please contact us at privacy[at]secretimmo.lu

Your request will be processed within one month after the confirmation of your identity. You will not have to pay a fee to access your personal information (or perform any other of your rights). However, we may charge you a reasonable fee if your access request is manifestly unfounded or inappropriate. We may also refuse to process your application for the same reasons.

We may ask for this information to help us confirm your identity and to ensure that we respect your right to access this information (or for the performance of any other of your rights). This is a security measure to ensure that your personal information is not disclosed to an unauthorized person. You are allowed to file a complaint with the National Data Protection Commission (“CNDP”) if you feel that your rights are not being respected.

8. Cookies

Our website doesn’t use any cookies to collect your personal data.

9. Our partners

By using these services, you accept our terms of use. None of these services use your personal data without your consent.

We also use real estate platform Apimo for the smooth handling of client requests made on our website. Find out more about the data processing carried out by Apimo: Apimo

We also use Matomo, an open source platform that conforms with GDPR, for gathering statistical data. Find out more about Matomo's privacy policy: Matomo

Regmate is a relationship management tool and digital safe for sensitive documents, in the context of the fight against money laundering (AML & KYC). To find out more about the processes implemented by Regmate: Regmate

Ninox is an internal database and activity management tool of Secretimmo, used for the management of our mandates, estimates and follow-up of transactions and partnerships. To find out more about the processes implemented by Ninox: Ninox

Google Cloud is a remote data storage solution. To find out more about the treatments implemented by Google Cloud: Google Cloud

10. Updates to our Privacy Policy

We keep this Policy under regular review and we may change, modify, add, or remove portions from this Privacy Policy at any time. We will post any modifications or changes to the Policy on our website prior to such changes taking effect.

11. DPO External Data Protection Officer:

Luxgap Sàrl, 6 rue d’Arlon, L-8399 Windhof.