1. Purpose

The purpose of this privacy policy is to inform users of the www.clochedor.lu website, as well as individuals who use the forms associated with Cloche d’Or projects, about how their personal data is collected, used, and protected.

Personal data is processed in accordance with Regulation (EU) 2016/679 of April 27, 2016, on the protection of personal data (“GDPR”), as well as applicable Luxembourg law.

2. Data Controller

The data controller is:

Grossfeld Immobilière S.A.
17 Rue de la Poudrerie
L-3364 Leudelange
Luxembourg

Luxembourg Commercial Register: B85508
VAT No.: LU19142777

Phone: +352 24 83 93 1
Email: info@grossfeld.lu

3. Personal Data Collected

When you use the website www.clochedor.lu, its contact forms, registration forms, or forms related to a real estate project such as MONTERA, we may collect your first name, last name, email address, phone number, and any other information you voluntarily provide as part of your request.

For inquiries regarding a real estate project, the information collected may also include the type of property you are looking for, the nature of your real estate project, your estimated budget, your preferences, and whether you would like to receive information, be contacted, or schedule an appointment.

While browsing the website, certain technical data may also be processed, including the IP address, information about the browser and device used, connection dates and times, and data necessary for the proper functioning and security of the website.

4. Purposes and Legal Bases for Data Processing

Personal data is used to respond to inquiries submitted through the website or forms, provide information about La Cloche d’Or’s real estate projects, schedule an appointment, or enable an advisor to follow up with someone who has submitted an inquiry.

When processing is necessary to respond to a request regarding real estate or to take precontractual steps at your request, it is based on Article 6(1)(b) of the GDPR.

When you choose to receive communications or marketing information that is not directly necessary for processing your request, the processing is based on your consent in accordance with Article 6(1)(a) of the GDPR. You may withdraw this consent at any time.

Certain technical data may also be processed to ensure the operation, security, and improvement of the website based on the legitimate interest of Grossfeld Immobilière S.A., in accordance with Article 6(1)(f) of the GDPR.

Finally, certain data may be retained when necessary to comply with a legal obligation.

5. Forms Related to Real Estate Projects and Typeform

Some information request forms related to Cloche d’Or projects, including the MONTERA project, are created using the Typeform solution, provided by Typeform S.L.

When you fill out one of these forms, the information you provide is processed by Typeform on behalf of Grossfeld Immobilière S.A. to enable the collection and transmission of your request.

Typeform uses technical infrastructure and third-party service providers that, depending on the account configuration, may process certain data outside the European Economic Area. When such transfers occur, they are governed by the mechanisms provided for under the GDPR, including applicable adequacy decisions and/or standard contractual clauses adopted by the European Commission.

6. Recipients of the Data

Personal data is accessible only to individuals and organizations that need to review it in order to process your request.

In particular, this information may be made available to the teams at Grossfeld Immobilière S.A., as well as to the sales teams involved in marketing the relevant real estate project.

In connection with certain real estate projects, information may be shared with teams at the Promobe / T-Comalux S.A. group, located at 17 rue de la Poudrerie, L-3364 Leudelange, when such sharing is necessary for the processing and follow-up of your request.

Technical service providers may also have access to certain data to the extent strictly necessary for the performance of their services. These include, in particular, wait: agency / Wait S.A., which is involved in the design, development, and maintenance of the website; Infodata S.à r.l., which provides hosting and technical services related to the website; and Typeform S.L. for forms created using the Typeform platform.

These service providers act as subcontractors or technical service providers and may use the data only in connection with the tasks assigned to them.

Data is not sold to third parties.

7. Website Hosting

The site is hosted by:

Infodata S.à r.l.
22, Industrial Zone
L-8287 Kehlen
Luxembourg

The web host provides the technical infrastructure necessary for the website to operate.

8. Shelf Life

Data provided in connection with an inquiry or a real estate project is retained for as long as necessary to process the request and manage the relationship with the individual concerned.

If no contractual relationship is established, data used for sales follow-up or marketing purposes are retained for a maximum of three years from the date of the last contact with the data subject, unless a legal obligation requires a different retention period.

If a contract or real estate transaction is entered into, the data necessary for managing the contractual relationship may be retained for the periods specified by applicable legal obligations and statutes of limitations.

The technical data and logs necessary for the security of the site are retained only for as long as necessary for this purpose.

9. Cookies

The website www.clochedor.lu uses cookies and similar technologies necessary for its operation and may also use, subject to the user’s consent when required, cookies for audience measurement or related to third-party services.

You can accept, reject, or change your cookie preferences at any time using the cookie manager available on the website.

Rejecting non-essential cookies does not prevent you from accessing the site's main features.

10. Data Security

Grossfeld Immobilière S.A. and its service providers implement appropriate technical and organizational measures designed to protect personal data against loss, destruction, alteration, unauthorized access, or accidental or unlawful disclosure.

11. Your Rights

In accordance with the GDPR, you have—subject to the conditions set forth in the regulation—the right to access your personal data, the right to rectification, the right to erasure, the right to restrict processing, the right to object, and, when the conditions are met, the right to data portability.

When the processing is based on your consent, you may withdraw your consent at any time, without this affecting the lawfulness of the processing carried out prior to such withdrawal.

To exercise your rights or for any questions regarding the processing of your personal data, please contact:

Grossfeld Immobilière S.A.
17, rue de la Poudrerie
L-3364 Leudelange
Luxembourg
Email: info@grossfeld.lu

Proof of identity may be requested when necessary to verify the identity of the person exercising their rights.

You also have the right to file a complaint with:

National Commission for Data Protection (CNPD)
15, Boulevard du Jazz
L-4370 Belvaux
Luxembourg

12. Links to Third-Party Websites

This website may contain links to websites or services operated by third parties. Grossfeld Immobilière S.A. is not responsible for the processing of data carried out directly by these third parties. We encourage you to review their own privacy policies.

13. Changes to the Privacy Policy

This policy may be amended to reflect changes to the website, the services offered, the tools used, or applicable regulations.

The version published on www.clochedor.lu is the version in effect at the time of viewing.

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