Data controller
The data controller is Team Immo S.à r.l., trading as Team Real Estate, whose registered office and contact details are given in the legal notice. For any question about your data, write to the e-mail address given there.
Data processed
- Identity and contact details: surname, first name, e-mail address, telephone number.
- Your project: the message sent, the property concerned, the time frame of your project, viewing or appointment requests.
- Online valuation: the address and features of the property, and the result of the valuation.
- Telephone verification: the number, the code sent by text message and the result of the verification.
- Website assistant: the content of the conversation and any information you choose to give.
- Newsletter: the e-mail address, the date and proof of your subscription.
- Technical data: connection logs needed for the security of the website.
Please do not share sensitive data (health, opinions, etc.) in free-text fields or with the assistant.
Purposes and legal bases
- Answering your contact, information or viewing requests: steps taken at your request prior to entering into a contract (Article 6(1)(b) GDPR).
- Carrying out the online valuation and sending you your report: steps taken at your request prior to entering into a contract (Article 6(1)(b)).
- Verifying your telephone number by text message: the agency’s legitimate interest in preventing erroneous or abusive requests (Article 6(1)(f)).
- Contacting you again about your real estate project: your consent, given by ticking the box provided (Article 6(1)(a)).
- Sending you the newsletter: your consent, confirmed by e-mail (Article 6(1)(a)).
- Running the website assistant: your request and the agency’s legitimate interest in answering you quickly (Article 6(1)(b) and (f)).
- Measuring website traffic anonymously and keeping the website secure: the agency’s legitimate interest (Article 6(1)(f)).
- Complying with legal obligations, in particular accounting and, where applicable, anti-money laundering obligations: legal obligation (Article 6(1)(c)).
No decision producing legal effects concerning you is taken solely on the basis of automated processing: the online valuation is indicative and an agent remains your contact.
Recipients
Your data is intended for authorised members of the Team Real Estate team. It is also processed on the agency’s behalf and according to its instructions by processors bound by a contract compliant with Article 28 GDPR:
- the publisher of the agency’s real estate management software (Apimo);
- the providers sending e-mails and text messages;
- the provider of the artificial intelligence model used by the website assistant;
- The host of the website and of the audience measurement tool, on OVHcloud servers located in Strasbourg (France).
Your data is never sold. It may be disclosed to the authorities where required by law.
Transfers outside the European Union
The website and its data are hosted in France, within the European Union. Where a provider, in particular the provider of the conversational assistant, processes it outside the European Economic Area, the transfer is covered by an adequacy decision of the European Commission or by its standard contractual clauses. A copy of these safeguards can be obtained on request.
Retention periods
- Contact, viewing and valuation requests: three years from our last exchange, unless a contractual relationship is ongoing.
- Newsletter: until you unsubscribe; proof of consent is then kept for the applicable limitation period.
- Text message verification codes: a few minutes; the result of the verification is kept with the valuation request.
- Accounting and contractual documents: for the periods required by law.
- Technical logs: for a limited period, as needed for the security of the website.
Your rights
You have the right of access, rectification, erasure, restriction of processing, data portability and objection, under the conditions laid down in Articles 15 to 21 GDPR. Where processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before; every newsletter includes an unsubscribe link.
To exercise your rights, write to the e-mail or postal address given in the legal notice. Proof of identity may be requested if there is reasonable doubt about your identity. We will reply within one month, which may be extended by two months for complex requests.
Complaint to the CNPD
If you believe that the processing of your data does not comply with the regulations, you may lodge a complaint with the National Data Protection Commission (CNPD), 15, boulevard du Jazz, L-4370 Belvaux, cnpd.public.lu.
Security
The agency implements appropriate technical and organisational measures to protect your data: encrypted connection (HTTPS), back-office access restricted to authorised persons and protected by authentication, backups and access monitoring.
Minors
The website is intended for adults. It is not designed to collect data from minors under sixteen.
Changes to this policy
This policy may change, in particular to reflect new services or changes in the regulations. The date of the last update is shown at the top of the page.