Privacy Policy

In order to respond to technological developments, it is essential to ensure the protection of privacy.

This Privacy Policy specifies how THE PILGRIM SARLS (hereinafter referred to as "we", "our", "us") collects, uses, and processes your personal data ("Personal Data") in the context of your relationship with us.

For the purposes of this Policy, "personal data" refers to any information relating to an identified or identifiable person, and includes all data that can be directly or indirectly attributed to a natural person.

THE PILGRIM SARLS is committed to complying with the applicable laws and regulations regarding data protection, notably the General Data Protection Regulation 2016/679 ("GDPR"), which has been in effect since May 25, 2018. As the "Data Controller" as defined by the GDPR, we control how your personal data is collected and the purposes for which it is used. Personal Data We Collect

THE PILGRIM SARLS processes your personal data only if and to the extent that the law permits us to do so or if there is an appropriate legal basis for doing so.

When you complete the contact form available on our website, we collect information such as your name, surname, email address, phone number, and the content of the messages you send us. Similarly, if you wish to subscribe to our newsletter or use our estimation tool, we need to collect your email address.

When you use our estimation tool and wish to request a physical evaluation of your property by one of our agents, we collect the following information: your name, surname, email address, phone number, and the characteristics of the property to be evaluated. We also collect your data when you contact us directly via any communication channel (for example, when you send us an email containing feedback or comments).

By providing this information, you expressly consent to the processing of your data by THE PILGRIM SARLS for the purposes indicated in Section 2 below. If other purposes are applicable, they will be communicated at the end of each form.

Finally, certain information is collected automatically. When you access our website, we may automatically collect certain information from your device via log files. This information includes your IP address, MAC address, device identifier, as well as your device's operating system, the pages visited, the queries made, and the date and time of the connection. The use of these logs allows us to improve our site and collect statistical data.

The personal data we collect may include the following:

a) Identity data

b) Data related to your real estate assets How Do We Use Your Personal Data?

We process your personal data only for a specific purpose, and we only process personal data that is relevant to achieve this purpose. THE PILGRIM SARLS processes your personal data in the following cases:

a) to provide you with the information or services you requested (for example, to respond to a contact request);

b) to communicate the results of the evaluation of your property when you use our estimation tool;

c) to improve our site, products, and services;

d) to contact you about various events, including product updates and customer support;

e) to send you marketing information or our newsletter when you subscribe or unsubscribe, as well as to provide you with personalized content. We will only use your personal data for the purposes for which we collected them, unless we reasonably believe we need to use them for another reason that is compatible with the original purpose. If we need to use your personal data for unrelated purposes, we will inform you and explain the legal basis that allows us to do so. Legal Basis for Processing Your Personal Data

For the purposes outlined in point 2:

a) Legitimate interest (including sending a commercial offer or responding to a contact request);

b) Contractual execution.

c) Legitimate interest (anonymized browsing data based on logs);

d) Consent.

e) Satisfaction (including sending the newsletter). Sharing Your Personal Data

We may use or disclose your personal data if we are legally required to do so or if we believe it is necessary to protect our rights and/or to comply with applicable law or regulation.

As part of our contractual obligations, we may share your personal data with specific trusted third parties. None of these third parties is based outside the Grand Duchy of Luxembourg or processes your personal data outside this country. If a third-party service provider processes personal data outside the EU/EEA in the course of our activities, the transfer will only occur if the European Commission has confirmed an adequate level of data protection for the third country, or if other appropriate data protection safeguards are in place (such as binding internal data protection provisions or standard contractual clauses). Security of Your Personal Data

We are committed to protecting your personal information and implementing appropriate technical and organizational security measures to prevent unauthorized or unlawful processing, as well as against accidental loss, destruction, or damage.

The personal information we collect is stored in a secure environment. Our employees are required to maintain the confidentiality of your information. To ensure the security of your personal information, we implement the following measures:

SSL protocol (Secure Sockets Layer) Access management — authorized personnel only Backups Firewalls

We are committed to maintaining a high degree of confidentiality by integrating the latest technological innovations to ensure the protection of your data. However, it is important to note that despite our efforts, no security mechanism offers absolute guarantees. Therefore, there is always some risk associated with using the internet to transmit personal information. Retention Period for Your Personal Data

Your personal data is retained by THE PILGRIM SARLS only for as long as necessary to fulfill the purpose of our communication exchanges (for example, when contacting us via our contact form) or until you unsubscribe from our newsletter, if you are subscribed (an unsubscribe link is available in every newsletter sent to you). Your Rights Regarding Your Personal Data

As a natural person, you have certain rights that you may exercise in certain circumstances. These rights include the right to:

Request access to your Personal Data; Request correction of your Personal Data; Request deletion of your Personal Data; Request limitation of the processing of your Personal Data; Object to the processing of your Personal Data; You have the right to request the transfer of your personal information, on your behalf or on behalf of another data controller, in an electronic and structured format (right to data portability).

If you wish to exercise any of these rights, please contact us at contact@thepilgrim.lu.

Your request will be processed within one month from the confirmation of your identity. No fees will be charged for accessing your personal information (or exercising any other right). However, reasonable fees may be charged if your access request is clearly unfounded or excessive. In some cases, we may also refuse to process your request, but we will explain the reasons for this refusal if applicable.

To confirm your identity and safeguard your personal information, we may ask you for additional information. This security measure is aimed at preventing your personal information from being disclosed to unauthorized persons.

If you feel that your rights are not being respected, you have the right to lodge a complaint with the National Commission for Data Protection ("CNDP"). Cookies

Our site does not use cookies that identify you. Our Partners

To ensure optimal service for users of our site, we utilize the following external services:

Google Cloud: a remote data storage solution. To learn more about how Google Cloud processes data: https://cloud.google.com/terms/cloud-privacy-notice?hl=fr

Google Ads: the promotion of real estate ads in Google search results to targeted audiences. To learn more, please visit the following link: https://policies.google.com/technologies/ads?hl=fr

Meta: an advertising service through the social networks Facebook and Instagram. To learn more about how Meta processes data: https://www.facebook.com/privacy/policy/

Update to This Policy

We reserve the right to modify, add, or remove parts of this Policy at any time. Any changes will be published on our site before they become effective.

Last updated: June 2024

contact@thepilgrim.lu