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Privacy Policy Real Estate Media Inc.

Preamble

To cope with technological developments, it is necessary to give heed to the protection of privacy. Real Estate Media SA ("IMMOTOP") undertakes to comply with the new European General Data Protection Regulation (GDPR) which came into force on May 25th, 2018. The personal data collected by IMMOTOP is entirely governed by this new regulation.

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

For all the processing carried out, we act as a data controller within the meaning of the GDPR.

Index

1. Collection of personal data
2. Purposes of data processing
- Information that you provide voluntarily
- Registration information
- Transaction information
- Comments and opinions
- Information we collect automatically
- Activity information
- Cookies and similar technologies
- Information we obtain from third-party sources
3. Legal basis of processing
4. Contact forms and interaction
- Links to third-party websites
5. Log files and cookies
6. Data recipients
7. Storage period
8. Right of objection, withdrawal, and transfer
9. Right of access and rectification
10. Right to restrict processing
11. Exercise of rights
12. Security
13. Cookies

1. collection of personal data

In general, your Personal Data is not automatically recorded when you browse the immotop.lu website.
However, during your visit, a banner appears at the bottom of the screen to notify you of the use of cookies while you are browsing the website. It is up to you to choose between accepting or rejecting the deposit of cookies depending on the purpose of each cookie.

Some cookies do not collect any personal data but simply provide a better browsing experience. To learn more about the types of cookies and similar technologies we use, why and how you can control these technologies, please see our cookies policy.

In some cases, especially when you want to leave a message on the website, you will be asked to provide your first name, last name, and email address.

By providing this information, you expressly consent to the processing of your Data by IMMOTOP for the purposes indicated in section 2 below. If there are purposes other than those indicated in point 2, they will be communicated at the end of each form.

2. Purposes of data processing

IMMOTOP processes your Personal Data for the following purposes :

a) Customer or user account management (personal space): posting and updating of real estate advertisements, after-sales services and complaints, conducting satisfaction surveys ;
b) Billing management ;
c) Litigation management (unpaid bills, disputes) ;
d) Prospecting, including email prospecting: developing commercial and marketing statistics, developing and sending promotional offers, email alerts to prospects and customers, private or professional, sending information about our new or existing services for professional clients ;
e) Management of evaluation and customer satisfaction surveys and user reviews ;
f) Contest management ;
g) Feedback management : When you post messages and reviews on the services or you contact us, for example with a question, problem, or comment, we collect information about you, including your name and the content of your request. If you contact our customer support teams, we will record and keep a record of your conversation for quality and training purposes and to answer your questions.

Information that you provide voluntarily

Registration information
The registration information that you provide when you create an account on immotop.lu allows us to grant you access to our services and provide them to you in accordance with our general conditions of sale.
We also use this information to authenticate your access to the services, to contact you, to hear your views, and to notify you of important changes or updates to our services.

Transaction information
Your transaction information (such as, for example, the information to be provided when entering a contest) enables us to process your request.

Comments and opinions
We collect all comments posted on our website so that we can answer your questions and/or requests, provide quality customer support, and resolve any problem related to our services.
We will also analyze your comments to improve our services and your customer experience.


Information we collect automatically

When you access our services, we may automatically collect certain information from your device, such as your IP address, MAC address, or device ID. In certain countries, including Europe, this information may be considered personal information under applicable data protection laws.

Activity information
We analyze your files, newsletter subscription, and details provided when creating a customer or user account or when registering for a contest. We allow you to access your personal file so you can easily reorganize your information.

Cookies and similar technologies
Like many other websites and online services, we use cookies and other technologies to keep a record of your interaction with our services. Cookies also help us manage a range of features and content. For more information on the types of cookies and similar technologies we use, why and how you can control these technologies, please check our special “Cookies” section.


Information we obtain from third-party sources

The immotop.lu website integrates the services of third-party applications allowing you to share content or services from our website. You have the option to oppose this sharing (see Cookies policy). The information collected allows us to access analytical reports so that we can tailor our services to the needs of our clients..

3. Legal basis of processing

For the purposes explained in point (2) :

a) Contractual obligation ;
b) Contractual obligation ;
c) Legitimate interest ;
d) Legitimate interest or consent (email alerts, newsletter) ;
e) Legitimate interest ;
f) Consent ;
g) Legitimate interest.

4. Contact forms and interaction

Your personal information is particularly collected via our contact form.
We use the information collected for the following purposes :

- Follow-up of your requests ;
- Information ;
- Statistics ;
- Contacts.

When you access our services, we may collect certain information automatically from your device. In certain countries, including Europe, this information may be considered personal information under applicable data protection laws.

For example :

- Activity Information : We collect information about your use of the services and information about you from the orders ;
- Cookies and similar technologies : We use cookies and similar tracking technologies to collect and use personal information about you (for example, your IP address, device ID, the browser type, and the time, the frequency, and the duration of your interaction with the services);
- Information collected for advertising and audience tracking purposes.

Links to third-party websites

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates or to several websites that may offer useful information to our visitors. We provide these links to you only for convenience, and the inclusion of a link does not imply endorsement of the relevant website by IMMOTOP. If you follow a link to any of these websites, please note that they have their own privacy policies, and we take no responsibility for those policies or those linked websites. Please check these policies before submitting any personal information to these websites. For more information on third-party services, please refer to section 6 of this policy.


5. Log files and cookies

We collect certain information through log files and cookies.
This mainly concerns the following information :

- IP address ;
- Operating system ;
- Visited pages and requests;
- Day and time of connection ;

The use of such files allows us to :

- Improve services and offer a personalized welcome ;
- Collect statistical data.

6. Data recipients

Your Personal Data will be communicated to the following recipients :

- Sales, marketing, accounting, and IT employees of Real Estate Media SA to manage customer relations, marketing, and the implementation of your services ;
- The agencies or private advertisers that you contact when you want to get in touch with them ;
- Internet users who would like to contact you when you post an advertisement on our website ;
- Our contests partners when it is necessary for them to contact you themselves to deliver prizes to the winners, for example ;
- Our business partners when this information is necessary for the implementation of our ancillary services if you are a real estate professional (Service Photos Pro, Social Connect, Hektor, Homepad, etc.).

We are also required to transmit your Personal Data to the following third-party services :

Google : https://www.google.com/intl/fr/policies/privacy/
Facebook : https://www.facebook.com/privacy/explanation
Twitter : https://twitter.com/fr/privacy
Linkedin : https://www.linkedin.com/legal/privacy-policy?_l=fr_FR
Pinterest : https://policy.pinterest.com/fr/privacy-policy
Instagram : https://help.instagram.com/833836199971426/?locale=fr_FR

7. Storage period

Your Personal Data is stored by IMMOTOP only for the period related to the purpose of exchanging communications (contacting us via our contact form) or until you unsubscribe from our newsletter, if you have subscribed to it (an unsubscribe link is available in every newsletter we send).

8. Right of objection, withdrawal, and transfer

You have the right to object, to delete your Personal Data, and to withdraw your consent. You can also request the transfer of your Personal Data.

The right of opposition is the opportunity provided to Internet users to refuse that their personal information be used for certain purposes mentioned during collection. You may express your objection to the processing of your personal information if we have a legitimate interest (or the interest of a third party) in doing so and there is a valid reason to object to the processing of the Data. You also have the right to object if we are processing your personal information for direct marketing purposes.

The right of withdrawal is the opportunity provided to users to request the deletion of their personal information. You may also request the deletion of your personal information when you have expressed your right to object to the processing of your Data (see above).

When you give your explicit consent to authorize the collection, processing, and transfer of your personal information for a particular purpose, you have the right to withdraw your consent for the processing of this Data at any time. Once we have received notice of your withdrawal of consent, we will no longer process your information for the purposes for which you have given your consent, unless we have a legitimate reason to do so.

You may request the transfer of your personal information on your behalf or on behalf of another controller in an electronic and structured format (right to data portability). This allows you to retrieve and transfer your Data in a usable electronic format.

9. Right of access and rectification

You may request access to your personal information (commonly known as a “Personal Data Access Request”). This request allows you to receive a copy of your personal information and to verify that we are lawfully processing this Data.

You may also request information about whether we have personal information about you and, if so, what information is available and why we are keeping/using it.

In addition, you may request that the personal information we have about you be corrected. This allows you to rectify any incomplete or inaccurate information we have about you.

10. Right of restriction

You may request the restriction of the processing of your personal information. This allows you to suspend the processing of your personal information, for example if you wish to establish the accuracy or the reason for the processing of the Data.

11. Requests for the exercise of rights

To request the exercise of your rights, you can contact us at the following email address dpo@luxgap.com.

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

We may ask you for this information to help us confirm your identity and to ensure that you observe your right to access this information (or to enforce any of your other rights). This is a security measure designed to ensure that your personal information is not disclosed to an unauthorized person. You are authorized to lodge a complaint with the National Data Protection Commission (Commission Nationale pour la Protection des Données “CNDP”) if you believe that your rights have been violated.

12. Security

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

- SSL (Secure Sockets Layer) protocol ;
- Access management – authorized person ;
- Backups ;
- Firewall.

We are committed to maintaining a high degree of confidentiality by integrating the latest technological innovations to ensure the confidentiality of your Data. However, since no mechanism provides maximum security, there is always a risk when it comes to using the internet to transfer personal information.

13. Cookies

Our cookie policy allows you to better understand the arrangements we make in terms of navigation on our website. It informs you about the cookies on our website and their purpose (1) and about the procedure to follow to configure them (2).

1. General information on cookies

This website may place cookies on the hard drive of your device (computer, tablet, mobile, etc.) to ensure smooth and optimal navigation on our website. This page describes what information they collect, how we use it, and why we sometimes need to store these cookies.

"Cookies" are small text files of limited size that are downloaded on your computer and allow us to recognize your computer, tablet, or mobile in order to personalize the services we offer and improve your experience.

The information collected through cookies does not identify you in any way. Cookies are used exclusively for our own needs to improve the interactivity and performance of our website and to provide you with content tailored to your interests. None of this information is communicated to third parties.

To better inform you about the information identified by cookies, you will find below the different types of cookies that can be used on the immotop.lu website, their names, purpose, and retention period.

2. Your cookie setting preferences

When you connect to the immotop.lu website, certain information relating to your browsing activity may be saved in files called "cookies."

The immotop.lu website uses tracking cookies as well as social cookies. You have the option to decline the deposit of these cookies via a button on the cookies banner.

However, some cookies do not contain any personal data that is not mandatory for their use and therefore do not require the explicit consent of the user. These are called functional cookies.

Every now and then, we test new features and make subtle changes to the way the website is structured. When we are testing new features, certain cookies may be used to ensure that you get a consistent experience on the website while making sure we understand which optimizations our users value the most.

We use the following cookies :
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