PRIVACY POLICY FOR WEBSITES AND MOBILE APPLICATIONS


Introduction

At HILP Sàrl, we respect and protect your privacy and believe that transparency is the key to good data governance. We want to remain worthy of the trust you place in us by visiting our websites and using our services. We also want you to feel comfortable when you surf our sites. That is why we would like to inform you about the precautions we take when processing the personal data you entrust to us.

The following brands, mobile applications and websites ("our websites") are part of HILP Sàrl ("we", "our"):

HILP (www.hilphelps.com)

 By using our websites, you agree to our Privacy Policy and the Terms of Use set out below. The Privacy Policy relates to the collection and use of personal information that you provide to us through the use of our websites.

We reserve the right, at our discretion, to change or remove portions of this Privacy Policy at any time. This Privacy Policy is in addition to any other terms and conditions applicable to our websites.

You are responsible for the use of third party sites (which may be linked to our websites). In this case, we invite you to consult the privacy and confidentiality policy of these third party sites.

Your personal data

You provide us with a certain amount of personal data relating to your identity (surname, first name) and your contact information (e-mail address and telephone number). This is also the case when you submit requests or communicate with us or when you place a property advertisement on our websites.

The personal data we may collect and process are as follows

    Your surname, first name, e-mail address, telephone number, postal address

    Your electronic identifiers, such as your IP address and web pages visited

    Your passwords

    Your preferences in terms of property searches

    How you came to know us

    Information relating to your property in the event of an advert being placed

    Information about your payment methods in the event of payment by credit card

    Your personal data in order to respond to support requests

Responsibility for processing your personal data

HILP Sàrl with registered office at 12, rue du Château d’Eau L-3364 LEUDELANGE -  Luxembourg (hereinafter referred to as "HILP"), informs you that, for the purposes set out below and in order to be able to provide its services, as well as to transmit information and contact requests relating to specific real estate advertisements through its websites (hereinafter jointly referred to as "services") and for the operation of the said websites, processes personal data, provided by you or otherwise acquired during the performance of the services and/or during your browsing of this website, in the capacity of the person responsible for this processing.

Duration of storage of this data

Your personal data will be kept in our database for a period of 36 months from the end of the last relationship with our websites.

How we process your personal data

The processing of your personal data is carried out within the framework of the purposes defined by HILP prior to its application, namely.

The processing of such data is carried out within the framework of appropriate procedures and measures to protect the security in terms of integrity, confidentiality and accessibility of the user's data, in accordance with the applicable legislation. The purpose of this data processing is their use, including their collection, recording, organisation, storage, updating, selection, extraction, comparison, interconnection, blocking, communication, deletion, combination of two or more of the above activities, and also to carry out profiling on the basis of the preferences expressed during navigation on the site, within the limits necessary for the pursuit of the purposes for which the data were collected.

Purposes of processing

The processing of your personal data is carried out within the framework of the purposes defined by HILP prior to its application, namely

    1. The processing is necessary for the performance of a contract to which you are party. It is used to carry out any measure aimed at providing the requested service, which may be carried out using automated and computerised methods. This processing will also involve the concept of profiling, based on the preferences expressed when browsing this website, and is an integral and essential part of the services themselves and, therefore, indispensable for providing them. The nature of the services provided requires the communication to HILP and the automated processing of data and information regarding the location, typology and characteristics of the properties sought. These data and information, as well as their processing, are indispensable in order to satisfy and respond to your requests.

    2. To fulfil any related obligations under the applicable regulations.

    3. If necessary, to exercise and/or defend a right before the competent authority.

    4. If requested by the data subject, to respond to his/her request for support from our services.

Legal basis for processing

The legal basis for the processing of your personal data referred to in point 1 of the above purposes is the need for HILP to ensure the performance of the contract to which you are party.

The processing of your personal data referred to in point 2 of the above purposes is based on the need to fulfil any obligations under applicable law related to the provision of the services.

The processing of your personal data referred to in point 3 of the above purposes is based on the legitimate interest of HILP, the exercise and/or defence, where applicable, of your rights before the competent authorities.

The processing of your personal data referred to in point 4 of the above purposes is based on your explicit and expressed consent when browsing our website and/or mobile application and by issuing a support request to our services.

Nature of data disclosure and consequences of non-disclosure

The disclosure of your personal data and, as indicated, your profiling is a necessary condition for the processing carried out for the above purposes.

Therefore, in the event of non-disclosure of your personal data and/or your objection thereto, HILP will not be able to provide the services, nor fulfil any associated obligations under the applicable law.

Other possible purposes of processing

HILP may process your personal data, including via automated systems, for the processing of information about your preferences regarding the location, type and characteristics of the properties in which you are interested, to send you information, material and commercial offers related to goods and/or services and/or companies with whom HILP may develop commercial partnership agreements and/or initiatives, campaigns and joint projects, such as, for example, banks, finance companies, telecommunication service providers, property companies, home service providers, as well as to develop research, statistics and market studies. Copies of correspondence sent from our websites, including personal information, may be stored in archival form by HILP for statistical reporting and technical follow-up in case of malfunction only.

Legal basis for processing for other purposes

The processing of your personal data for these purposes will be based on your free, explicit and informed consent, specifically and distinctly requested and always revocable.

Nature of data disclosure and consequences of non-disclosure for other purposes

The disclosure of your personal data is optional for the processing carried out for the other purposes mentioned above. Therefore, if you do not consent to the processing of your personal data for these purposes, the processing will be limited to the activities referred to in the main purposes, i.e. the performance of the obligations arising from the provision of the services, as well as the fulfilment of any related obligations under the applicable law.

Personal data collected for the purposes described in this paragraph will be stored for a period of 36 months from the date of registration on our websites.

Persons to whom your data may be communicated or who may become aware of it

The processing of your data will be carried out by persons designated by HILP and who have functions related to this processing, such as customer service employees, employees dealing with advertisers in the areas of sales and marketing (sales department and GoToMarket), financial personnel, personnel in charge of the maintenance of computer systems.

Your personal data may be communicated to and processed by subjects outside the HILP organisation, service providers in favour of HILP, external suppliers of ICT (Information and Communication Technology) services, who will process them only within the limits of the aforementioned purposes and within the framework of their contractual relationship with HILP.

In addition, in order to satisfy information and contact requests relating to specific real estate searches, the data will be communicated to real estate agencies, building contractors and/or private advertisers of reference.

For all the above purposes, data may be communicated in the Grand Duchy of Luxembourg or abroad to third parties such as tax and legal consultants of HILP in connection with its obligations, to companies and technical consultants in charge of the management and maintenance of our information systems, software and databases, to financial, administration, archiving, audit and budgetary certification services companies, in any case in close connection and within the limits of the fulfilment of their respective tasks and activities.

If necessary for the purposes mentioned above, your personal data may also be communicated or made available to other entities of the group of which HILP is a part.

For processing to provide you with direct marketing information about third party products and/or services, where you have expressly given your consent for such purposes, your data will be communicated to third parties carrying out such marketing information activities.

Security

We do everything possible to ensure the security, integrity and confidentiality of the personal data and information transmitted on/through our sites and to prevent their accessibility to unauthorised third parties. To this end, we review and update our security measures in accordance with current technologies. Unfortunately, no data transmitted over the Internet can be guaranteed to be completely secure.

In addition, our employees and contractors who provide services related to our information systems are required to respect the confidentiality of personal information held by us. However, we cannot be held responsible for events resulting from unauthorised access to your personal information.

Cookies

Cookies are small data files that can be sent from a website to the user's terminal (usually the browser), where they are stored before being transmitted back to the site on the next visit. A cookie cannot retrieve any other data from your terminal's hard drive, transmit computer viruses or acquire e-mail addresses. Cookies can be used by both the site owner and third parties and can be easily disabled by you.

HILP, in order to provide its services, needs to use cookies, including third party cookies, throughout our sites. If you choose to disable the use of cookies, please be aware that, for purely technical reasons, HILP may not be able to provide certain services or deliver them in the manner you expect.

For more information on the cookies used by our sites and the procedure for activating/deactivating them, even individually, we invite you to read the detailed information on cookies on our websites by accessing the following link: Cookie policy


Your rights and contacts

As an interested party in the processing of your personal data, processed through this website by HILP, you are able to exercise the following rights at any time:

    1. The right to obtain confirmation as to whether or not personal data concerning you exist and, if so, to obtain access to and a copy of such data. Unless otherwise provided by applicable law, HILP may deny you the opportunity to obtain such a copy where this would affect the rights and freedoms of others;

    2. The right to obtain information concerning:

        a. The origin of your personal data;

        b. The purpose and manner of processing of your personal data;

        c. The logic applied in the case of processing carried out using electronic instruments;

        d. The identification details of the owner and, if appointed, the managers and the privacy representative;

        e. The persons or categories of persons to whom personal data may be disclosed;

    3. The right to obtain:

        a. Updating, rectification, integration of your personal data;

        b. The deletion, anonymization or blocking of data processed in violation of the law, including those not necessary for the preservation of the purposes for which the data were collected or subsequently processed, in the cases envisaged by the applicable law;

        c. The limitation of the processing of your personal data in the cases envisaged by the law;

    4. The right to object, in whole or in part:

        a. The right to object, in whole or in part: a. For legitimate reasons to the processing of personal data concerning you, even though they are relevant to the purpose of the collection;

        b. To the processing of your personal data for the purpose of sending advertising material or direct sales or for the performance of market research or commercial communication;

    5. The right to :

        a. Revoke your consent at any time, if it is the legal basis for the processing, without prejudice to the lawfulness of the processing based on the consent before revocation;

        b. To submit a complaint to the supervisory authority;

        c. In the cases provided for by the applicable law, to receive your data in a structured, commonly used and machine-readable format;

    6. The right to obtain certification that each of the recipients to whom the personal data has been transmitted has been notified of any corrections, cancellations or limitations to the processing, except in cases where this is disclosed or involves the use of means that are manifestly disproportionate to the right protected. In any case, at your express request, you will also be able to obtain the details of these recipients.

For any contact request or to exercise your rights, exclusively related to data protection, you can contact our data protection officer

    by email at info@hilphelps.com


General information

We have made it a point of honour to ensure that our practices with regard to the protection of your personal data are strictly in accordance with the legislation applicable in the Grand Duchy of Luxembourg and in the European Union: the General Data Protection Regulation (EC) 2016/679 of 25 May 2018, available by following this link: https://www.cjoint.com/doc/17_12/GLnmzFxp4tM_rgpd.pdf


Please note that we do not assume any responsibility for the privacy and confidentiality policies of websites to which our sites establish hyperlinks.

Terms of Use of User Generated Content
A. Definitions


Contributions: information including data, text, video, still images, soundtracks or any other material that HILP  S.à.R.L, hereinafter referred to as "HILP", allows you to host, share, publish, post, save or upload to its websites in accordance with these terms of use.

Contributions of Other Users: this is information including data, text, video, still images, soundtracks or any other material that HILP S.à.R.L. has allowed users other than you to host, share, publish, post, record or upload to its websites.

B. Terms of use applicable to Contributions

HILP may allow you to make Contributions to its websites.

You acknowledge that you are solely and fully responsible for all Contributions you make to any of the HILP websites. HILP is not responsible for monitoring the Contributions. HILP does not endorse any information contained in the Contributions, including any opinions, recommendations or advice expressed therein. HILP is under no obligation to treat your Contributions as confidential information.

HILP may, at any time and without any liability to you, remove, modify or disable access to your Submissions at its sole discretion and without prior notice to you. Without limiting the previous sentence, HILP  S.à.R.L. may remove or disable access to one or more of your Contributions if it considers that :

    a. such Contributions violate any law or regulation

    b. such Contributions infringe the intellectual property rights of a third party

    c. it is required by a regulatory body or other competent authority

    d. such contributions are :

        - misleading or deceptive

        - inappropriate for the purpose of our websites

        - likely to cause harm

        - materially wrong

        - obscene

        - defamatory

        - illegal or

        - damaged due to the presence of a virus or invalid code.

You retain all proprietary rights in your Contributions. HILP not obliged to treat your Contributions as private information.

To the extent that any Submissions are protected by intellectual property rights, you grant HILP a worldwide, non-exclusive, royalty-free, perpetual, transferable and irrevocable right to use, reproduce, modify, adapt, translate, publish, create derivative works from, display and publicly perform your Submissions throughout the world and in any medium, whether now existing or not. You also grant each user of the Website the non-exclusive right to use, reproduce, adapt, translate, distribute, create derivative works from, display and perform your Submissions as permitted by HILP and these terms of use.

You grant to HILP the right to use your registered name or the name under which you have posted your Contribution and the right to specify and substantiate that:

    a. you own and control all of the rights to your Contributions; or

    b. you own the rights including all necessary licences, permissions and consents to use and allow HILP to publish your Submissions.

For all Contributions in which you have moral rights, you declare that :

    a. you do not claim that your name or personally identifiable information is associated with the Contribution or any derivative, new or updated version of the Contribution.

    b. you do not object to the publication, use, modification, deletion and exploitation of the Contribution by HILP

    c. you waive any claim of any kind against HILP that you may have by virtue of any moral rights you may have.

You understand that by accessing the Website, you may be exposed to Contributions from other users. You acknowledge and agree that HILP has no control over, and is not responsible for, any Contributions by other users. You waive any and all claims of any kind that you may have against HILP arising out of or in connection with the Submissions of other users.