Privacy Policy for zeas.immo

Introduction

Welcome to zeas.immo, a real estate agency based in Luxembourg, focusing on the Hesperange commune. This Privacy Policy explains how we collect, use, disclose, and protect your personal data in compliance with the EU General Data Protection Regulation (GDPR) and Luxembourg data protection laws. Last updated: May 10, 2025.

Legal Framework

This Privacy Policy complies with:

  • The General Data Protection Regulation (EU) 2016/679 (GDPR)
  • The Luxembourg Law of 1 August 2018 on the organization of the National Commission for Data Protection (CNPD) and the general data protection framework
  • The Luxembourg Law of 1 August 2018 on the protection of individuals with regard to the processing of personal data in criminal matters and national security
  • The amended Luxembourg Law of 30 May 2005 concerning the protection of privacy in the electronic communications sector

Data Controller

zeas.immo, located at [full physical address], is the data controller responsible for your personal data. For inquiries, please contact us at info@zeas.immo or +352 [phone number].

Personal Data We Collect

We collect and process only the personal data necessary for our stated purposes, including:

  • Identity information: Name, address, identification documents
  • Contact information: Email address, telephone number, postal address
  • Property preferences: Search criteria, viewing history, property requirements
  • Financial information: For property transactions, including proof of funds, bank details for transactions, and financial status for rental applications
  • Communication records: Emails, calls, messages related to property inquiries
  • Technical data: IP address, browser type, device information when you visit our website
  • Property imagery: Photos of properties that may incidentally include personal items

How We Collect Your Data

We collect personal data through:

  • Direct interactions when you contact us about properties
  • Forms completed on our website
  • Property viewings and transactions
  • Automated technologies like cookies on our website
  • Third parties such as property portals where you’ve expressed interest

Purpose and Legal Basis for Processing

We process your personal data for specific purposes with corresponding legal bases:

  • Providing real estate services: Processing necessary for the performance of a contract or to take steps at your request before entering into a contract
  • Property management: Legitimate interests to manage properties effectively
  • Legal compliance: Processing necessary for compliance with legal obligations (anti-money laundering checks, tax reporting)
  • Service improvement: Legitimate interests to improve our offerings
  • Marketing communications: Consent-based processing for direct marketing

Data Retention Periods

We retain your personal data only as long as necessary:

  • Active client data: Throughout our business relationship and for 10 years afterward (Luxembourg commercial prescription period)
  • Property transaction records: 30 years (maximum limitation period under Luxembourg Civil Code)
  • Marketing data: Until you withdraw consent or for 3 years after our last interaction
  • Website usage data: 13 months maximum

Your Rights Under GDPR

You have the following rights regarding your personal data:

  • Right to access your personal data (Art. 15 GDPR)
  • Right to rectification of inaccurate data (Art. 16 GDPR)
  • Right to erasure (“right to be forgotten”) (Art. 17 GDPR)
  • Right to restriction of processing (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object to processing based on legitimate interests (Art. 21 GDPR)
  • Right to withdraw consent at any time for consent-based processing
  • Right to lodge a complaint with the CNPD or your local supervisory authority

To exercise these rights, please contact our Data Protection Officer at dragos@zeas.immo.

Data Sharing and International Transfers

We may share your data with:

  • Property owners when necessary for viewings or transactions
  • Service providers who support our operations (IT services, marketing)
  • Legal authorities when required by law
  • Notaries and financial institutions for transaction processing

For transfers outside the European Economic Area, we implement appropriate safeguards such as Standard Contractual Clauses approved by the European Commission.

Data Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encryption of sensitive data
  • Access controls and authentication measures
  • Regular security assessments
  • Staff training on data protection
  • Secure data storage systems

Special Categories of Data

We generally do not collect special categories of personal data. If such processing becomes necessary, we will obtain your explicit consent unless another legal basis applies.

Property Photographs and Visual Data

When photographing properties, we take measures to minimize capturing personal items or identifiable individuals. Before publishing any property imagery, we review and edit content to protect privacy.

Video Surveillance

If we use CCTV at our premises, cameras are positioned only in necessary areas with clear signage. Recordings are kept for a maximum of 30 days unless needed for a specific investigation and are accessible only to authorized personnel.

Cookies and Similar Technologies

Our website uses cookies and similar technologies to enhance functionality and analyze usage patterns. You can manage your preferences through browser settings. Essential cookies cannot be disabled as they are necessary for the website to function properly.

Children’s Privacy

Our services are not intended for children under 16. We do not knowingly collect data from children without parental consent.

Changes to This Policy

We may update this policy periodically to reflect changes in our practices or legal requirements. Material changes will be communicated to you, and the updated policy will be posted on our website with a revision date.

Data Protection Officer

We have appointed a Data Protection Officer who can be contacted at:

  • Email: dragos@zeas.immo
  • Phone: +352 [phone number]
  • Address: [full physical address]

Language

This policy is available in English, French, and German. The English version prevails in case of discrepancies.

Accountability and Compliance

We maintain records of our processing activities and conduct regular data protection impact assessments for high-risk processing. Our staff receives regular training on data protection requirements.

Complaints

For concerns about how we handle your data, please contact us first at dragos@zeas.immo. You may also lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) at www.cnpd.lu.

By using our services, you acknowledge that you have read and understood this Privacy Policy.