PRIVACY POLICY
LuxReal - Real Estate Association of Luxembourg a.s.b.l., is a Luxembourg non-profit organization with registered address at 38, Rue Arthur Herchen, L-1727 Luxemburg registered with the Luxembourg Trade and Companies Register under number F8097 (hereafter the “Organization” or “LuxReal” or “Us”).
LuxReal processes your personal data in accordance with the applicable legislation, including:
• Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”);
• The Act of 1 August 2018 on the organization of the National Data Protection Commission and the general data protection framework.
• The Act of 30 May 2005, as amended, concerning the processing of personal data in the electronic communications sector.
Our Organization undertakes to process personal data in a fairly and transparent way and based on valid legal grounds, obtained for specific lawful purposes, adequate, relevant, and not excessive; accurate and kept up to date; not held for longer than necessary, protected in appropriate ways and not transferred outside of the European Economic Area, unless adequate protective measures are in place.
Our Privacy Policy particularly covers the following issues:
1. WHO IS RESPONIBLE FOR YOUR PERSONAL DATA?
2. WHO IS CONCERNED?
3. WHAT KIND OF PROCESSING DO WE PERFORM AND WHY?
4. HOW DO WE OBTAIN YOUR PERSONAL DATA?
5. DO WE USE COOKIES?
6. WHO HAS ACCESS TO YOUR PERSONAL DATA? WHO WE SHARE YOUR PERSONAL DATA WITH?
7. HOW DO WE PROTECT YOUR PERSONAL DATA?
8. WHICH COUNTRIES DO WE TRANSFER YOUR PERSONAL DATA TO?
9. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
We reserve the right to update our personal data protection policy in line with any changes in legislation or in the way we treat your personal data. Every modification made will be notified on the Website and by email.
Please visit our website frequently to be aware of any changes and modification to our present policy.
1. WHO IS RESPONIBLE FOR YOUR PERSONAL DATA?
Your personal data is processed by LuxReal, acting as a data controller in respect of your personal data within the meaning of the GDPR.
For any concerns regarding your personal data feel free to contact Us, either by:
• Tel.:+352 621 130 779
• E-mail: info@luxreal.lu
• Postal address: 38 Rue Arthur Herchen, L-1727 Luxembourg
2. WHO IS CONCERNED?
This Privacy Policy seeks to provide you with an overview of the processing of personal data LuxReal is performing regarding the following data subjects:
• Visitors of our website http://www.luxreal.lu/ (the “website”);
• Members of LuxReal (“Personal Members”) or (“Supporting Members”);
• Any person contacting LuxReal by any means or through our website’s contact form;
• Participants to LuxReal’s events or sponsored by Us.
3. WHAT KIND OF PROCESSING DO WE PERFORM AND WHY?
The table below explains how we use your personal data, namely:
(i) The purposes for processing your personal data.
(ii) the categories of personal data being processed.
(iii) Data subjects impacted by the processing.
(iv) Legal basis on which the processing is based.
(v) Retention period during which your data is kept.
PURPOSES
DATA PROCESSED DATA SUBJECTS LEGAL BASIS RETENTION PERIODS
Daily Management of our Organization
PURPOSE
Administrative management of LuxReal including, the listing of members, new members and old members, management of annual fees and their recovery
DATA PROCESSED
Identification and contact data (name, first name, username, password, phone number, e-mail address, birthday, nationality)
Professional data (company, occupation, industry, address, zip code, city, country)
Contribution payment data (amount of the fee and payment date)
DATA SUBJECTS
Founding Members,
Members
New members
Old Members
Honorary Members
LEGAL BASIS
The processing is necessary for:
the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6. b) of the GDPR);or,
our legal obligation (Art. 6. a) of the GDPR) or,
our legitimate interests (Art. 6. f) of the GDPR) i.e. the interest of ensuring optimal management of LuxReal, including fees ‘recovery.
PURPOSE
Organization and promotion of LuxReal ’s activities, including management of events, sending of newsletters
DATA PROCESSED
Identification and contact data (phone number, e-mail address, country, zip, city, address, name, first name)
Professional data (company)
DATA SUBJECTS
Members of LuxReal
Participants to LuxReal’s events
LEGAL BASIS
Your consent (Art. 6 a) of the GDPR) or,
the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6. b) of the GDPR);or
your legitimate interests (Art. 6. f) of the GDPR) i.e. the promotion of our activities.
LuxReal's website activities
PURPOSE
Management of LuxReal’s website
DATA PROCESSED
Identification and contact data (name, first name, phone number)
Professional data (position, company, postal address, e-mail address)
DATA SUBJECTS
Board Members
Advisory Board Members list
LEGAL BASIS
The processing is necessary for: our legitimate interests pursued by LuxReal (Art. 6. f) of the GDPR) i.e. the promotion of our activities and legal structure.
PURPOSE
Registration form
DATA PROCESSED
Contact Details (first name, last name, Username, Phone, Email)
Additional information (Company, Occupation, Industry, Address, Zip, City, Country, Birthday, Nationality)
DATA SUBJECTS
Visitors
LEGAL BASIS
The processing is necessary for:
the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6. b) of the GDPR);
PURPOSE
USER Profile Page
DATA PROCESSED
Username
DATA SUBJECTS
Members
LEGAL BASIS
Your consent (Art. 6 a) of the GDPR)
PURPOSE
LuxReal’s events pictures
DATA PROCESSED
Pictures from events (gallery)
DATA SUBJECTS
Members
Participants
LEGAL BASIS
The processing is necessary for our legitimate interests pursued by LuxReal (Art. 6. f) of the GDPR) i.e. the promotion of our activities, or
Your consent (Art. 6 a) of the GDPR)
PURPOSE
Contact Form
DATA PROCESSED
Contact data (name, e-mail address)
DATA SUBJECTS
Visitors
LEGAL BASIS
Your consent (Art. 6 a) of the GDPR)
4. HOW DO WE OBTAIN YOUR PERSONAL DATA?
LuxReal collects your personal data:
• directly from you;
• when requesting membership to LuxReal;
• from LuxReal members and participants during our events;
• using certain features of the website and;
• use of our LinkedIn social network page.
5. DO WE USE COOKIES?
LuxReal uses cookies and similar tracking technologies to follow the activity on the website and hold information.
A cookie is a text file sent on the user’s browser and saved on the hard drive of its device when the user visit the website. It can be used by websites to make a user's experience more efficient.
LuxReal can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission.
You can at any time change or withdraw your consent to reject non-essential cookies. For more information, please refer to https://www.luxreal.lu/cookie-policy.
6. WHO HAS ACCESS TO YOUR PERSONAL DATA? WHO WE SHARE YOUR PERSONAL DATA WITH?
Personal data are processed by LuxReal with complete confidentiality to meet the purposes described in the table above.
LuxReal undertakes regarding the persons concerned to comply with an obligation of discretion and ensure that all its employees and collaborators act with the same reserve.
Certain of your personal data may be shared with entrusted third parties, such as :
- Our provider who manage our platform and data bases, located in the EU.
When required, we may also transfer your personal data to the local public authorities such as the Luxembourg Business Registers, to our lawyers, to the public bailiffs, to the police etc., to comply with the legal or regulatory requirements to which we are subject or to assert our rights or exercise them in Court.
7. HOW DO WE PROTECT YOUR PERSONAL DATA?
LuxReal implements appropriate technical and organizational measures to ensure an adequate level of security to prevent the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data that is transmitted, stored, or otherwise processed.
8. WHICH COUNTRIES DO WE TRANSFER YOUR PERSONAL DATA TO?
In principle, personal data will not be transferred to a third country outside the European Economic Area ("EEA") or an international organization.
However, if it would be necessary for the purposes defined in this policy, we may have to transfer your personal data to countries outside the European Economic Area, which may not offer the same level of data protection as the Grand Duchy of Luxembourg.
These third countries should be granted an adequacy decision from the European Commission to ensure the transfer has a sufficient level of protection in terms of data protection. If there is no adequacy decision, a transfer will only be possible if appropriate safeguards are put in place (e.g. binding corporate rules, standard data protection clauses, an approved code of conduct, or an approved certification mechanism). In the absence of the above mechanisms, transfers to a third country shall only take place if it is one of the exceptions listed in GDPR.
In any case, the processing is carried out in conformity with the GDPR requirements.
9. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
The GDPR provides you with specific rights according to the legal basis on which LuxReal bases the processing of your personal data. In this context, you have:
• A right of access: you have the right to obtain a confirmation that your personal data are processed or not. If your data are processed, you may have access to them and information about their processing. You may also request a copy of the data.
• A right of rectification: you have the right to obtain rectification of inaccurate or incomplete information about you that is processed by LuxReal.
• A right to erasure: you have the right to obtain the erasure of your personal data in the following situations:
(i) data are no longer necessary for the purposes for which they were collected;
(ii) you withdrew your consent where the processing is based on consent and there is no other legal basis for such processing;
(iii) you object to the processing of your personal data and there is no compelling legitimate reason justifying the processing;
(iv) data have been unlawfully processed;
(v) data must be erased to be compliant with a legal obligation.
• Right to restriction of processing: you have the right to obtain a restriction of the processing of your personal data in certain cases (e.g. contestation regarding the accuracy of the data, unlawful processing that leads to a request for a restriction of processing etc.).
When processing has been limited, personal data may, except in cases of storage, only be processed if:
- you have provided your consent in this regard; or
- we need it for the establishment, exercise and defence of legal claims; or
- the processing is necessary for the protection of the rights of other natural or legal persons; or
- processing is necessary for important reasons of public interest of the Union or of a Member State.
• Right to data portability. when we process your personal data with your consent or on the grounds of a contract, you have the right:
- to obtain the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit it to another provider of your choice; or
- to obtain from us the transmission of that data to another provider of your choice.
• Right to object: you have the right to object to the processing of your personal data, and LuxReal will cease such processing:
- when based on the public interest or legitimate interest. However, we may continue the processing if such processing is necessary to fulfil a legitimate interest or for the establishment, exercise or defence of legal claims; or
- when it is carried out for marketing purposes (including profiling in connection with such marketing).
If you believe that your data protection rights have been violated, you have the right to:
- lodge a complaint with the relevant supervisory authority, in the Member State in which the breach may have occurred, in which you have your permanent residency, or in which you are working; and/or
- bring an action with the competent court.
In Luxembourg the competent authority is the National Commission for the Protection of Data (the “CNPD”) (https://cnpd.public.lu/fr/particuliers/faire-valoir/formulaire-plainte.html).
To exercise your rights listed above, you can contact us at the following address:
• Tel.:+352 621 130 779
• Email: info@luxreal.lu
• Postal address: 38, rue Arthur Herchen, L-1727 Luxembourg