1. Who are we?
BPI Real Estate Luxembourg SA, registered office 2 route d’Arlon, 8008 Strassen (Luxembourg), registered with the Luxembourg Trade and Companies Register under number B105237 (hereinafter “BPI” or “we”), is responsible for processing the personal data of its clients and prospects, of visitors to the websites it operates, and of all contact persons at its partners and suppliers (hereinafter “you”).
This policy sets out how and why BPI collects personal data, which data it processes, who has access to the personal data, how BPI protects them, how long it retains these data and sets out the rights of the persons concerned, in accordance with the applicable regulations, specifically the European General Data Protection Regulation (GDPR).
2. The legal framework for processing this information
The basic principle is that we collect and process personal data only if:
we have your agreement;
we need this information for concluding and/or fulfilling a contract with you;
we have to comply with a legal obligation or regulation (e.g. obtaining proof of your identity and bank account number under anti-money laundering legislation);
and/or this information is required in order to pursue our legitimate interests and/or those of third parties (e.g. the promotion of our real-estate projects and/or those of partners, and the organisation of promotional events), provided that your interests or fundamental rights and freedoms do not prevail over these interests.
3. How do you provide us your personal data?
This may happen in a variety of ways, for example when you visit our website, when you ask us for information, through the internet, by phone or by any other means (real-estate agent, request for a quote or for a visit, etc.), when you fill in a form, when we receive information indirectly (via third parties or third-party websites), when you sign an agreement with BPI, and so on.
4. The personal data concerned
Which data we process depend on the circumstances. This may include, but is not restricted to:
identification details, such as your first name and surname;
contact details, such as your email address and telephone number;
personal details, such as household composition, gender, language and civil status;
a copy of your I.D. card;
photographs and audio-visual recordings;
information on the real-estate projects you are interested in, such as their location and the investment being considered;
information on the nature of the interest (investor, family home, etc.) you have shown in BPI and its projects, and in participating in events that we organise, as well as those of our partners.
5. Why we collect this information and what we can do with it?
We collect this information:
in order to offer you services matching your request and/or visits to our projects, to notify you of open days and/or suggest other projects that may meet your needs;
to prepare and perform an agreement;
to respond to a request for information;
to monitor your file, send out invoices, collect payments and/or handle any disputes;
to improve our products and services in response to your comments on current, past and future real-estate projects, including web analytics and your participation in any events we organise.
We gather data for research purposes in order to better understand our clients and adapt our services accordingly.
Cookies are technically necessary, at least partially, to ensure smooth communication between your computer and our website. However, they can also be useful (e.g. for saving your preferred settings), and some specific data can be sent to the website in order to evaluate and improve its performance.
Through your web browser settings, you can decline cookies and thus stop them being installed on your hard disk. In this case, we cannot guarantee the best performance of the website in all circumstances. Please consult the documentation relating specifically to the web browser that you use.
About Google Analytics:
The information collected in this way is usually transmitted to a Google server located in the USA, where it can be stored. In order to protect the personal nature of the data collected, your IP address is shortened by Google before leaving the European Union or other contracting states of the Treaty on the European Economic Area. Only in certain exceptional cases is the complete IP address sent to a Google server in the USA before being shortened.
Google guarantees that IP addresses transmitted by your server for the purpose of Google Analytics will not be merged with other Google data. More specifically, you can prevent the data collected by cookies relating to your use of the website (including your IP address) being sent to and used by Google, by downloading and installing on your computer the plug-in available for your web browser via the following link: https://tools.google.com/dlpage/gaoptout?hl=en
7. Who has access to this information?
We transmit this information:
To our own services and, where applicable, to our service-providers for fulfilling our missions and/or for commercial promotion purposes,
Within companies belonging to the CFE/BPI group with a view to promoting links and synergies between the different entities of the group,
To third parties with whom BPI works on real-estate projects, such as real-estate agents or other property development companies, and in the case of resuming or expanding our activities, and from whom we require to comply with the regulations as far as is necessary for the fulfilment 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 legal and/or tax authorities.
We will never sell on your personal data.
In principle, the information processed is never transmitted outside of the European Union, except in very limited circumstances in order to meet a legal or regulatory obligation or where necessary for performing an allocated task and/or defending or protecting BPI’s rights and those of the persons concerned.
8. How we protect your data?
BPI will make every effort to protect these data deploying both human and technical resources (computer protection). BPI nevertheless draws your attention to the fact that no absolute guarantee of security, particularly on the internet, can be provided.
9. Processing of your data by other persons or entities
If you visit other internet sites via the BPI website or the hyperlinks it contains, you are responsible for checking the data confidentiality and compliance policies of these sites; BPI does not assume any obligation in this regard and is not liable in any way for how your personal information is used by these websites.
10. How long the data is stored?
We do not retain personal information for longer than is required for the purposes for which it was collected, taking into account the applicable limitation periods and legal retention obligations.
11. Your rights over your personal data
In accordance with the applicable legal requirements, you have the following rights:
To access your personal data, request any explanations regarding why they have been collected and how they will be used, and to transmit them in turn (“right to portability”);
To correct, complement and/or update your personal data (“right to accuracy”);
To request the deletion of your personal data (“right to oblivion”) except where it is essential for us during the fulfilment of the contract or for respecting our legitimate interests or the law;
To object to the processing of your personal data in certain cases;
To request a restriction on their processing in the cases covered by law;
To withdraw your consent for the use of your personal data where this consent is required.
To exercise one of the above rights, you can contact us at any time, sending a signed and dated request with proof of your identity, by post to the above address or by email to firstname.lastname@example.org.
You are also entitled to make a claim to the National Commission for the Data Protection, 15 Boulevard du Jazz, L-4370 Belvaux.