Privacy policy - Bitbourg

Who is responsible for your Personal Data

This Privacy Notice explains how Immobilière Bitbourg S.A. (“Immobilière Bitbourg S.A.”, “we”, “us” or ”our”) collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us as a Immobilière Bitbourg S.A.’s client, acting for a client or being generally interested in our services and our publications in accordance with applicable data privacy laws and regulations, which include the General Data Protection Regulation 2016/679 (“GDPR”) which is applicable as of 25 May 2018.
We control the ways your Personal Data are collected and the purposes for which we use your Personal Data acting as “data controller” for the purposes of the GDPR.

Personal data we collect about you

When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your Personal Data may include for example your name, your contact details or information on how you interact with us.
We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only if you have consented to us doing so

Categories of data we collect
We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our services or as a result of your relationship with one or more of our staff and clients.

Data category	Type
Personal identification information	Name and surname Title, Salutation (Mr / Mrs / Ms) E-mail address Phone numbers

How and why we use your Personal Data

We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. In particular, we process your Personal Data for the following purposes:

To establish, administer and implement a business relationship;
To strengthen the existing business relationship or to develop a new business relationship or to approach interested parties including information on current legal developments and our range of services (Marketing);
To provide our services to you and manage our relationship with you, including communicating with you in relation to the products and services you obtain from us;
To ensure the safety of our clients, employees and other stakeholders;
Any other purposes we notify to you from time to time.

We will only use your Personal Data for the purposes for which we collected it and which we informed you about, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Your rights in relation to your Personal Data

Under the GDPR you have various rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

Request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
Request rectification of your Personal Data;
Request the erasure of your Personal Data;
Request the restriction of processing of your Personal Data;
Object to the processing of your Personal Data.

If you want to exercise one of these rights please contact us at GDPR@lu.gt.com.
If you are not satisfied with our response, you also have the right to lodge a complaint at any time with the National Commission for Data Protection (“CNPD”), the Luxembourg supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state.

Security of your Personal Data

We are committed to taking appropriate technical and organisational measures to protect your Personal Data against unauthorised or unlawful processing and against accidental loss, disclosure, destruction or damage.
Your Personal Data is stored in Luxembourg in electronic and physical form. Any physical documentation is kept under lock and key in a secure location at our premises. Copies of this documentation are kept securely. Electronic files that contain Personal Data are stored within a secured IT infrastructure.

Sharing your Personal Data

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
We may also share your Personal Data with certain trusted third parties in accordance with contractual arrangements in place with them, including:

IT service providers;
Administrative authorities, courts, tribunals, government agencies, law enforcement agencies and notaries;
Clients, insofar as relating to data of shareholders, organs or other employees of the respective client;
Cooperation partners and legal representatives acting on our behalf;
Other recipients as determined by the client (i.e. group companies of the client);
If you exercise your right to data portability, we will usually disclose your Personal Data to an intermediary that facilitates data portability in accordance with applicable law and regulations.

Some of the above-mentioned recipients may be based outside of Luxembourg and process your Personal Data outside of Luxembourg. Where a transfer of your Personal Data is necessary to a location outside the European Economic Area (“EEA”) we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.
An interfirm agreement between all Grant Thornton member firms that share and process Personal Data is in place. Where a third party service providers process Personal Data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually in the form of standard contractual clauses.

Retention period

We will only retain your Personal Data for as long as we need it in order to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer considered as Personal Data. Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.
If you are a client, former client, interested party or prospective client or a contact person of one of the aforementioned, we store your Personal Data for marketing purposes until revocation or the revocation of your consent if the marketing measures were carried out based on your consent.

Changes to your Personal Data

We are committed to keeping your Personal Data accurate and up to date. Therefore, if your Personal Data changes, please inform us of the change as soon as possible using the contact information provided below.

Links

Our website contains links, but this Privacy Notice applies only to personal data collected via the Immobilière Bitbourg S.A. website and to how Immobilière Bitbourg S.A. processes personal data. We are not responsible for the privacy practices of other sites.

What is a Cookie
A cookie is a small piece of data or message that is sent from an organisation's web server to your web browser and is then stored on your hard drive. Cookies can't read data off your hard drive or cookie files created by other sites, and do not damage your system.
However, you can reset your browser so as to refuse any cookie or to alert you to when a cookie is being sent. Web browsers allow you to control cookies stored on your hard drive through the web browser settings. To find out more about cookies, including what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org
We only use cookies to monitor the performance of our website and to improve user experience.
If you choose not to accept our cookies, some of the features of our site may not work as well as we intend.

Cookies used by the GTIL website

Cookie type	Cookie Name	Purpose
Google analytics	utma _utmb _utmc _utmz	These cookies are used to monitor the performance of our site. We use the information to help us improve the site. The cookies collect information in an anonymous form, including the number of visits to our site, where visitors have come from to the site and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Updates to our Privacy Notice

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Notice at any time, and we will make an updated copy of such privacy notice publicly available.
If we make any material changes to this Privacy Notice, we will notify you accordingly, by email or by means of a notice on our Site’s home page.

Contact information

If you have questions or concerns regarding this Privacy Notice or you wish to exercise your rights in relation to your Personal Data, please do not hesitate to contact us at contact@bitbourg-business-center.lu or send your request to the following address:

Immobilière Bitbourg
Attn. DATA PROTECTION OFFICER
7, Rue de Bitbourg
L-1273 Luxembourg