The collection, processing and use of your personal data are carried out in accordance with the strict requirements of European data protection legislation, based on the principles of data minimisation, transparency and data security. We will only process and use your data to the extent that this is necessary, legally permitted, or required and requested by you for the performance of the contract concluded with you or the agreed service and the resulting customer relationship.
(1) In the following, we inform you about the collection of personal data when using our website. Personal data means all data that can be related to you personally, such as your name, address, email addresses and user behaviour.
(2) The data controller within the meaning of Article 4(7) of the EU General Data Protection Regulation is Ton Eggen, SR IMMO Int’l S.à r.l., Grand-Rue 20, L-9410 Vianden. You can contact our data protection officer at contact@sri.lu or via our postal address.
(3) When you contact us (for example, via a contact form or by email), personal data is collected. The data collected when using a contact form is indicated in the respective contact form. This data is stored and used exclusively for the purpose of responding to and processing your enquiry, contacting you, and handling the associated administrative matters. The legal basis for processing the data is our legitimate interest in responding to your enquiry in accordance with EU data protection law, particularly where your contact is aimed at entering into a contract.
(4) Your data will be deleted after your enquiry has been finally processed, provided that it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that no statutory retention obligation prevents such deletion.
(5) If we use commissioned service providers for certain functions of our services or if we wish to use your data for advertising purposes, we will inform you in detail about the respective processes below.
In doing so, we also indicate the criteria defined for the storage period.
We process your personal data on the basis of the proper performance of the contract. Without this legal basis, we cannot conclude and perform the contract with you. We also use your personal data to send you information about the real estate products and services offered.
Your personal data is processed for the following purposes:
a) User enquiries for registration on the website
b) Provision of services on the website (e.g. registration, account access),
c) Technical statistical analysis measures,
d) Protection against fraud and misuse,
e) Compliance with legal requirements.
We offer services for real estate financing. In doing so, you have the opportunity to contact the respective providers directly. As soon as you use our services, provide us with your personal data and give us your consent to process the data, the processing of this data is subject to the following data protection rules as well as the European General Data Protection Regulation (EU GDPR).
Your data is processed by us in accordance with Articles 5 et seq. of the EU GDPR. In detail, your data is processed by the following groups of persons:
a) Employees authorised to administer the website and provide the associated services;
b) Third-party companies (e.g. IT service providers, hosting providers, etc.)
(1) With regard to your personal data, you have the following rights vis-à-vis us:
a) Right of access to information,
b) Right to rectification or erasure,
c) Right to restriction of processing,
d) Right to object to processing,
e) Right to data portability.
(2) You also have the right to lodge a complaint regarding the processing of your personal data with our data protection officer or with the data protection supervisory authority:
Commission Nationale pour la Protection des Données (CNPD) L-4361 Esch-sur-Alzette, 1, avenue du Rock’n Roll.
(1) When you use the website for information purposes only, i.e. if you do not register or provide us with any other information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary to display our website to you and to ensure its stability and security (the corresponding legal basis is Article 6(1)(f) of the EU GDPR):
a) IP address
b) Date and time of the request
c) Difference in time zone from Greenwich Mean Time (GMT)
d) Content of the request (specific page)
e) Access status/HTTP status code
f) Amount of data transferred in each case
g) Website from which the request originates
h) Browser
i) Operating system and its interface
j) Language and version of the browser software.
(2) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive in connection with the browser you use and that provide certain information to the party that places the cookie (in this case, us). Cookies cannot execute programmes or transfer viruses to your computer. They serve to make the Internet offering as a whole more user-friendly and efficient.
(3) Use of Cookies
(a) This website uses the following types of cookies, the scope and functionality of which are explained below:
- Transient cookies (see b)
- Persistent cookies (see c).
b) Transient cookies are automatically deleted when you close your browser. These include session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the same session. This allows your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close your browser.
c) Persistent cookies are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete cookies at any time in your browser's security settings.
d) You can configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies. Please note that you may then not be able to use all the functions of this website.
e) We use cookies to identify you on subsequent visits if you have an account with us. Otherwise, you will have to log in again each time you visit.
f) The Flash cookies used are not collected by your browser, but by your Flash plug-in. In addition, we use HTML5 storage objects that are stored on your device. These objects store the required data independently of the browser you use and do not have an automatic expiration date. If you do not want Flash cookies to be processed, you must install an appropriate add-on, such as “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe Flash Killer cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using private browsing mode in your browser. We also recommend that you regularly delete your cookies and browser history manually.
(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. To this end, you will generally need to provide additional personal data, which we use to provide the respective service and to which the aforementioned data processing principles apply.
(2) In some cases, we use external service providers to process your data. These providers have been carefully selected and commissioned by us, are required to follow our instructions and are subject to regular monitoring.
(3) If our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in the description of the respective service.
(1) If you have given your consent to the processing of your data, you may withdraw this consent at any time. Such withdrawal will affect the lawfulness of the processing of your personal data after you have notified us of your decision.
(2) Where we base the processing of your personal data on a balancing of interests, you may object to the processing. This is the case if the processing is not necessary, in particular for the performance of a contract with you, which we indicate in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of a justified objection on your part, we will examine the situation and either cease processing the data, adapt the processing, or inform you of our compelling legitimate grounds worthy of protection on the basis of which we will continue the processing.
(3) Of course, you may object at any time to the processing of your personal data for advertising and data analysis purposes. You can notify us of your objection to advertising using the following contact details:
SR IMMO Int’l S.à r.l.
Data Protection Officer
20, Grand-Rue
L-9410 Vianden
contact@sri.lu
1. Use of Google Analytics
(1) Our website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, which are text files stored on your computer that enable an analysis of your use of the website. The information generated by the cookie about your use of the website is generally transmitted to and stored on a Google server located in the United States. If IP anonymisation is activated on this website, however, your IP address will first be truncated by Google within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity and provide the website operator with other services related to website and Internet use.
(2) The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
(3) You can refuse the use of cookies by selecting the appropriate settings in your browser, but please note that if you do so, you may not be able to use all the functions of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and its transmission to Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=fr.
(4) We use Google Analytics to regularly analyse and improve the use of our website. The statistics obtained enable us to improve our offering and make it more attractive to you as a user. In exceptional cases where personal data is transferred to the United States, Google complies with the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Article 6(1)(f) of the EU GDPR.
(5) Information about the third-party provider: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353(1)4361001.
Terms of use: http://www.google.com/analytics/terms/fr.html,
Overview of data protection policy: https://marketingplatform.google.com/intl/fr/about/,
and Privacy Policy: https://policies.google.com/privacy?hl=fr&gl=de.
(6) This website also uses Google Analytics for cross-device analysis of visitor flows, which is carried out using a user ID. You can deactivate cross-device analysis of your use in your customer account under “My Data”, “Personal Data”.
Use of Google AdWords Conversion
(1) We use the Google AdWords service to draw attention to our attractive offers using advertising materials (so-called Google AdWords) on external websites. The analysis of data relating to advertising campaigns enables us to evaluate the success of individual advertising measures, with the aim of showing you advertisements that are of interest to you, making our website more attractive to you and ensuring a fair calculation of advertising costs.
(2) These advertisements are delivered by Google via so-called “ad servers”. For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as the display of advertisements or user clicks, can be measured. If you access our website via a Google advertisement, Google AdWords stores a cookie on your PC. These cookies generally expire after 30 days and are not intended to personally identify you. The unique cookie ID, the number of ad impressions per placement (frequency), the last advertisement (relevant for post-view conversions) and opt-out information (indicating that the user no longer wishes to be addressed) are generally stored as analysis values for this cookie.
(3) These cookies enable Google to recognise your Internet browser. If a user visits certain pages of an AdWords customer's website and the cookie stored on their computer has not yet expired, Google and the customer can recognise that the user clicked on the advertisement and was redirected to that page. A different cookie is assigned to each AdWords customer. Cookies therefore cannot be tracked via the websites of AdWords customers. We do not collect or process any personal data ourselves as part of the aforementioned advertising measures. We only receive statistical evaluations from Google. Based on these evaluations, we can see which advertising measures used are particularly effective. We do not receive any other data concerning the use of advertising materials; in particular, we cannot identify users based on this information.
(4) Due to the marketing tools used, your browser automatically establishes a direct connection with Google's server. We have no influence over the scope and subsequent use of the data collected by Google through this tool and therefore inform you according to the best of our knowledge: through the integration of AdWords Conversion, Google receives the information that you have accessed the relevant section of our website or clicked on an advertisement. If you are registered with a Google service, Google may associate the visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may learn your IP address and store it.
(5) You can prevent participation in this tracking procedure in various ways:
(a) by adjusting your browser software accordingly; in particular, deleting third-party cookies will mean that you will not receive advertisements from third-party providers;
b) by disabling conversion tracking cookies by configuring your browser to block cookies from the domain “www.googleadservices.com”, https://www.google.fr/settings/ads, whereby this setting is deleted when you delete your cookies;
c) by disabling interest-based advertisements from providers that are part of the “About Ads” self-regulatory campaign via the link http://www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies;
d) by permanently disabling them in your Firefox, Internet Explorer or Google Chrome browsers via the link http://www.google.com/settings/ads/plugin. We would like to point out that, in this case, you may not be able to use all the functions of this service in their entirety.
(6) The legal basis for processing your data is Article 6(1)(f) of the EU GDPR. You can find further information about data protection at Google on the following websites: https://policies.google.com/privacy?hl=fr and https://services.google.com/sitestats/fr.html. You can also visit the Network Advertising Initiative (NAI) website at http://www.networkadvertising.org. Google complies with the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
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