This information is provided, in compliance with articles 13 and 14 of EU Regulation 679/2016 (hereinafter the "Regulation"), to users (hereinafter: "Users" or "User") of the site Immotop.lu in desktop and mobile versions and applications, (hereinafter: "Website and App") owned by Real Estate Media SA, the Data processor of the personal data (hereinafter: "Holder") and has the purpose of describing the methods for managing the Site and Apps with reference to the processing of personal data, as well as allow the Site and App Users to know the purposes and methods of processing the personal data by the Holder when conferred.
As specified in General Terms and Conditions the services offered by the Holder are aimed at people older than 18 years. Should Data Processor become aware of the data processing of people under 18 years without a valid parental or legal guardian consent, he reserves the right to unilaterally interrupt the use of the service offered as well as to cancel the acquired data.
Terms that are not defined in this personal data protection disclosure have the same meaning as described in General Terms and Conditions.
Users who publish real estate ads undertake to comply with the General Conditions and Terms of Service, also with regard to the protection of personal data. Users assume responsibility for any communication and publication of third-party data, guaranteeing that they have full right to communicate them. The Owner is free from any liability towards third parties, deriving from the illegitimate use of their data.
The Data controller, pursuant to and for the purposes of the Regulation, informs that the aforementioned legislation provides for the protection of individuals with regard to the personal data processing, and that this treatment will be based on the principles of correctness, lawfulness, transparency and protection of the confidentiality and fundamental rights.
In relation to the use of the Site and App, the following types of Users are distinguished:
Simple Users can access some services (e.g. search for properties) anonymously, while for other services (such as posting a listing or receiving updates automatically) it is necessary to register before using.
Professional Users, after signing a Service Contract, have access to certain services intended for them.
The personal data provided by Users through the use of the Site and App, will be processed for the purposes described below:
In order for Users to receive advice on financing from banks or financial intermediaries and proposals regarding mortgages and financing, the Mortgage Advice service allows Users to forward personal data and information on their orientation and preferences regarding the location, type, characteristics of real estate and possible financing to Group companies other than the Controller.
In order to allow the User to get sector information such as news and curiosities, as well as advertising information, the User can join the information, promotional and profiling Activities service to receive informational, promotional and marketing communications on the basis, in some cases, of the activity done on the Site and App.
It is possible to activate anytime the registration to the aforementioned communications, by selecting the following items, present on the Profile page of each Simple User:
The Holder will thus be able to make activities of analysis on the interests, habits and choices of Users, also in order to be able to send them customized promotional material on the services offered.
In order to allow professional operators to qualify themselves as Professional Users, subject to the stipulation of a Services Contract with the Holder, it is necessary for the operator to provide the personal data indicated below, to be contacted in order to know the services dedicated to professionals:
The processing of data for the purposes mentioned in the point C finds its legal basis in the art. 6 (a) of the Regulation ([…] the interested party has given consent to the processing of its personal data for one or more specific purposes). <br /> The processing of data for the purposes mentioned in the points A, B and D finds its legal basis in Art. 6(b) of the Regulation ([...] the processing is necessary for the performance of a contract to which the data subject is a party or to the execution of pre-contractual measures taken at its request).
In the case mentioned in the letter A (II), the non-conferral will not compromise the supply of the service provided for therein.
In particular, in the hypothesis of the letter A (I) the failure to provide the data necessary for the registration of the User, will determine the impossibility to provide the services mentioned in the subsequent letters B, C and D.
The Holder ensures that personal data are processed in full compliance with the Regulation, using manual, IT or telematic systems. Processing can also be carried out using automated tools to store, manage and transmit the data.
The data collected and processed will be protected with physical and logical methods in order to minimize the risks of unauthorized access, diffusion, loss and destruction of data, pursuant to art. 25 and 32 of the Regulation.
The processing of data will last no longer than is necessary to meet the purposes for which they've been collected, such as the storage of search criteria, notification, publication of listings and contact of professional operators.
According to the art. 7 paragraph 3 of the Regulation, the interested party has the right to obtain at any time the revocation of the consent to the processing. To request the deletion of its personal data, the interested party can send a request to the email address privacy@immotop.lu
Browsing data such as date and time of connection, device used, browser version or pages visited are kept for a maximum of 6 (six) months.<br /> If no cancellation request is received by the Holder, the personal data will be stored for a period not exceeding 10 (ten) years, with effect from the date of the last access to the Site and/or App by the User.<br /> Certain data may be kept for 10 (ten) years from the end of the contractual relationship (invoicing, contract, correspondence, etc.), thus allowing the Data Controller to comply with its legal and accounting obligations.<br /> Furthermore, the Data Controller may keep the personal data collected in order to be able to defend its position and interests in the event of a conflict or litigation.<br /> At the end of the defined retention period, the Data Controller securely destroys the personal data.
The personal data collected may be processed by subjects or categories of subjects acting as data processing Managers pursuant to art. 28 of the Regulation or that are authorized to process the data pursuant to art. 29 of the Regulation.
Furthermore, for some services, the data may be communicated to companies that collaborate or use the services of the Data controller (for example individual proponents for information about properties; banks or credit intermediaries for the provision of mortgages and loans and other financial services related to the sale of a property), with the sole intention of providing the services requested by the User. In these cases the companies are autonomous holders, therefore the Holder is not responsible for the processing of the data by them. Furthermore, the Data controller is not responsible for the contents and compliance with the legislation on personal data protection by sites not managed by the Data controller.
Apart from the aforementioned hypotheses, personal data will not be communicated except to subjects, entities and Authorities to whom communication is obligatory pursuant to laws or regulations.
The personal data collected through the Site and App, may be transferred outside the national territory, only and exclusively for the execution of the services requested through the Site and App and in compliance with the specific provisions of the Regulation.
Some personal data may be shared with recipients located outside the European Economic Area. The Holder ensures that the processing of personal data by these recipients takes place in compliance with the Regulation.
The IT systems and the technical and software procedures underlying the operation of the Site and App acquire, during their normal exercise, some personal data whose transmission is implicit in the access and operation mechanisms and protocols in use on Internet.
Every time the User connects to the Site and App and every time he recalls or requests a content, the access data are stored in our systems, in the form of tabular or linear data files.
This category of data includes, for example, IP addresses, domain names of computers used by users who connect to the Site and App, the request by the User's browser, in the form of URI (Uniform Resource Identifier) notation addresses, the date and time of the request to the server, the method used in submitting the request to the server, the amount of data transmitted, the numeric code indicating the status of the response given by the server and other parameters relating to the operating system and to the IT environment of the User.
This data may be used by the Holder for the sole purpose of obtaining anonymous statistical information regarding the use of the Site and App in order to identify the Users' favorite pages and therefore provide more adequate contents and to check the correct functioning. Upon request of the Authority, the data could be used to determine responsibility in case of hypothetical computer crimes against the Site and App or its Users.
Cookies are aimed at speeding up the analysis of Internet traffic, making easier for Users to access the services offered by the Site and App and providing useful and relevant advertising to visitors. With the use of cookies, no personal data are transmitted or acquired and no user tracking systems are used. If the User do not want the information provided by him to be collected through the use of cookies, he can implement a simple procedure present in his browser that allows to refuse the function of cookies.
The information relating to the real estate proposals entered on the Site and App will be visible in the searches done in the internal search engine and could be made available to third party search engines as Site and App allow the indexing of their contents by third-party engines.
In the event that the listing page has already been removed from Site and App, it is possible that the cache copy remains in the search results for a few days. The search results are not managed by Site and App, but the user can report the removal of the page and request the update of the cache copy directly to the search engine.
When using the Site and App with the active position detection function, the Site and App may collect and process information on the User's current position. This data are processed anonymously, in a format that does not allow to identify the User personally, and are used only to facilitate the use of some Site and App Location-based functions. Location services can be activated or deactivated by the User at any time by accessing the settings of your device.
For more information, please read the page Use of Cookies.
In particular, in the hypothesis of the letter A (I) the failure to provide the data necessary for the registration of the User, will determine the impossibility to provide the services mentioned in the subsequent letters B, C and D.
To exercise the rights in the previous point, the concerned person may at any time contact the Data Protection Officer for any communications regarding the processing of his Personal Data, or to know the updated list of any subcontractors appointed by the Data controller, by sending notice to the following contacts:
The Data Controller:
Real Estate Media SA
4, rue Samuel Beckett, L-4371 Belvaux, Luxembourg
privacy@immotop.lu
Data Protection Officer (DPO):
Luxgap Sàrl
2, Rue de l’Ecole, L-8376 Kahler Garnich, Luxembourg
dpo@immotop.lu
This Policy may be subject to amendments. Whenever substantial changes to the use of the data relating to the User should be made by Real Estate Media SA, the latter will notify the User by publishing them with the utmost clarity on its pages.
Date of last update:
4 November 2024