Privacy and Personal Data Protection Policy

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 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.

Applicable principles to the Personal Data Treatment  Back to top

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.

Type of users  Back to top

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.

Purpose and legal basis of the Treatment  Back to top

The personal data provided by Users through the use of the Site and App, will be processed for the purposes described below:

  1. Service supply for Simple Users:
    1. In order to provide certain services such as saving listings, saving a search and receiving information on new listings automatically, the User must register through the Site and App. The data necessary for the Registration are limited to the provision of:
      • Name
      • Surname
      • Email address
      • Phone number
    2. The User, by accessing his personal section present on the Site and App (hereinafter "User Profile"), may provide additional personal data as additional information (eg date of birth, gender, residence) that will be collected by the Holder if provided.
  2. Supply of services of Contact Advertisers and Research Forwarding:
    1. To enable Advertisers to provide the User with the information they require regarding the properties, the Advertisers Contact service allows the User to forward its personal data to real estate agencies, construction companies, other companies and real estate professionals and private users who advertise real estate listings.
    2. In order to simplify Users in their real estate search, the Search Forwarding service allows to forward the searches made by the User to real estate agencies and other competent companies and professionals in the search area.
  3. Information, promotional and profiling activities:

    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:

    • "I would like to receive information and promotional notices"
    • "I would like to receive the IMMOTOP.LU News newsletter"

    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.

  4. Service provision for Professional Users:

    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:

    • Name
    • Surname
    • Company name
    • Municipality
    • Email address
    • Phone number

    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.

Methods of Processing and Storage of Personal Data  Back to top

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

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.

Recipients of Personal Data  Back to top

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.

Transfer of Data to a Third Country or to an International Organization  Back to top

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.

Browsing Data Collection  Back to top

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.

Information about Cookies, Search Engines and Position Data  Back to top

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.

Rights of the data subject  Back to top

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.

  1. confirmation of the existence or not of personal data concerning him, even if not yet recorded, in a concise, transparent, intelligible and easily accessible form, with simple and clear language;
  2. the indication:
    1. of the origin of the personal data;
    2. of the purposes and methods of treatment;
    3. of the legitimate interests pursued by the Data controller or third parties;
    4. of any recipients or categories of recipients of the personal data;
    5. any intention of the data controller to transfer personal data to a third country or an international organization;
    6. of the period of storage of personal data;
    7. of the logic applied, as well as the importance and the expected consequences of this treatment for the person concerned, in the case of processing carried out with the aid of electronic tools in the context of an automatic process of collection and/or profiling;
    8. of the identification data concerning the Data controller, Subcontractors, any designated Representative and the Data Protection Officer (so called DPO);
    9. the subjects and categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or appointees;
  3. the possibility of proposing a complaint to a supervisory Authority;
  4. the updating, rectification or, when interested, integration of the data;
  5. the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including those whose storage is not necessary in relation to the purposes for which the data have been collected or subsequently processed;
  6. the limitation to the processing;
  7. the portability of personal data concerning him to another Data controller;
  8. revocation of the processing;
  9. the attestation that the operations mentioned in the letters a) and b) have been brought to the attention, even with regard to their content, of those to whom the data have been communicated or diffused, except in the case where such fulfillment proves impossible or involves a manifestly disproportionate use of resources with respect to the protected right;
  10. the opposition, in whole or in part, for legitimate reasons, to the processing of the personal data concerning him, even if pertinent to the purpose of the collection.

Data Controller and Data Protection Officer  Back to top

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

Data Protection Officer (DPO):
Luxgap Sàrl
2, Rue de l’Ecole, L-8376 Kahler Garnich, Luxembourg

Changes  Back to top

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.