Privacy Policy

Privacy Policy 

 

In order to address technological advancements, it is crucial to ensure the protection of privacy. This Privacy Policy outlines how AF Promotions (hereinafter referred to as "AF Promotions," "we," "our," "us") collects, uses, and processes your personal data ("Personal Data") in the context of your relationship with us. 

 

For the purposes of this Policy, the term "personal data" refers to any information relating to an identified or identifiable person, including all data that can be directly or indirectly attributed to an individual. AF Promotions is committed to complying with the current data protection laws and regulations, notably the General Data Protection Regulation 2016/679 ("GDPR"), which has been in effect since May 25, 2018. 

 

As the "Data Controller" under the GDPR, we oversee how your personal data is collected and the purposes for which it is used.

 

1. Personal Data We Collect: 

 

AF Promotions processes your personal data only if permitted by law or if there is an appropriate legal basis to do so. 

 

  1. When you fill out the contact form available on our website, we collect information such as your name, surname, email address, phone number, and the content of the messages you send us. Similarly, if you wish to subscribe to our newsletter or use our estimation tool, we need to gather your email address. 
  2. When you use our estimation tool and wish to request a physical estimation of your property by one of our agents, we collect the following information: your name, surname, email address, phone number, as well as the characteristics of the property to be estimated. 
  3. Furthermore, we collect your data when you contact us directly through any communication channel (e.g., when you send us an email containing a comment or feedback). 
  4. By providing this information, you expressly consent to the processing of your data by AF Promotions for the purposes outlined in section 2 below. If other purposes are applicable, they will be communicated at the end of each form. 

 

Finally, some information is collected automatically. When you access our site, we may automatically collect certain information from your device through log files. This information includes your IP address, MAC address, device identifier, as well as your device's operating system, pages visited, queries made, and the date and time of connection. The use of these files allows us to improve our site and gather statistical data.

 

The personal data we collect may include the following elements: 

 

  1. Identity data 
  2. Data related to your real estate assets

 

2. How Do We Use Your Personal Data? 

 

We process your personal data only for a specific purpose, and we only process relevant personal data to achieve that purpose. AF Promotions processes your personal data in the following cases: 

 

  1. to provide you with the information or services you have requested (e.g., responding to a contact request); 
  2. to communicate the results of the estimation of your real estate when you use our estimation tool; 
  3. to improve our website, products, and services; 
  4. to contact you regarding various AF Promotions events, including product updates and customer support; 
  5. to send you marketing information or our newsletter when you subscribe or unsubscribe, as well as to offer you personalized content. 

 

We will only use your personal data for the purposes for which we collected them, unless we reasonably believe that we need to use them for another reason, and that reason is compatible with the original purpose. If we need to use your personal data for unrelated purposes, we will inform you and explain the legal basis that allows us to do so.

 

3. Legal Basis for Processing Your Personal Data 

 

For the purposes outlined in point 2: 

 

  1. Legitimate interest (including sending a commercial offer or responding to a contact request); 
  2. Contractual performance. 
  3. Legitimate interest (anonymous browsing data based on logs). 
  4. Consent. 
  5. Consent (including sending the newsletter).

 

4. Sharing Your Personal Data 

 

We may use or disclose your personal data if we are legally required to do so or if we believe it is necessary to protect our rights and/or comply with current laws or regulations. 

 

In the context of our contractual obligations, we may share your personal data with specific trusted third parties. None of these third parties are based outside the Grand Duchy of Luxembourg, nor do they process your personal data outside of this country. If a third-party service provider processes personal data outside the EU/EEA in the course of our activities, the transmission will only occur if an appropriate level of data protection has been confirmed for the third country by the European Commission, or if other appropriate data protection safeguards are in place (such as binding corporate rules on data protection or standard contractual clauses). 

 

The designer of this site, our subcontractor Nextimmo Sàrl, stores your data on a secure server and uses it exclusively to present you with properties that match your search criteria.

 

5. Security of Your Personal Data 

 

We are committed to protecting your personal information and implementing appropriate technical and organizational security measures to prevent unauthorized or unlawful processing, as well as accidental loss, destruction, or damage. 

 

The personal information we collect is stored in a secure environment. Our employees are required to respect the confidentiality of your information. To ensure the security of your personal information, we implement the following measures: 

 

1) SSL Protocol (Secure Sockets Layer) 

 

2) Access management — authorized personnel only 

 

3) Backups 

 

4) Firewall 

 

We are committed to maintaining a high level of confidentiality by incorporating the latest technological innovations to ensure the protection of your data. However, it is important to note that despite our efforts, no security mechanism offers an absolute guarantee. Therefore, there is always some risk associated with using the Internet to transfer personal information.

 

6. Retention Period of Your Personal Data 

 

Your personal data is retained by AF Promotions only for the duration necessary to achieve the purpose of our communication exchanges (e.g., during contact via our contact form) or until you unsubscribe from our newsletter, if you are subscribed (an unsubscribe link is available in each newsletter sent to you).

 

7. Your Rights Regarding Your Personal Data 

 

As an individual, you have certain rights that you can exercise under specific circumstances. These rights include the right to: 

 

  1. Request access to your Personal Data; 
  2. Request the correction of your Personal Data; 
  3. Request the erasure of your Personal Data; 
  4. Request the restriction of the processing of your Personal Data; 
  5. Object to the processing of your Personal Data; 
  6. You have the right to request the transfer of your personal information, on your behalf or on behalf of another data controller, in an electronic and structured format (right to data portability). 

 

If you wish to exercise any of these rights, please contact us at afp.lu@yahoo.com. 

 

Your request will be processed within one month from the confirmation of your identity. No fee will be charged to access your personal information (or to exercise any other right). However, reasonable fees may be charged if your access request is manifestly unfounded or inappropriate. In some cases, we may also refuse to process your request, but we will explain the reasons for this refusal if applicable. 

 

To confirm your identity and ensure the protection of your personal information, we may request additional information from you. This security measure aims to prevent the disclosure of your personal information to an unauthorized person. 

 

If you believe that your rights are not being respected, you have the right to file a complaint with the National Data Protection Commission ("Commission nationale pour la protection des données" or « CNDP").

 

8. Cookies 

 

Our website does not use cookies that allow us to identify you.

 

9. Our Partners 

 

To ensure optimal service for users of our site, we rely on the following external services: 

 

Nextimmo: A hybrid agency implementing websites for partner real estate agencies. To learn more about the processes carried out by Nextimmo, click here. 

 

Apimo: Real estate software that allows us to optimize the management of client requests made on our site. For more information about the processes carried out by Apimo: https://apimo.pro/privacy/

 

Matomo: A secure, transparent, and GDPR-compliant analytics platform for measuring website audiences. To learn more about Matomo's privacy policy : https://matomo.org/privacy-policy/ 

 

MailChimp: An email delivery service for newsletter subscribers. For more information about MailChimp's privacy policy: https://mailchimp.com/fr/about/security/

 

Google Cloud: A remote data storage solution. To learn more about the processes implemented by Google Cloud: https://cloud.google.com/terms/cloud-privacy-notice?hl=en

 

10. Update of this Policy 

 

We reserve the right to modify, add, or delete parts of this Policy at any time. Any changes will be published on our website before these changes become effective. 

 

11. Data Protection Officer: 

 

Jérôme ADAM, Technical Manager of AF Promotions, afp.lu@yahoo.com