BPI Real Estate Luxembourg sa, whose registered office is located at 8008 Strassen, 2 route d'Arlon (Luxembourg), registered with the Trade and Companies Register under number B105237 (hereinafter "BPI" or "we"), is responsible for processing the personal data of its clients and prospects, visitors to the websites it operates and contact persons with its partners and suppliers (hereinafter "you").
This policy sets out how and for what purposes BPI collects personal data, what data it processes, who has access to it, how it protects it, how long it keeps it and the rights of the persons concerned, in accordance with the applicable regulations on the subject, in particular the European General Regulation on Data Protection (GDR).
The fundamental principle is that we only collect and process personal data if :
• we have your agreement ;
• These data are necessary for us to conclude and/or execute a contract with you ;
• we had to comply with a legal or regulatory obligation (e.g. obtaining proof of your identity and bank account number in the context of anti-money laundering legislation) ;
• and/or this data is necessary for the pursuit of our legitimate interests and/or those of third parties (e.g. the promotion of our real estate projects and/or those of partners, as well as the organisation of promotional events), insofar as your interests or fundamental rights and freedoms do not take precedence over these.
This can be done in various ways, for example when you visit our website, when you request information from us, either via the Internet, by telephone or by other means (estate agent, request for an offer, request for a visit, etc.), when you fill in a form, when information is communicated to us indirectly (via third parties or third-party websites), when you sign an agreement with BPI, etc.
The data processed varies depending on the case. This may include, but is not limited to :
• identification data, such as your surnames and first names ;
• contact data such as your email address and telephone number ;
• personal details, such as household composition, gender, language and marital status ;
• a copy of your identity card ;
• of photos and audio-visual recordings ;
• information on the real estate projects you are interested in, such as the location in question as well as the planned investment amount ;
• information on the type of interest (investor, family home, etc.) that you have in BPI and its projects and on your participation in the events that we organise, as well as those of our partners.
We collect this information:
• to offer you services corresponding to your request and/or visits to our projects, to notify you of open days and/or offer you other projects that might correspond to your needs ;
• for the drawing up and execution of an agreement ;
• to respond to a request for information ;
• for the follow-up of your file, the sending of invoices, the collection of payments and/or the management of possible litigation ;
• to improve our products and services by taking into account your comments on current, past and future real estate projects, including audience analysis and your possible participation in the events we organise.
In general terms
We collect data for research purposes in order to better understand our clients and adapt our services accordingly.
To do this, this site uses "cookies", i.e. small text files placed on your computer.
Cookies are technically necessary, at least partially, to ensure smooth communication between your computer and our site. However, they can also be useful - for example for saving your preferred settings - and certain data can be transmitted to the site to evaluate and improve its operation.
In particular, with regard to the Google Analytics feature :
• This is a Google service that works on the basis of cookies and aims to analyse the use of a website and then to offer services and functionalities related to this use ;
• The data collected in this way is generally transferred to a Google server in the United States, where it may be stored. In order to protect the personal nature of the data collected, your IP address is abbreviated by Google before you leave the European Union or other treaty countries within the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA before being abbreviated ;
• Google guarantees that the IP addresses transmitted by your server as part of Google Analytics will not be combined with other Google data. In particular, you can prevent the data collected by the cookie about your use of the website (including your IP address) from being sent to Google and processed further by downloading and installing the plug-in available for your browser on your computer via the following link: https://tools.google.com/dlpage/gaoptout?hl=fr.
We pass on these data :
• to our own services and, where applicable, to our service providers for the fulfilment of our missions and/or for trade promotion activities ;
• within the companies of the CFE/BPI group and/or to third parties with whom BPI works on real estate projects - such as real estate agents or other real estate development companies - as well as in the event of a possible takeover or expansion of our activities, and to whom we ask to comply with the regulations to the extent necessary for the execution of your contract with us and/or the pursuit of our legitimate interests and those of third parties ;
• to the competent authorities in accordance with the applicable regulations, such as judicial and/or tax authorities.
We never resell your personal data.
In principle, the processed data is not transferred outside the European Union, except in very limited circumstances, in order to comply with a legal or regulatory obligation or when it is necessary to carry out the mission entrusted to us and/or to defend or protect the rights of BPI and those of the persons concerned.
BPI undertakes to deploy its best efforts to protect this data on the one hand by human means, and on the other hand by technical means (computer protection). BPI nevertheless draws your attention to the fact that no absolute guarantee of security, particularly on the Internet, can be guaranteed.
If you visit other websites via the BPI website and the hyperlinks contained therein, it is your responsibility to check their privacy/data protection policies. BPI does not assume any obligation in this respect and therefore declines all responsibility for the use of your personal data by these websites.
We do not keep personal data longer than is necessary for the purposes for which it was collected, taking into account the applicable statute of limitations and legal retention obligations. If you have expressed an interest in one of our real estate projects and/or if you have acquired one, we keep your contact data to keep you informed about our activities and new projects as long as you do not object.
In compliance with the applicable legal conditions, you have the following rights :
• access them, ask for any explanation as to the purpose of their collection and processing, transmit them to you ("right of portability") ;
• rectify, complete and/or update them ("Right to Accuracy") ;
• request their deletion ("right of oblivion") except for what is indispensable to us during the execution of the contract or for the respect of our legitimate interests or the law ;
• oppose their treatment in certain cases ;
• request a limitation of treatment in cases covered by the law ;
• withdraw your consent for their use where such use is effectively based on your consent.
To exercise any of the aforementioned rights, you may contact us at any time by sending your request, dated and signed with proof of your identity, by post to the above-mentioned address or by email to email@example.com.
You also have the right to file a complaint with the National Commission for Data Protection - 15, Boulevard du Jazz L-4370 Belvaux.