PRIVACY POLICY
1. Introduction
Estating S.A. is the holding company of Estating Group. This privacy policy will explain how our organization uses the personal data we collect from you when you use our website or app.
1.1 Scope
Estating S.A. takes its clients data protection seriously and treats data with confidentiality and according to data protection laws. We will collect certain personal data if you visit Estating S.A. websites/app. The following data privacy policy explains, which data Estating S.A. collects, for which purposes and informs about your rights.
If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.
The web site owner is responsible for data collection. You will find contact details in the imprint on Estating S.A.’s website and further below in the data privacy policy.
1.2 Principles
Our principles for processing personal data are:
- Fairness and lawfulness. When we process personal data, the individual rights of the clients must be protected. All personal data must be collected and processed in a legal and fair manner.
- Restricted to a specific purpose. The personal data of clients must be processed only for specific purposes.
- Transparency. The client must be informed of how his/her data is being collected, processed and used.
2. Data
2.1 What data do we collect?
Estating S.A. collects the following data:
- Personal identification information (Name, email address, phone number, your financial advisor)
- Server log-in Data
- Browser type and version
- Operating system
- URL
- Hostname
- Time of visit
- IP address
2.2 Log Data only for app?
We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.
2.3 How do we collect your data?
You directly provide Estating S.A. with most of the data we collect. We collect data and process data when you:
- Register online
- Voluntarily when you complete a customer survey, complete a contact form or provide feedback on any of our message boards or via email
- Use or view our website via your browser’s cookies.
- Contact us via social media, e.g. linkedin
When you use the app, third parties may collect, store and/or process the information detailed in this Privacy Policy. These third parties are carefully selected to ensure that they, and their related entities, who may access your information, provide your information with equal protection to that stated in this Privacy Policy and required by applicable privacy laws.
Link to privacy policy of third party service providers used by the app:
2.4 How will we use your data?
Estating S.A. collects your data so that we can:
- Maintain website functionality
- Measure success of marketing campaigns
- Target better offers to our users
- Provide a contact form and respond to your request
- Email you with special offers on other products and services we think you might like (newsletter).
- Analysis of user behaviour with google analytics
2.5 How do we store your data?
Estating S.A. securely stores your data at on servers in the EU.
The data is encrypted at rest and at transit using SSL or TLS encryption (https). If encryption is activated, the data you provide cannot be read by unauthorized third parties.
2.6 What is the legal basis for collecting, storing and processing personal data
The egal basis for collecting and using the personal data described in this Privacy Policy depends on the personal data we collect and the specific context in which we collect the information:
- Estating S.A. needs to perform a contract with you
- You have given consent to do so
- Processing your personal data is in Estating S.A. legitimate interests and may be required to comply with the law
Estating S.A. will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.
Estating keeps your data in compliance with GDPR requirements and complies with GDPR removal rules. Legal retention periods are preserved.
Data based on contact forms and emails are stored to enable processing of your questions/comments and follow-up communication. Estating S.A. processes the data due to your consent. You may ask to revoke your consent at any time via email. Your provided data will be stored until you request erasure, the purpose for storing the data ceases or you revoke your consent.
2.7 Marketing
Estating S.A. would like to send you information about products and services of ours that we think you might like, via our Estating Newsletter.
If you have agreed to receive marketing, you may always opt out at a later date.
You have the right at any time to stop Estating S.A. from contacting you for marketing purposes or giving your data to other members of the Group.
If you no longer wish to be contacted for marketing purposes, please unsubscribe using the link in our email
3. What are your protection rights?
Estating S.A. would like to make sure you are fully aware of all of your data protection rights.
Every user is entitled to the following:
- The right to access – You have the right to request Estating S.A. for copies of your personal data.
- The right to rectification – You have the right to request that Estating S.A. correct any information you believe is inaccurate. You also have the right to request to complete information you believe is incomplete.
- The right to data portability – You have the right to request that Estating S.A. transfers the data that we have collected to another organization, or directly to you.
- The right to erasure – You have the right to request that Estating S.A. erase your personal data.
- The right to restrict processing – You have the right to request that Estating S.A. restrict the processing of your personal data.
- The right to object to processing – You have the right to object to Estating S.A. processing of your personal data.
- The right to erasure, to restrict processing or to object to processing is contingent on data being no longer necessary for the performance of contractual, compliance or statutory obligations.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: data.protection@estating.com
4. Cookies
4.1 What are cookies?
Cookies are text files with small pieces of data — like a username and password — that are used to identify your computer as you use a computer network, to collect standard Internet log and visitor behaviour information.
When you visit our websites, we may collect information from you automatically through cookies or similar technology.
For further information, you may visit www.allaboutcookies.org.
4.2 How do we use cookies?
Estating S.A. uses cookies in a range of ways to improve your experience on our website,
including:
- Keeping you signed in
- Understanding how you use our website
4.3 What type of cookies do we use?
There are a number of different types of cookies, however, our website uses:
- Strictly necessary cookies – These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site
- Functionality – Estating S.A. uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
- Advertising – Estating S.A. uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We may also share online data collected through cookies with our advertising partners in the future. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website/app.
- Statistics cookies – Estating S.A. uses these cookies to collect information about how you use our website, like which pages you visited, and which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.
4.4 How to manage cookies?
You can set your browser to inform you about, restrict the use of or not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Estating S.A. will ask for your consent when you open our website.
5. Social Media
Estating SA is active on social media platforms and is processing user data for communication purposes. User data may be processed outside of the European Union which may restrict user data rights. Social media platforms maintain their own data protection rules. For further information or any requests please contact the platform providers directly
LinkedIn: Website: https://www.linkedin.com; Data privacy policy: https://www.linkedin.com/legal/privacy-policy;
Medium: website: https://medium.com; Data privacy policy: https://policy.medium.com/medium-privacy-policy-f03bf92035c9
6. Newsletter and other electronic communication
Estating SA is using newsletter, emails or other electronic communication only with your consent or if legally required.
You can register for any electronic communication by providing your email address. We may ask for your name and further information if necessary, to provide appropriate services to you.
Double-Opt-In: When you register for an electronic communication, we will send you an email and ask for verification of your registration to avoid misuse of email addresses. Estating SA is storing registration information, e.g. registration time and IP address.
7. User Account
Users, e.g. contractual partners, can register and open accounts. During the registration Estating SA will ask for mandatory details. Estating SA will collect data at all times a user registers, accesses or uses the personal account to prove who registered and to prevent any misuse.
Estating will delete user data after account closure, legal retention periods are preserved. If you want to delete your account, please send an email to data.protection@estating.com
8. Cloud-Dienste
Estating SA is using cloud service providers (Microsoft 365, Amazon Web Services) which are accessible through the Internet for several business processes, e.g. document management, calendar management, email, spreadsheet applications, presentations, video conferences, chats. In this context, personal data may be processed and stored on the service provider’s servers, as far as Estating processes data as described in this policy. The service providers also process usage data and meta data for security reasons and service optimization.
9. Client Relationship Management
Estating SA is using Hubspot Inc. Massachusetts USA, as client relationship management system. Hubspot confirms that no transfer of European data to any country or recipient not recognized as providing an adequate level of protection for personal data (within the meaning of applicable European Data Protection Laws) will take place, unless it first takes all such measures as are necessary to ensure the transfer is in compliance with applicable European Data Protection Laws. For further information please use the Hubspot data processing agreement:
10. Children’s Privacy – only for app?
These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
11. General Information
11.1 Privacy policies of other websites
Estating S.A. website contains links to other third party resources. Our privacy policy applies only to our website/app, so if you click on a link to another website, you should read their privacy policy.
Third-party resources are not under the control of Estating S.A., and Estating S.A. is not responsible for the contents of any of websites. The third-party hypertext links presented on this site are provided for your convenience only. The inclusion of any link on this website does not imply any recommendation, approval or endorsement of that site by Estating S.A.
11.2 Security
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
11.3 Chances to our privacy policy
Estating S.A. keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 15.04.2021
11.4 How to contact us
If you have any questions about Estating S.A.’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Email us at: data.protection@estating.com
11.5 How to contact the appropriate authority
Should you wish to report a complaint or if you feel that Estating S.A. has not addressed your concern in a satisfactory manner, you may contact the Luxembourg data protection supervisory authority Commission nationale pour la protection des données (CNPD)
To contact the CNPD, you may use the form on the CNPD website via the following link or use the contact form here.
The form may be completed online or sent to the CNPD by post to the following address:
Commission nationale pour la protection des données
Service des réclamations
15, Boulevard du Jazz
L-4370 Belvaux
