0. DUTY TO PROVIDE INFORMATION/DUTY OF TRANSPARENCY UNDER ARTICLE 13 EU GDPR (DIRECT COLLECTION) AND 14 EU GDPR (THIRD PARTY COLLECTION)
We should like to inform you how we deal with your personal data that we collect and store in the context of our contractual relationship. Personal data means data that relates to you in person and may be used to identify you:
name and contact details of the controller and of the controller’s representative
Purpose of data processing and legal basis
Pre-contractual measures for the conclusion and implementation of purchase and rental agreements for the real estate to be brokered or real estate valuations on the basis of a brokerage contract, service contract, agency agreement, search request, etc.
First and last name, residential address, telephone numbers, e-mail address, occupation, age/date of birth, marital status, household size, income and assets, domestic animals, registration number, tax number
The data is communicated in whole or in part to landlords, sellers, tenants, buyers, owners, agents, notaries, banks, authorities, suppliers, insurers, etc.
Duration of storage
The data will be stored, supplemented or updated as required for the purpose for which the personal data is collected and which you have requested, unless otherwise stipulated by statutory obligations, such as retention periods pursuant the money laundering law (5 years), commercial law (6 years), tax law (10 years) or the real estate broker and property developer ordinance (5 years).
Right of access to information
You have the right at any time to request access to information about your data that we hold.
Right to rectification or erasure of data
In the event that this data has been incorrectly or incompletely stored, you have the right to request rectification or erasure.
Right to restriction of processing
You may request that the processing of the data be restricted in the event that you are contesting the accuracy of the data collected, the processing is unlawful or the purpose of the processing has been fulfilled.
Right to withdraw consent
Insofar as the processing of your personal data takes place for a specific purpose on the basis of your consent, you may withdraw such consent at any time; however, the processing of your data will remain lawful until such time as you withdraw your consent.
Right to object to processing
You may object at any time to the processing of your personal data; the data will then no longer be processed.
Right to transfer data
You have the right to have data provided to you by the controller transferred to a third party.
Right to lodge a complaint
You have the right to lodge a complaint with a supervisory authority, if you consider that the processing of the data relating to you is unlawful.
Real estate portals, ad hoc advisers, contact forms, e-mails, print media, etc.
Automated decision-making (incl. profiling)
The data collected is processed in the programme easy2pilot. The programme enables real estate to be matched against your profile. The data you enter yourself under the "search" function on our website enables you to automatically receive suitable real estate offers via e-mail, as soon as a new property appears on our portal. Under "valuation", object-related data is collected on real estate to be valued and your contact data is then requested.
1. An overview of data protection
Data collection on our website
Who is responsible for the data collection on this website?
The data collected on this website are processed by the website operator. The operator's contact details can be found in the website's required legal notice.
How do we collect your data?
Some data are collected when you provide it to us. This could, for example, be data you enter on a contact form.
Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data such as the browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter our website.
What do we use your data for?
Part of the data is collected to ensure the proper functioning of the website. Other data can be used to analyze how visitors use the site.
What rights do you have regarding your data?
You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.
Analytics and third-party tools
You can object to this analysis. We will inform you below about how to exercise your options in this regard.
2. General information and mandatory information
Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.
Notice concerning the party responsible for this website
The party responsible for processing data on this website is:
Erlo Société Anonyme
Siège: 1 B, Wäistrooss, L-5450 Stadtbredimus
Adresse postale: B.P. 12, L-5501 Remich
Administrateurs délégués: Monika Lohmeier, Ernst Lohmeier
Tél.: +352 28 20 76 76 - Fax.: +352 28 20 76 78
Aut. Gouv. Luxbg.: 97746, 97746/C et 97746/D
RC: Luxembourg, B 84725
N° Matricule: 2001 2228 911
N° TVA: LU 18956483
The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).
Revocation of your consent to the processing of your data
Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
Right to file complaints with regulatory authorities
If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities. The competent regulatory authority for matters related to data protection legislation is the data protection officer of the state in which our company is headquartered. A list of data protection officers and their contact details can be found at the following link: https://cnpd.public.lu/en.html
Right to data portability
You have the right to have data which we process based on your consent or in fulfillment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.
SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser's address line when it changes from "http://" to "https://" and the lock icon is displayed in your browser's address bar.
If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.
Information, blocking, deletion
As permitted by law, you have the right to be provided at any time with information free of charge about any of your personal data that is stored as well as its origin, the recipient and the purpose for which it has been processed. You also have the right to have this data corrected, blocked or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.
Opposition to promotional emails
We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements with regard to sending promotional and informational materials not expressly requested. The website operator reserves the right to take specific legal action if unsolicited advertising material, such as email spam, is received.
3. Data collection on our website
Most of the cookies we use are so-called "session cookies." They are automatically deleted after your visit. Other cookies remain in your device's memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.
Server log files
The website provider automatically collects and stores information that your browser automatically transmits to us in "server log files". These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
These data will not be combined with data from other sources.
The basis for data processing is Art. 6 (1) (f) DSGVO, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
Should you send us questions via the contact form, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1)(a) DSGVO. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.
Registration on this website
You can register on our website in order to access additional functions offered here. The input data will only be used for the purpose of using the respective site or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject your registration.
To inform you about important changes such as those within the scope of our site or technical changes, we will use the email address specified during registration.
We will process the data provided during registration only based on your consent per Art. 6 (1)(a) DSGVO. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will continue to store the data collected during registration for as long as you remain registered on our website. Statutory retention periods remain unaffected.
Processing of data (customer and contract data)
We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us (master data). This is done based on Art. 6 (1) (b) DSGVO, which allows the processing of data to fulfill a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same.
Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.
Data transferred when signing up for services and digital content
We transmit personally identifiable data to third parties only to the extent required to fulfill the terms of your contract with us, for example, to banks entrusted to process your payments.
Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent.
The basis for data processing is Art. 6 (1) (b) DSGVO, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
4. Social media
Facebook plugins (Like & Share buttons)
Our website includes plugins for the social network Facebook, Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. The Facebook plugins can be recognized by the Facebook logo or the Like button on our site. For an overview of Facebook plugins, see https://developers.facebook.com/docs/plugins/.
If you do not want Facebook to associate your visit to our site with your Facebook account, please log out of your Facebook account.
Your privacy preferences with Twitter can be modified in your account settings at https://twitter.com/account/settings.
Our pages use Google+ functions. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Collection and disclosure of information: Using the Google +1 button allows you to publish information worldwide. By means of the Google+ button, you and other users can receive custom content from Google and our partners. Google stores both the fact that you have +1'd a piece of content and information about the page you were viewing when you clicked +1. Your +1 can be displayed together with your profile name and photo in Google services, for example in search results or in your Google profile, or in other places on websites and advertisements on the Internet.
Google records information about your +1 activities to improve Google services for you and others. To use the Google + button, you need a globally visible, public Google profile that must contain at least the name chosen for the profile. This name is used by all Google services. In some cases, this name may also replace a different name that you have used to share content via your Google account. The identity of your Google profile can be shown to users who know your email address or other information that can identify you.
Use of collected data: In addition to the uses mentioned above, the information you provide is used in accordance with the applicable Google data protection policies. Google may publish summary statistics about users' +1 activity or share it with users and partners, such as publishers, advertisers, or affiliate websites.
5. Analytics and advertising
This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses so-called "cookies". These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
Objecting to the collection of data
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics.
This website uses Google AdSense, a service for including advertisements from Google Inc. ("Google"). It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google AdSense uses so-called "cookies", which are text files stored in your computer that enable an analysis of the way you use the website. Google AdSense also uses so-called web beacons (invisible graphics). Through these web beacons, information such as the visitor traffic on these pages can be evaluated.
The information generated by cookies and web beacons relating to your use of this website (including your IP address), and delivery of advertising formats, is transmitted to a Google server in the US and stored there. This information can be passed on from Google to contracting parties of Google. However, Google will not merge your IP address with other data you have stored.
AdSense cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
You can prevent the installation of cookies by setting your browser software accordingly. Please be aware that in this case, you may not be able to make full use of all the features of this website. By using this website, you agree to the processing of data relating to you and collected by Google as described and for the purposes set out above.
If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) DSGVO. You can revoke consent to the storage of your data and email address as well as their use for sending the newsletter at any time, e.g. through the "unsubscribe" link in the newsletter. The data processed before we receive your request may still be legally processed.
The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.
7. Plugins and tools
Google Web Fonts
For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
If your browser does not support web fonts, a standard font is used by your computer.
This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/de/policies/privacy/.