51, Bld Grande Duchesse Charlotte

L-1331 Luxembourg-Belair

+352 28 26 97 41

Anne Sophie Sarrado Managing Director
+352 691 241 924

Privacy policy
The purpose of this confidentiality policy is to inform website users of the methods used to collect, process and use their Personal Data and of their rights on the matter of Personal Data Protection in terms of applicable regulations and, more specifically, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on Personal Data Protection (the “GDPR”) and the law of 1 August 2018 on the General System for Data Protection (the “Law of 1 August 2018”).

1 Data controller

As part of the operation of this website (the “Website”), the property agency ADESMAX REAL ESTATE, established and with its registered office in 51, Bld Grande Duchesse Charlotte L-1331 Luxembourg-Belair (l’ « Agence »), (the “Agency”) is required to process certain Personal Data of users of the Website (the “Users”).

The Agency determines the purposes and means to process Data in accordance with the GDPR and the Law of 1 August 2018. As such, the Agency is responsible for Data processing.

2 Data collected and processing

The Agency collects two types of Personal Data :

2.1. The Data that the User communicates directly to the Agency

The Agency may collect Data provided by the User when such User fills out a contact form. If the User wishes to receive further information about an advertisement, the Data collected shall be: full name, email, telephone number.

The User will have the ability to submit a rental application form. In this case, the User will be required to provide information about his or her personal situation and that of his or her household (spouse, number of dependant children), professional situation (such as job, income level, etc.). These Data are used to build a file with a view to renting a property offered by the Agency.

The User shall be able to obtain an estimate of a property offered for sale. In this context, the User will be required to complete a form and provide Data relating to the property to be sold.

If the User decides to subscribe to the newsletter from the Agency, his or her email address shall be collected and processed. The User may, at any time, decide to unsubscribe from the newsletter by contacting the Agency or using the link included in each newsletter received.

2.2. Data collected indirectly by the Agency

When browsing the Website, the Agency collects a certain amount of browsing Data. This includes :

• Connection data, such as the date and time of connection, the browser version and IP address ;

• Tracking Data : the Agency implements means that enable it to follow the behaviour of a User of the Website while browsing, namely through the use of cookies (see article 7 for further details).

3 Purposes of Data processing and legal basis

The Data provided by the User when completing a form are necessary to respond to the request from said User. It shall not be used for other purposes without prior consent.

Browsing data are collected in order to analyse and measure the quality of browsing of the Website by Users. The User has the ability to accept or reject the collection of browsing Data.

The legal basis for Data processing by the Agency is the data subject's consent (article 6.1.a) of the GDPR). In general, the Agency does not collect Data from Users without their prior consent.

4 Transfer of Data

As part of its operations, the Agency may be required to transfer data only to persons to which the Agency outsources certain tasks related to the operation of the Website. These are the following subcontractors : .

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

The Agency may be required to disclose Data to comply with regulations in force or as requested by an authority, as part of judicial proceedings, e.g. to respond to complaints and/or claims, to protect the rights or interests of the Agency or its clients.

5 Data Security and storage

The Agency shall take all the appropriate precautionary, technical and organisational measures so as to ensure the security, integrity and confidentiality of User Data and, specifically, prevent their deformation, damage or access by unauthorised third parties. However, the Agency cannot guarantee the elimination of every risk and, in particular, risks related to the use of the Internet.

The Agency shall inform the relevant persons as soon as possible in the event of a breach of the Personal Data that is likely to entail a significant risk to their rights and freedoms, in accordance with article 34 of the GDPR.

The Agency shall store the Data for a period no longer than that necessary for the purposes for which they were processed. Thus, the Data provided by the User when completing a form shall not be stored for a period longer than six months if there is no follow-up.

At the end of this period, the Agency shall proceed to delete or anonymise the Data, unless the Agency is subject to a legal obligation to store the Data for a longer period.

6 User Rights

Users are informed that they shall have the following rights :

• Right to access the data: the User may request, at any time, to obtain access to the Data on him or her, as well as a copy of such Data – the Agency reserves the right to ask the User for proof of identity ;

• Right to demand the rectification of the Data: the User may request, at any time, the rectification of inaccurate or incomplete Data ;

• Right to demand the erasure of the Data: the User may request the erasure of his or her Data when, for instance, the Data are no longer necessary for the purposes for which they were collected or processed ;

• Right to demand limitations in processing: the User may request the Agency to restrict the processing of Data if, for instance, the User contests the accuracy of the Data on him or her or objects to the processing of Data on him or her ;

• Right to Data portability: the User shall have the right to have his or her Data transferred to another data controller in a structured, common and machine-readable format, if processing takes place through automated means or is based on prior consent ;

• Right to object to Data processing: the User may object to the processing of his or her Data and may withdraw his or her consent if processing is based on consent, if, for instance, the Data are used for market research.

Users may contact the Agency to exercise their rights or obtain more information regarding the processing of their personal Data, at the following address : n.vivien@adesmax.lu. The Agency shall reply within a maximum period of one month.

Users are also advised that if they are dissatisfied with the Agency's response to one of their requests or with the manner in which the Agency processes Data, they have the right to lodge a complaint before a control authority (the National Commission for Data Protection in Luxembourg – CNPD – www.cnpd.public.lu).

7 Cookies and other trackers

7.1. Definition

The Agency uses cookies and other trackers on its Website (jointly, “Cookies”). Cookies are text files that can be saved, with the User's consent, in a dedicated space in the hard drive of the device (computer, smartphone, tablet, etc.) at the time of using the Website through browsing software.

Cookies are sent by the Website server to the User's browser and are intended to collect information relating to the User's browsing and provide, in return, custom services or information.

7.2. User Consent and Cookie management

When connecting to the Website, a banner is displayed at the bottom of the first page. The User must either accept or customise the use of cookies (e.g. by rejecting certain Cookies) in order to browse the Website.

Subject to receiving prior consent from the User, Cookies will be stored in the memory of the device (computer, smartphone, tablet, etc.). Information collected in this manner may be used by the Website or a third party or partner.

The User may also adjust how cookies are managed by changing his or her browser settings according to his or her preferences. The procedure to be followed is described in the following information pages :

- Internet Explorer : https://support.microsoft.com/fr-lu/help/17442/windows-internet-explorer-delete-manage-cookies

- Safari : https://support.apple.com/fr-lu/guide/safari/manage-cookies-and-website-data-sfri11471/mac

- Chrome : https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=fr-FR

- Mozilla Firefox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences

7.3. Different types of Cookies used on the Website

The Agency uses the following Cookies :
Functional Cookies : they allow for recognising the User while using the Website, by keeping a record of the different choices made during the User's last visit to the Website. They thus allow for customising, simplifying and facilitating browsing of the Website.

Audience measurement and analytical Cookies : they record certain information about connections with the goal of analysing and measuring traffic on the Website in order to improve the presentation of the Website. These Cookies are used to optimise the Website.

Third-party applications – social networks : the Agency uses third-party applications that allow the User to share content, such as a property advertisement, on social networks, such as Facebook, Twitter, Google, Google+, Youtube, LinkedIn, Pinterest and Instagram.

These social networks may identify the User when clicking on one of the buttons to share content through his or her user account or while visiting the Website if the User is logged in to the user account of the social network in question.

The Agency does not control the process used by social networks to collect browsing Data on the User of the Website. Consequently, the User is invited to review the confidentiality policy of the social network used by clicking on one of the links below, so as to learn about the browsing Data collected and the manner in which they are used.

https://www.facebook.com/privacy/explanation

https://twitter.com/fr/privacy

https://www.google.com/intl/fr/policies/privacy/ (Google, Google+, Youtube)

https://www.linkedin.com/legal/privacy-policy?_l=fr_FR

https://policy.pinterest.com/fr/privacy-policy

https://help.instagram.com/519522125107875?helpref=page_content

8 Miscellaneous provisions

The Agency reserves the right to amend or adapt the confidentiality policy at any time. For any matters related to this confidentiality policy, please contact the Agency at the following email address n.vivien@adesmax.lu.

These texts are the property of Real Estate Media SA and are protected by copyright. Their use is only authorized once the customer has paid the user fees.