PREAMBLE

This Privacy Policy (the “Policy”) aims to inform users of the website about the methods of collection, processing, and use of their personal data, as well as their rights regarding the protection of personal data in accordance with the applicable provisions, and more specifically with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of personal data (the “GDPR”) and the Law of 1 August 2018 on the general regime of personal data protection (the “Law of 1 August 2018”).

As part of the operation of this website (the “Website”), the real estate agency Bureau Immobilier Wagner Sàrl, established and having its registered office at 46a Grand-Rue L-9710 Clervaux (the “Agency”), is required to process certain personal data of the users of the Website (the “Users”).

For the purposes of this Policy, personal data (“Data,” “Personal Data”) refers to any information relating to an identified or identifiable natural person, directly or indirectly.

The Agency determines the purposes and means of Data processing carried out in accordance with the GDPR and the Law of 1 August 2018. As such, the Agency is the controller of the Data processing carried out.

1 / COLLECTION OF PERSONAL DATA

The Agency collects two types of Personal Data:

1.1 / Data directly provided by the User to the Agency

The Agency may collect Data provided by the User when they fill out a contact form. If the User wishes to receive additional information regarding a listing, the collected Data will be: first name, last name, email, and phone number.

The User may also submit a rental application file. In this case, they will be required to provide information regarding their personal situation and that of their household (spouse, number of dependent children), their professional situation (for example their employment, income level, etc.). This Data is used to create a file for the purpose of renting a property offered by the Agency.

The User may request an estimate of their property intended for sale. In this case, they will be required to fill out a form and provide Data related to the property to be sold.

If the User decides to subscribe to the Agency’s newsletter, their email address will be collected and processed. The User may unsubscribe at any time by contacting the Agency or using the link provided in each newsletter.

1.2 / Data indirectly collected by the Agency

During navigation on the Website, the Agency collects certain browsing Data. This includes:

Connection Data such as the date, time of connection, browser type, and IP address;
Data from trackers: the Agency implements means to monitor User behavior on the Website, notably through cookies (see Cookie Management Policy).

2 / PURPOSES OF DATA PROCESSING

Personal Data is processed for the following purposes:
a) Management of contact requests;
b) Management of rental application files;
c) Management of newsletter subscriptions;
d) Prospecting, including email prospecting: preparation of commercial and marketing statistics, preparation and sending of promotional offers, email alerts to prospects and clients (private or professional), sending of information on our new or existing services to professional clients;
e) Improvement of the Website and services (notably through cookies).

3 / LEGAL BASIS OF PROCESSING

For the purposes explained in point (2):
a) Legitimate interest;
b) Pre-contractual/contractual performance;
c) Consent;
d) Legitimate interest;
e) Legitimate interest.

4 / DATA RECIPIENTS

In the course of its activities, the Agency may share Data only with persons to whom the Agency outsources certain tasks related to the operation of the Website. These subcontractors include: IMMOTOP.lu

The Agency does not transfer Users’ Data to third countries within the meaning of the GDPR, i.e., outside the European Union.

However, when Personal Data is transferred (including remote access) to a third country outside the European Union that is not subject to an adequacy decision, appropriate safeguards are put in place in accordance with Chapter V of the GDPR, notably through contracts incorporating standard data protection clauses adopted by a data protection authority and approved by the European Commission.

The Agency may be required to disclose Data to comply with applicable laws or at the request of an authority, or in the context of legal proceedings, for example to respond to complaints and/or claims, or to protect the rights or interests of the Agency or its clients.

5 / DATA SECURITY AND RETENTION

The Agency takes all necessary precautions and appropriate technical and organizational measures to ensure the security, integrity, and confidentiality of Users’ Data, particularly to prevent it from being altered, damaged, or accessed by unauthorized third parties. However, the Agency cannot guarantee the elimination of all risks, particularly those related to the use of the Internet.

The Agency will inform the concerned individuals as soon as possible in the event of a personal data breach likely to result in a high risk to their rights and freedoms, in accordance with Article 34 of the GDPR.

The Agency retains Data for no longer than necessary for the purposes for which it is processed. Data provided by the User when filling out a form will not be kept for more than six (6) months if no follow-up occurs.

At the end of this period, the Agency will delete or anonymize the Data, unless it is subject to a legal obligation to retain it for a longer period.

6 / USERS’ RIGHTS

Users are informed that they have the following rights:

Right of access to Data: the User may request access to their Data at any time, as well as a copy – the Agency reserves the right to request proof of identity;
Right to rectification: the User may request at any time that inaccurate or incomplete Data be corrected;
Right to erasure: the User may request that their Data be deleted when, for example, it is no longer necessary for the purposes for which it was collected or processed;
Right to restriction of processing: the User may request that the Agency restrict Data processing if, for example, the User disputes the accuracy of their Data or objects to its processing;
Right to Data portability: the User has the right to transfer their Data to another controller in a structured, commonly used, machine-readable format if processing is carried out by automated means or based on prior consent;
Right to object: the User may object to the processing of their Data, and they may withdraw their consent if processing is based on consent, for example if Data is used for commercial prospecting.

Users may contact the Agency to exercise their rights or to obtain more information regarding the processing of their Personal Data at the following email address: info@immo-wagner.lu. The Agency will respond within a maximum of one (1) month once the requester’s identity has been confirmed.

The User will not have to pay any fee to access their Personal Data (or to exercise any of their other rights). However, the Agency may charge a reasonable fee if the request is manifestly unfounded or excessive. The Agency may also refuse to comply with the request for the same reasons.

Users are also informed that if they are not satisfied with the Agency’s response to a request or with the way the Agency processes their Data, they have the right to file a complaint with a supervisory authority (the National Commission for Data Protection in Luxembourg – CNPD – www.cnpd.public.lu).

7 / MISCELLANEOUS

The Agency reserves the right to modify or adapt the Privacy Policy at any time.
For any questions related to this Privacy Policy, please contact the Agency at the following email address: info@immo-wagner.lu

These texts are the property of Real Estate Media SA and are protected by copyright. Their use is only permitted once the client has paid the usage rights.

Last updated: September 29, 2021

COOKIE MANAGEMENT POLICY

DEFINITION

The Agency uses cookies and other trackers on its Website (collectively, “Cookies”). Cookies are text files that may be stored, with the User’s consent, in a dedicated space on the terminal’s hard drive (computer, smartphone, tablet, etc.) during the use of the Website via browsing software.

Cookies are transmitted by the Website server to the User’s browser and are intended to collect information relating to the User’s browsing and to provide back specific indications or services.

There are two types of Cookies:

Session Cookies: temporary cookies deleted when the User closes their browser. When the browser is restarted and the User returns to the site that created the cookie, the site will not recognize them. The User will need to log in again (if required) or reselect their preferences/themes if the site uses these features. A new session cookie will then be generated and remain active until the User leaves the site and closes their browser.
Persistent Cookies: these remain in one of the User’s browser subfolders until they are manually deleted or until the browser deletes them based on the duration specified in the persistent cookie file.

COOKIE MANAGEMENT

When logging onto the Website, a banner appears at the bottom of the first page. The User must either accept or customize the use of cookies (for example by refusing certain Cookies) in order to continue browsing the Website.

Subject to the User’s prior consent, Cookies will be stored on the terminal (computer, smartphone, tablet, etc.). The information thus collected may be used by the Website or, where applicable, by a third party or partner.

The User may also directly adjust cookie settings by configuring their browser according to their preferences. The procedure is described in the following information pages:

COOKIES USED ON THE WEBSITE

The Agency uses the following Cookies:

Functional Cookies: they allow the User to be recognized when using the Website, by storing the different choices made during their last visit. They personalize, simplify, and facilitate navigation on the Website.
- Name: rc::a
  Source: google.com
  Purpose: used to distinguish humans from bots; allows creation of valid usage reports.
  Retention: persistent
- Name: rc::c
  Source: google.com
  Purpose: used to distinguish humans from bots.
  Retention: session
Analytical and audience measurement Cookies: they record certain connection information to analyze and measure Website traffic and aim to improve the Website’s presentation. These Cookies are used for Website optimization purposes.
Third-party applications – social networks: the Agency uses third-party applications allowing the User to share content, such as property listings, on social networks Facebook, Twitter, Google, Google+, YouTube, LinkedIn, Pinterest, and Instagram.

These social networks may identify the User when they click on a button to share content via their user account, or when they visit the Website while logged into their social network account.

The Agency does not control the process used by social networks to collect Data relating to the User’s navigation on the Website. Users are therefore invited to consult the privacy policy of the relevant social network by clicking one of the links below to learn about the browsing Data collected and how it is used: