Privacy Policy Real Estate Media Inc. 2018

Introduction: Data collections

At the time that our Internet site is accessed or our services are used, we collect two types of data:

- The data that you send us directly (personal information),
- The data that you send us indirectly, called “cookies” or similar technologies (navigation information).

1) Your personal information

The data that you send us directly includes your identity (first and last name) as well as you contact information (email address and telephone number). This information is necessary for the proper functioning of our Internet site when you desire to get in contact with a professional or individual advertiser and also when you want to create a user account. In the same way, when you post a real estate advertisement on our site, Internet users must be able to contact you either by email or telephone.

A) Your permission

We are allowed to create a data base made up of the personal information that you have sent to us, particularly at the time of the creation of your customer page, at the time of a real estate advertisement or again at the time of your contact with an advertiser with whom you want to get in contact again. You will be informed of the collection and processing of your personal information into our data base as well as the processing of your personal information under the conditions and according to the methods presented in this Privacy Policy notice.

We will also be able to collect your personal information at the time our services are used when you register on our site through a contest, when you subscribe to our newsletter or again when you register for email alerts. However, you must clearly give your permission by checking the corresponding box; otherwise we will not collect your personal information.

B) Collected personal information

The personal information that we are allowed to create at the time of your registration or your contact as an Internet user or an advertiser are the following:

- Your first and last names, your email address, your telephone number,
- Your passwords,
- Information related to your payment methods within the framework of payment by bank card,
- The dates of your participation in our contests as well as your mailing address if your participation requires it in order to send prizes by mail.

Within the framework of the creation and use of a user account, you have the ability to connect via your Facebook account or via Google+. Certain personal information that you have sent to these third-party services can be sent to us by these third-party services. You have the right to modify your sharing restriction parameters for personal information at the time of the creation of your account on www.immotop.lu through Facebook and Google+. These parameters can be changed at any time with these third-party services. We are committed to respect the privacy of your information as well as the parameters that you have set up. Using these third-party services to connect to www.immotop.lu is your personal choice and the applicable privacy policy for this connection personal information will be that of the third-party service used. In this case, we will request that you refer to the privacy policy of these third-party services; Real Estate Media Inc. will not be held liable for it. In the same way, we commit to not share your personal information that you have sent to us at the time of your registration or your use of our services with third parties.

C) Use of your personal information

The purpose for the collection of your personal information can take several forms:

The management of your customer or user account to manage:

- Putting your advertisements online and updating them,
- Your invoices,
- After-sales service, claims or even carrying out satisfaction surveys,
- Your requests for the right of access to correction or dispute,
- Non-payment or potential lawsuits,

Putting prospecting or loyalty programs in place:

- Developing commercial and marketing statistics,
- Developing promotional operations for prospects and customers, whether individual or professional,
- Developing individual and professional customer satisfaction surveys as well as obtaining the opinions of users,

Adapting our content to your profile:

- For the purpose of offering you content such as articles, contests, promotions or advertisements corresponding to the personal information that you have sent to us (your country most of the time),
- For the purpose of personalizing our communications on your behalf, in our newsletter for example.

D) Where your personal information is sent

Your personal information will be sent, in certain cases, to:

- Agencies or private advertisers which you contact when you wish to have a business relationship with them,
- Internet users who desire to contact you when you post an advertisement on our site,
- Our contest partners when it is necessary for them to contact you themselves in order to give out prizes to the winners, for example,
- Our business partners when this information is necessary for putting our accessory services in place if you are a real estate professional (Services Photos Pro, Social Connect, Hektor, Homepad, etc.),
- The business, marketing, accounting and technology employees of Real Estate Media Inc. in order to manage customer relations, marketing and putting our services in place.

E) Prospection by email

When you create a user account or at the time of your subscription to certain ones of our services (contests, email alerts, newsletter, etc.), we are allowed to offer to you:

- Our newsletters
- Our email alerts corresponding to your research criteria,
- Our promotional offers within the framework of the publication of an advertisement for an individual advertiser,
- Our promotional offers and information on our new or existing products for our professional customers.

As an individual user of our services, you must clearly indicate that you accept this type of solicitation by checking the appropriate box. After you accept, you have the right to stop receiving this information at any time. In this case:

- You can cancel your subscription to newsletters by clicking directly on the unsubscribe link at the bottom of the newsletter.
- You can stop receiving email alerts by clicking on the unsubscribe link at the bottom of the latest email alert received. If, in spite of all this, you continue to receive email alerts, we request that you verify that you have not subscribed to several email alerts and to inactivate all of them if so. If the email alerts continue after that, please send us an email at support [at] immotop [dot] lu containing the email address where you are receiving the alerts.

F) Your rights

You have various rights concerning your personal information:

- The right of information
- The right of access
- The right of correction, dispute and suppression

To exercise your rights you can contact us by email at support [at] immotop [dot] lu or by mail by sending a signed letter to the following address:

Real Estate Media SA
70, rue de Belval
L-4024 Esch-Sur-Alzette
LUXEMBOURG

For each of these methods of communication, please send us the necessary information with a photocopy of your identity document as well as your signature at the bottom of your request. Do not forget to give us an email or postal address allowing us to contact you. Real Estate Media Inc. has a legal time frame of 1 month from the date it was received to reply to you request.

2) Your navigating information

A) What is a cookie?

Cookies or similar technologies are sets of data that we are allowed to collect without you communicating them to us. This data consists of your navigating information on your device (computer, tablet, smartphone, etc.) when you use our Internet site. Cookies are created at the time of your navigation to a dedicated space on your device. Information contained in this file can only be read or modified by its sender. Cookies allow, among other things, Real Estate Media Inc. to create statistics on the number of views of the site www.immotop.lu, to retain your connection information or to host you.

This collection of information is not imposed upon you, except in the case where cookies are necessary to the proper functioning of our site, as stipulated in the General Rule on the Protection of Data, which goes into effect on May 25, 2018.

B) Cookies that we send out

At the time our services are used or at the time of your connection to our site, it is possible that we will install cookies on your device according to your preferences that you have indicated concerning cookies.

These cookies allow us:

- to collect Personal Data related to your device,
- to recognize your device at the time of your next connection to our site or use of our services.

The Personal Data in question is detailed in Part 1)B) of this document.

C) The purpose of these cookies

i) Technical cookies

Technical cookies can allow us:
  • to improve your user experience, particularly in the following ways:
    • by adapting the presentation of our site www.immotop.lu to the display preferences of your device, such as the choice of language, for example,
    • by pre-filling the connection fields for your user account with the personal data that you filled in at the time of your registration through the registration form,
    • by putting certain pages in cache to make access to these pages more rapid.
  • to secure your user account by requesting that you reconnect after a certain lapse of time of inactivity.
Suppression of these cookies will not prevent you from navigating on our Internet site or from using our services. However, this action is likely to alter your user experience or to interfere with the normal use of our site and of our services.

ii) Advertising cookies

Advertising cookies allow us to suggest to you advertising content targeted at what you are interested in, whether on our Internet site, our services, or services offered by third parties with whom we work.

The use of these advertising cookies allows us to limit the number of times that you are exposed to the same advertising content, but also to measure the effectiveness of advertising campaigns.

Suppression of these cookies will not prevent you from navigating on our Internet site or from using our services. However, this action does not result in the suppression of the display of advertising content; it applies to the sending of non-targeted advertising content.

iii) Viewer measurement cookies and analytical cookies

Viewer measurement cookies allow us to measure and determine the statistics related to visits to our Internet site and our services (number of visits, number of unique visitors, time of connection, number of pages viewed, etc.).

Analytical cookies allow us to establish statistics related to the use of our site and our services, such as the pages visited or even the route taken by the user. The use of these analytical cookies allows us to improve the user-friendliness of our site and of our services. It also allows to suggest to you targeted editorial content, corresponding to what you are interested in. These cookies also allow us to identify potential navigation problems.

Suppression of these cookies will not prevent you from navigating on our Internet site or from using our services. However, this action allows for the sending of non-adapted editorial content.

D) Where collected Navigation Information is sent

The Navigation Information that we collect from cookies sent from our site and our services are sent to the company Real Estate Media Inc. as well as to the real estate portal IMMOTOP.LU (www.immotop.lu), which is used by it.

E) Connecting up personal data and cookies

We may be led to combine your Personal Data and your Navigation Data in certain instances:

When you access our services through your User Account:

- to offer you targeted editorial content, corresponding to what you are interested in, on all the devices that you use,
- to offer your targeted advertising content, corresponding to what you are interested in, on all the devices that you use.

At the time of your communication actions sent by email:

- to offer you promotional materials likely to interest you within the framework of the publication of your real estate advertisements on our Internet site as an individual advertiser,
- to suggest to you that you renew the publication period of your advertisement when it comes to an end or to inform you of options available to you to improve the effectiveness of your advertisement,
- to give you the opportunity to participate in our contests in the event that you have expressed an interest in being informed of their existence,
- to have our newsletters sent to you in the event that you have expressed an interest in receiving them.

F) Cookies sent by third parties

Cookies are allowed to be sent and used by third-party applications on our Internet site and in our services, or in advertising and editorial content inserted on our advertising pages. These third parties may collect certain navigation information, without being able to identify you: navigation information allows them to adapt their advertising content to your profile (age, location, etc.).

You can opt to refuse the use of these cookies on your device. In this case, neither Real Estate Media Inc. nor our partners will be able to collect your Navigation Information collected by these cookies.

The sending and the use of cookies by third parties are regulated by their Privacy Policy. We suggest that you become aware of their regulations on this subject and we are informing you of the method by which you can make your choices in the area of cookies.

i) Cookies sent by third-party applications

We are allowed to integrate into our site and services third-party applications allowing you to share cotent coming from our Internet site or services. In particular with the sharing functions of social networks such as Facebook, Twitter, LinkedIn, Google+, etc. Google+, etc.

Social networks having sharing buttons are allowed to identify you from the moment you are connected to any of these networks on your device and you use our site and services, even if you do not click on the share button. Real Estate Media Inc. is not able to act on or to control the way in which social networks act to collect potential Navigation Information or Personal Data.

In order to be acquainted with the Privacy Policy of these social networks and to indicate your preferences concerning the collection of your Navigation Information and Personal Data, please click on the URL of the social network in question:

- 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

ii) Cookies sent by content posted on our advertising pages by third parties

The advertising content included on our advertising pages are likes to contain cookies sent by third parties, whether it is the advertiser or a third-party service provider working for the advertiser (communication companies, advertising companies, viewer measurement companies, etc.) which have integrated advertising cookies into the advertiser’s content.

During their period of validity, cookies can allow the advertiser or the service provider working for the advertiser:

- to send out advertising content to advertising pages designated for that purpose,
- to collect Navigation Information related to your device,
- to identify your device at the time of later navigations of the sites or services on which the cookies had been posted by the advertiser or by the service providers working for the advertiser. This allows the advertiser or the service providers working from the advertiser to adapt the advertising content sent out on these sites and services other than the site www.immotop.lu and its services.
- to carry out viewer measurement and to create statistics from these measurements (number of displays, number of clicks, etc.).

Cookies posted by third parties are subject to the Privacy Policy of these third parties; we suggest that you become aware of them.

F) Your choices in the area of cookies

You can accept or refuse the uploading of cookies to your device at any time, by following the URL links that we have provided to you or by choosing directly with your Internet browser.

i) Viewer measurement cookies and analytical cookies

Viewer measurement cookies and analytical cookies are integrated into our site www.immotop.lu and our services by businesses. If you have not given permission for our site and our services to record cookies on your Internet browser in order to carry out viewer measurement, you can click on these deactivation links or forms which will register a deactivation cookie for viewer measurement cookies on your Internet browser:

- Google Analytics : https://tools.google.com/dlpage/gaoptout
- Gemius : http://optout.hit.gemius.pl/removeEN.php (CIM Metriweb)
- Bing : https://advertise.bingads.microsoft.com/fr-fr/ressources/politiques/refuser-optimisation
- Google Ads : https://support.google.com/ads/answer/2662922?hl=fr
- Criteo : https://www.criteo.com/fr/privacy/

The site Ranks.fr developed by Kiwax.fr is also a possible resource. To apply your right of refusal, you can let them know directly through their contact form by following the link:http://www.ranks.fr/fr/contact?m

ii) Advertising cookies

We suggest that you visit the site https://www.youronlinechoices.com to become aware of the registered companies which give you the right to refuse or to accept cookies used by these companies for the purpose of adapting the advertising content on your device to your Navigation Information: http://www.youronlinechoices.com/fr/controler-ses-cookies/

This platform will not block the displaying of advertising content, but will block the technologies allowing the sending of targeted advertising from the Internet sites that you view.

Advertising cookies are likes to be sent by third-party companies for purposes of behavioral advertising. For more information on their methods as well as to exercise your options in the area of advertising cookies, you can click on the following links:

- DoubleClick for Publisher : https://adssettings.google.com/u/0/authenticated
- Google Ads : https://support.google.com/ads/answer/2662922?hl=fr
- Bing : https://advertise.bingads.microsoft.com/fr-fr/ressources/politiques/refuser-optimisation
- Criteo : https://www.criteo.com/fr/privacy/

G) Your choices in the area of cookies via your Internet browser

You can configure your Internet browser so as to accept or to refuse the placing of cookies on your device. The refusal may be systematic or only be for certain senders of your choice.

i) Acceptance of cookies

In the event that your Internet browser is set up to accept the placing of cookies on your device, the cookies integrated into Internet pages that you have viewed will be systematically placed on your device.

ii) Refusal of cookies

As stated above, you can occasionally or systematically refuse the placement of cookies via your Internet browser. However, we would like to draw your attention to the fact that refusing the placement of technical cookies on your device is likely to impair your experience on our Internet site, that is, blocking the use of certain services which these cookies allow for. The Real Estate Media Inc. company shall not be held liable for any malfunction linked to the voluntary deactivation of technical cookies on your part.

iii) Making choices in the area of cookies via your Internet browser

To exercise your options in the area of cookies via your Internet browser, please become aware of the information pages of these browsers, which will explain to you what steps to take:

- 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
- Opera : http://help.opera.com/Windows/10.20/fr/cookies.html

3) Security of data

Real Estate Media Inc. commits to take all necessary measures in order to ensure the security of stored data as well as to make them inaccessible to non-authorized third parties.

To confirm the publication of your advertisement as an individual, you can choose to pay by bank card. Payment by bank card is secure and encrypted.

The site www.immotop.lu is completely subject to the https:// protocol, which allows for the security of the use of the Internet site as well as all information that you may provide.

A) How long your data is kept

Data is stored in our data base for a period of one year after your last business transactions with our Internet site and are kept for a period of 3 months in order to meet any legal obligations in the matter.

B) Person in charge of data processing

The general manager of the site www.immotop.lu is responsible for all questions related to privacy and the protection of your private data. To pose your questions you may send an email to privacy [at] immotop [dot] lu

All employees at Real Estate Media SA are required to respect the confidentiality and privacy of all personal data to which they might have access.

For all the requests listed above, all you have to do is send your official request, together with proof of your identity (copy of your identity card) to :

Real Estate Media S.A.
70 rue de Belval
L-4024 Esch-sur-Alzette
privacy [at] immotop [dot] lu