Privacy Policy atHome Finance

at atHome Finance we respect and protect your privacy and believe that transparency is the key to good governance of personal data.

This Privacy policy explains what data we collect about you and how we use it, as well as the rights you have and how you can exercise them. We undertake to implement all appropriate means to preserve the confidentiality and integrity of your personal data.

I.Who are we?

1. Contact details Data Controller

atHome Finance Sàrl, located in 5, rue Charles Darwin, L-1433 Luxembourg Grand Duchy of Luxembourg, carries out the processing of personal data, supplied by you or otherwise acquired during the performance of the services, as the controller of such processing.

2. Contact details Group Data Protection Officer

Post: 5, rue Charles Darwin, L-1433 Luxembourg Grand Duchy of Luxembourg

II.What personal data do we collect?

Only personal data strictly necessary for the achievement of the purposes mentioned below will be processed. In the context of our activities, and depending on the services you use, we may process the following data:

  • Your identity information: last name, first name, identification data, civil status, and date of birth, etc.
  • Your contact information: e-mail address, phone number, postal address, etc.
  • Information related to your personal life: family status, real estate project, etc.
  • Information related to your working life: work situation, education, etc.
  • Your economic and financial information: income, expenses, financial situation, bank data, etc.
  • Information regarding connection, geolocation and/or browsing data (for example, the location data, the device identification, etc.).
  • Information about your preferences.
  • Commercial information (for example, if you want to receive communications or newsletter by email from the Group)

If you are acting as “atHome finance partner”, we will collect your identity and professional information such last name, first name, professional identification, Company’s representant contact information such e-mail address, phone number, postal address, bank account details, etc.

Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the website, Platform etc., we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please consider that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities.

We may also use data obtained from external sources, in particular in the following cases:

  • The data obtained by the finance partner (bank, financial manager, family office, Real Estate Agencies, etc.) who contacts the "broker" with a view to collaborating on your file and this in complete transparency with you. In this case, your financial partner must inform you about the transferring of your contact details to us.
  • Updating data (e.g., concerning the composition of your family, your address, your expired identity document, etc.).

In some cases, we may collect personal data relating to people other than you, for example your ascendants, your children, your partner, the beneficiary(ies). If you provide us with such data, you undertake to inform the persons concerned.

III.How do we use your personal data?

1.For what purposes and on what legal basis do we use personal data?

Depending on the purpose for which we process your data from time to time, as explained below, we need to process one or other data, which will in general be, depending on each case, as follows:

We will first use your personal information to perform our contractual obligations to you or in order to take steps at the request of the data subject prior to entering into a contract, including to:

  • To make an appointment with our advisors/brokers.
  • To provide online services on the website such formulate one or more financing plans; to get a mortgage simulation, seek financing from banking partners, assess your borrowing capacity estimation, etc.
  • To provide customer support services through different channels.

As an atHome Finance partners we will use your personal information:

  • To manage your registration as a user on the website or application, grant you access to its various functionalities, products, and services available to you.
  • To perform and conclude the partner relationship agreement. This purpose includes processing your data, mainly to contact you for updates or informative notices related to the contracted functionalities, products, or services, including statistics, quality surveys and to be able to establish the degree of customer satisfaction with the provided service.

We may also use your personal data to comply with our legal obligations, in particular with regard:

  • To prevention of money laundering and terrorist financing.
  • Our tax accounting obligations.
  • When your request is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations.

Based on our legitimate interest, we may process your information in order to:

  • Manage our customers and have a global view of customers (for example by compiling statistics of our customers, product surveys in order to know who they are and to know them better).
  • We consider that we have legitimate interest in answering the requests or queries raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the queries raised.
  • Prevent abuse, fraud, and infringement; protect the company's assets.
  • Ensure the security of the company's property and people, as well as networks and IT systems.
  • Establish, exercise, defend and preserve the rights of the company or the persons it may represent, for example in disputes.
  • To send you communications regarding “products or services reminders”.
  • To offer you personalized services or to show you customized information, whether on our website, platform or those of third parties, as well as to engage in data enrichment we consider that we have a legitimate interest to conduct a profiling with the information that we have about you (such as your browsing, preferences, etc.) and the personal data that you have provided us, such as the age range language, since we understand that the data processing of these data is also beneficial to you because it allows you to improve your user experience and access the information in accordance with your preferences.
  • Usability and quality analysis to improve our services. - We consider that we have a legitimate interest in analyzing the usability and degree of user satisfaction as we understand that the processing of this data is also beneficial to you because the purpose is to improve the user and customer experience and to offer a higher quality service.
  • To invite you and participate as a Financial Partner to events organized by atHome group.

Based on consent, we may process your information in order to:

  • To provide you with and assist you in any services of interest to you that are offered by entities of the group such as atHome Property Advisor, atHome Assurance S.a.r.l and Taxx S.a.r.l. In this case, if you have given your prior consent, our Brokers will share some of your personal information with the relevant group department or entity in order to provide you with these services.
  • To receive communications to make a real estate project successful from the entities within the group (atHome Group S.a.r.l., atHome Finance S.a.r.l., atHome Assurance S.a.r.l and Taxx S.a.r.l.) With your consent, you will receive by email communications regarding insurance products, other finance services and Taxx S.a.r.l. services which could be interesting for your real estate project.
  • In case you have provided your phone number to get a mortgage simulation, you might receive follow-up calls by phone (based on opt-out) in order to improve our services and propose you a meeting with one of our brokers if relevant.
  • To receive newsletters from the group if you have subscribed to it. Remember that you can unsubscribe from the Newsletter at any time and free of charge thanks to the information we provide in each communication.

We may not use your personal data for new purposes. In any event, prior to using personal data for other purposes, we will inform you about such change to this Privacy Notice and, in case of new processing activities based on the consent, we will offer you the chance to decline participation in these changes.

2.Do we use your personal data to make automated decisions?

We do not use your data for profiling purposes or to make automated decisions. If we decide in the future to do so, we will inform you in advance and explain the logic behind such decision-making and the significance and intended consequences of such processing.

IV.Why is it necessary to provide us with your personal data?

If you refuse to provide us with the data requested in connection with certain services (such as, for example, formulate one or more financing plans or seek financing from banking partners), we may be unable to fulfil our role or to comply with your requests.

V.Where and how do we transfer your personal data?

1.Who has access to your personal data and to whom is it transferred?

In order to protect your privacy, the people who are authorized to access your data are precisely determined according to their tasks.

In order to achieve the purposes detailed above (see point 3.1), we are however required to communicate certain information to third parties:

  • Our banking, insurance, and real estate partners, who will only process it for the purposes mentioned above and within the framework of their contractual relationship with at Home Finance. Those will act as Controller or as Processors appointed from at Home Finance with a specific Data Protections Agreement under Art. 28 of the GDPR.
  • For the proper performance of our intermediary missions, your data may be transmitted to and/or processed by our IT subcontractors.
  • In order to comply with our legal obligations, your data may be transmitted to the authorities and our regulators.
  • In the event of a dispute, your data may be transmitted to our lawyers and used to defend our case in court.
  • If this is necessary to pursue the purposes mentioned above, your personal data may also be communicated or made available to other entities within the group of which at Home Finance is a member for internal administrative purposes.

2.Where do we transfer your personal data?

Under no circumstances will we transfer your personal data outside the EEA.

VI.How long will your personal data be kept?

  • In accordance with the provision governing the retention of personal data and with regard to the nature of the banking operations, the retention period of your personal data is set at thirty-six (36) months or up to five (5) years after the total repayment of your credit in the event that you have taken out a real estate loan by the intermediary of atHome Finance.
  • For the registration as a Financial Partner User, we will process your data for the time during which you remain a registered user (meaning, until the relationship has finished).
  • For customer support services, we will process your data for the time necessary to meet your request or application.
  • For Analysis of usability and quality, we will process your data occasionally for the time during which we proceed to carry out a specific quality action or survey or until we anonymize your browsing data.
  • We will also keep your data for as long as necessary for the achievement of the purposes such a legal obligation imposes such retention.
  • In the context of online services such mortgage simulation, we will keep your data 6 months except the user continues using the services. After that, the data will be anonymized and used for statistics reports.
  • We will process your data until you unsubscribe or cancel your subscription to the marketing communications.

VII.What are your rights and how can you exercise them?

We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, you may exercise your rights free of charge by writing us an e-mail to our e-mail address (, simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.

Below is a brief description of these rights.

Right of access – You may, at any time, obtain confirmation as to whether or not personal data concerning you are being processed and, where applicable, access to such data.

Right to rectification – You may, at any time, by sending us a written request, obtain the rectification of personal data concerning you that is inaccurate. You can, in the same way, request that incomplete data be completed.

Right to erasure – You may, at any time, by sending us a written request, obtain the erasure of your personal data.

Right to restriction of processing – Where restriction of processing is granted, personal data may only be processed with the consent of the data subject, or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for important reasons of public interest.

Right to object – You have the right to object, at any time and by sending us a written request, on grounds relating to your particular situation, to the processing of your personal data based on the legitimate interests we pursue. We will no longer process this personal data unless it is demonstrated that there are compelling legitimate grounds for the processing that override your interests and rights and freedoms, or for the establishment, exercise, or defense of legal claims. When your personal data is processed for direct marketing purposes, you have the right to object to this processing at any time.

Right to portability – You have the right, by sending us a written request, to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and to transmit this data to another controller.

Right to withdraw consent – Where processing is based on your consent, you have the right to withdraw consent at any time by sending us a written request. The withdrawal of your consent will not affect the lawfulness of the processing based on the consent made before the withdrawal of it.

Right to lodge a complaint – We make our best efforts to ensure compliance with our legal data protection obligations and to respond as quickly as possible to any complaint addressed to us in this regard.

In the event that you are not satisfied with the response received, you have the possibility to lodge a complaint with the Data Protection Authority.

National Commission for Data Protection
15, boulevard du Jazz
L-4730 Esch-sur-Alzette
Phone: (+352) 26 10 60 -1

VIII.Data Security

atHome Finance undertakes to ensure the protection and security of Personal Data, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties or used in an unlawful manner.

atHome Finance maintains adequate physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction. As part of those safeguards, atHome Finance employs sophisticated technology designed to protect Personal Data during its processing and prevent processing errors or unauthorized acts of third parties.

IX.Information on cookies

We use cookies to facilitate your browsing in the Platform, understand how you interact with us and, in certain cases, to be able to show you advertisements in accordance with your browsing habits.a

Please read our Cookies Policy to understand with greater detail the cookies that we use, their purpose, how to manage your preferences, as well as other information of interest.

X.Additional information on certain functionalities of the Website and Apps

Use of message archiving and internal chat messaging

In order to optimize your experience, atHome Finance makes available to you the message archive service (sent or received) and internal messaging (chat) of the Website and Apps through which Users, Registered, Users can initiate contact and give continuity to their communications. By accepting this Privacy Policy, you expressly consent to atHome Finance storing these conversations, accessing them, and using automated systems to verify them to ensure compliance with the general conditions of use of the service, development, and improvement of our services, as well as the other purposes described in this policy.

We reserve the right to block access to the messaging service if, at our discretion, we believe that communications may contain malicious content, spam, or pose a risk to Users, Registered Users. Since atHome Finance provides various forms of contact, Users, Registered Users or Advertisers may choose to communicate with you directly through the email address provided, your telephone number or through other communication channels outside at home’s control.

XI.Changes of the privacy notice

We may amend the information contained in this Privacy Policy when we consider this appropriate.

We suggest you review this Privacy Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website and our App.