Privacy Policy

1) Introduction

At ELLE REAL ESTATE (hereinafter “we”), confidentiality and respect for privacy are essential matters. This Privacy Policy explains how we collect, use, share and protect your personal data when you browse our website, use our services or interact with us.

By using our website and/or contacting us, you acknowledge that you have read and understood this Privacy Policy.

2) Data Controller

The data controller responsible for the processing of personal data collected via the website [www.ellerealestate.lu] is:

ELLE REAL ESTATE

Legal form: Sàrls

Address: 5 Rue de la Reine, 2418 Ville-Haute, Luxembourg

Email: [contact@ellerealestate.lu]

Telephone: [+352 621 599 540]

Otherwise, any GDPR-related request may be addressed to: [contact@ellerealestate.lu]

3) Hosting and service providers (processors)

We use technical service providers (processors) for the hosting, maintenance and/or operation of the website.

Publisher / technical service provider

AR Digital (technical service provider / hosting provider – data processor)

19 Boulevard Marcel Cahen, L-1311 Luxembourg

Telephone: +352 691 243 016

Email: hello@ardigital.eu

AR Digital acts solely on our instructions, in accordance with a data processing agreement within the meaning of Article 28 of the GDPR.

4) Personal data collected and source of the data

We collect personal data:

directly from you (forms, emails, telephone calls, meetings, documents provided),
indirectly through your browsing activity (cookies, technical logs),
via partners where you have consented or where necessary (e.g. real estate portals, financing partners, notaries/banks acting on instruction).

4.1 Categories of personal data processed

A. Identification and contact data

Last name, first name, title
Email address, telephone number
Postal address (if provided)
Professional contact details (where applicable)

B. Data related to a real estate project

Type of project (purchase, sale, rental, investment)
Search criteria (surface area, location, budget, timeframe)
Information necessary to assess the project (e.g. household composition, constraints, preferences)

C. Financial data (where applicable)

Budget, borrowing capacity, solvency-related information
Information necessary for introductions or referrals (at your request)

You are invited to provide only the information that is strictly necessary. Sensitive data is not requested unless legally required or necessary for the processing of the file.

D. Transaction and invoicing data (where applicable)

Data required for invoicing and accounting obligations
History of communications and services provided

E. Browsing data

IP address, technical identifiers
Dates and times of visits, pages viewed
Browser type, language, operating system

F. Job applications (where applicable)

CV, cover letter, professional background, qualifications
Information voluntarily provided (photo, public social media profiles, etc.)

5) Purposes, legal bases and data retention periods

We process your personal data only when necessary and on a valid legal basis.

5.1 Management of requests and business relationships

Purposes

Responding to your requests (contact, valuation, visits, files)
Organising meetings, visits and follow-up
Managing communications and customer/prospect follow-up

Legal basis

Pre-contractual measures (Art. 6(1)(b) GDPR) when you request a service
Legitimate interest (Art. 6(1)(f)) in responding to and managing the relationship

Retention period

Prospects: 3 years from the last contact
Active files: duration of the relationship plus applicable legal retention periods

5.2 Real estate intermediation (sale / purchase / rental)

Purposes

Assessing your needs and proposing suitable properties
Managing visits, communications and negotiations
Creating and managing a transaction-related file

Legal basis

Pre-contractual measures / performance of a contract (Art. 6(1)(b))
Legal obligation (Art. 6(1)(c)), where applicable
Legitimate interest (Art. 6(1)(f)) in organising and securing the transaction

Retention period

Transaction files: 10 years (prudent reference for evidence and legal obligations) or according to applicable legal requirements
Litigation: duration of the dispute plus applicable limitation periods

5.3 Legal, accounting and tax obligations

Purposes

Compliance with legal and regulatory obligations (accounting, taxation and applicable regulations)

Legal basis

Legal obligation (Art. 6(1)(c))

Retention period

10 years (accounting/tax retention in accordance with applicable obligations)

5.4 Marketing and promotional communications

Purposes

Newsletters, news, offers, properties likely to be of interest
Commercial follow-ups

Legal basis

Consent (Art. 6(1)(a)) for newsletters and electronic marketing where required
Legitimate interest (Art. 6(1)(f)) for certain communications to existing customers/prospects, with the right to object

Retention period

3 years from the last contact
Until withdrawal of consent (newsletter)

You may unsubscribe at any time via the unsubscribe link or by contacting us directly.

5.5 Statistics, audience measurement and cookies

Purposes

Website operation
Audience measurement and content improvement
Security and detection of technical issues

Legal basis

Strictly necessary cookies: legitimate interest
Statistical/marketing cookies: consent

Retention period

Cookies: generally up to 13 months (depending on category)
Technical logs: proportionate duration, generally 6 to 12 months

5.6 Recruitment (where applicable)

Purposes

Management of job applications
Creation of a CV database (where accepted)

Legal basis

Pre-contractual measures (Art. 6(1)(b))
Legitimate interest (Art. 6(1)(f)) in maintaining a CV database, where relevant

Retention period

Unsuccessful candidates: 2 years from last contact (unless objection)

6) Data recipients

Your data may be accessed, strictly on a need-to-know basis, by:

Our authorised internal teams
Our service providers (hosting, maintenance, CRM tools, email services, analytics) acting as processors
Our partners involved at your request or for the execution of the mission (e.g. notaries, banks/brokers, portals), where relevant

We do not sell your personal data.

7) Transfers outside the EEA (EU/EEA)

Some service providers (e.g. email tools, analytics, CRM) may process data outside the EU/EEA. In such cases, appropriate safeguards are implemented (e.g. standard contractual clauses and supplementary measures where required).

8) Security

We implement appropriate technical and organisational measures, including access controls, user authorisation management, encryption where relevant, backups, monitoring and security updates.

9) Your rights

Subject to legal conditions, you have the following rights:

right of access
right to rectification
right to erasure
right to restriction of processing
right to object (in particular to marketing)
right to data portability (where applicable)
right to withdraw your consent at any time (without retroactive effect)

Exercising your rights

Contact: [contact@ellerealestate.lu]

We may request proof of identity where necessary.

Complaint

You may lodge a complaint with the Luxembourg supervisory authority:

Commission nationale pour la protection des données (CNPD) – Luxembourg.

10) Cookies

Our website uses cookies.

Necessary cookies: essential for website operation (no consent required).
Statistical cookies: audience measurement (consent where required).
Marketing cookies: advertising/retargeting (consent required).

You can manage your preferences via our cookie banner (if available) and/or your browser settings.

11) Links to third-party websites

Our website may contain links to third-party websites. We are not responsible for their practices and encourage you to review their privacy policies.

12) Policy updates

We may update this Privacy Policy to reflect legal, technical or operational changes. The date of the latest update appears at the top of this page.