To cope with technological change, it is necessary to pay attention to privacy issues.
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. We therefore process your Personal Data only:
- If you have consented to the processing, or
- If the Personal Data is needed to perform the contract we have entered into with you; or
- If we need it to comply with a legal obligation; or
- If we have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms (provision of services, direct marketing …).
We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information and when you engage our services.
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:
- to provide you with the information or services you have requested (for example, responding to a contact request);
- to improve our site, products and services;
- to contact you about various Secretimmo events, including product updates and customer support;
- to send you marketing information 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.:
- Consent (including sending the Newsletter, a commercial offer or a response to a contact request);
- Legitimate interest (log-based anonymized navigation data);
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
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.
Our website doesn’t use any cookies to collect your personal data.
9. Our partners
In order to guarantee swift contact with our website users, we use the following external services:
- LiveAgent: a live chat module. Occasionally, data generated from conversations is stored in European datacenters located in Germany, the United Kingdom and Slovakia, hosted by Linode Inc.
Find out more about the data processing carried out by LiveAgent: LiveAgent
- SimplyBook.me: a secure and ISO 27001 certified appointment scheduling platform. The data generated by using this software can be transmitted outside EU. These international data transfers are notably subject to standard contractual clause (SCC) guidelines adopted by the European Commission to ensure your rights are respected.
To find out more about how SimplyBook processes your data: SimplyBook
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
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
11. DPO External Data Protection Officer:
Luxgap Sàrl, 6 rue d’Arlon, L-8399 Windhof.
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