1. Who we are
This Privacy Policy explains how Solum Real Estate S.à r.l. ("Solum", "we", "us", "our") collects, uses, and protects personal data submitted through the website lesalleesvertes.com (the "Site"), which markets the residential and commercial development known as Les Allées Vertes in Bertrange, Luxembourg.
Solum is the data controller for personal data processed via this Site within the meaning of the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the Luxembourg Data Protection Act of 1 August 2018.
2. What data we collect
Data you provide
When you submit the "Request a Private Viewing" form or otherwise contact us through the Site, we collect:
- Your name (first and last)
- Your email address
- Your phone number (optional, including country dialling code)
- The fact and timestamp of your consent to this Privacy Policy
Data collected automatically
When you browse the Site we may also process:
- Technical information (IP address, browser type and version, operating system, device type, referring URL)
- Pages visited, time on page, and interaction events (e.g. opening a 360° virtual tour)
- Cookies and similar technologies — see Section 8 below
3. How we use your data
We process personal data for the following purposes:
- Responding to your enquiry — to schedule a viewing, send property documentation, and answer your questions
- Lead and relationship management — recording your enquiry in our customer relationship management (CRM) system so the appropriate Solum representative can follow up
- Site operation and security — running the Site, protecting against abuse and fraud, diagnosing technical problems
- Compliance with legal obligations — including record-keeping obligations under Luxembourg law
We do not use your data for marketing emails or newsletters unless you have separately and explicitly opted in. Submission of the contact form is consent to processing — not to receiving marketing communications.
4. Legal basis
We rely on the following lawful bases under Article 6 GDPR:
- Consent (Art. 6(1)(a)) — for processing the data you submit through the contact form, as evidenced by the consent checkbox you tick before submission. You may withdraw your consent at any time (see Section 7).
- Legitimate interest (Art. 6(1)(f)) — for basic Site analytics, security, and the operation of the Site, where our interest in running and protecting the Site does not override your fundamental rights.
- Legal obligation (Art. 6(1)(c)) — where applicable Luxembourg or EU law requires us to retain or disclose data.
5. Who we share your data with
We do not sell your personal data. We share it only with the following categories of recipients, and only to the extent necessary for the purposes above:
- HubSpot, Inc. — our CRM and form-submission processor. Form submissions are sent directly to HubSpot's EU data centre. HubSpot is a US-based provider; international transfers are governed by EU Standard Contractual Clauses and the EU–US Data Privacy Framework where applicable.
- Hostinger International Ltd. — our hosting provider for the Site.
- Content delivery networks (Google Fonts, jsDelivr, Cloudflare) — used to deliver fonts, scripts, and the 360° virtual tour viewer. These providers may process your IP address as part of normal Site delivery.
- Professional advisers and authorities — lawyers, auditors, or competent public authorities, where required by law or to defend our legal interests.
6. How long we keep your data
We keep your personal data only as long as necessary for the purposes set out above:
- Active enquiries — for the duration of our communications and any subsequent commercial relationship
- Closed enquiries that did not lead to a transaction — for up to 24 months from the last contact, after which they are anonymised or deleted
- Records subject to a legal retention obligation (e.g. accounting records) — for the period required by Luxembourg law, typically up to 10 years
7. Your rights
Under the GDPR you have the right to:
- Access the personal data we hold about you
- Rectify data that is inaccurate or incomplete
- Erase your data (the "right to be forgotten") in certain circumstances
- Restrict processing in certain circumstances
- Object to processing based on legitimate interest
- Data portability — receive your data in a structured, commonly used format
- Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal
- Lodge a complaint with the supervisory authority — in Luxembourg, the Commission Nationale pour la Protection des Données (CNPD)
To exercise any of these rights, please email privacy@solumre.com. We will respond within one month, as required by GDPR. We may need to verify your identity before processing your request.
8. Cookies and tracking
The Site uses cookies and similar technologies for the following purposes:
- Strictly necessary cookies — required for the Site to function (e.g. remembering your language preference, recording cookie consent)
- Analytics — aggregate, non-identifying statistics about Site usage
The Site displays a cookie banner on your first visit allowing you to accept or decline non-essential cookies. You can revoke or change your choice at any time by clearing your browser cookies for this Site.
9. Security
We implement reasonable technical and organisational measures to protect personal data against accidental loss, unauthorised access, disclosure, alteration, or destruction. The Site is served over encrypted HTTPS, form submissions are transmitted over TLS, and data in our CRM is access-controlled. However, no transmission over the Internet is ever fully secure; we cannot guarantee the absolute security of data transmitted to or from the Site.
10. Children
The Site is intended for adults considering luxury residential or commercial property in Luxembourg. We do not knowingly collect personal data from children under 16. If you believe a child has submitted data to us, please contact privacy@solumre.com and we will delete it.
11. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or the services we provide. The "Last updated" date at the top of this page indicates when the policy was most recently revised. We recommend reviewing this page periodically. Material changes will be communicated via a prominent notice on the Site or, where appropriate, by email to contacts in our CRM.
12. Contact
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at: