Privacy Policy atHomeGroup S.a.r.l.

Last update : 1st of April 2023

at atHomeGroup S.a.r.l we respect and protect your privacy and believe that transparency is the key to good governance of personal data.

It is important for you to know:

We always recommend that you read this entire Privacy Policy so that you know, in detail, what data we use for each service you request from us and how long we need to keep it.

In addition, this Privacy Policy may be modified by the unilateral decision of atHomeGroup, so we recommend that you consult it regularly.

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

    atHomeGroup 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

    Email: privacy@athome.eu

    Post: 5, rue Charles Darwin L-1433 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:

    As a “User “ (Buyer-Private Seller; Landlord-Tenant) we will collect:

    • Your identity information: name, last name, ID etc.
    • Your contact information: e-mail address, phone number, postal address, etc.
    • Information related to your personal life: family status, real estate project, incomes, information regarding the move, etc.
    • Information about your preferences
    • Other information regarding properties you are going to advertise, or you are looking for.
    • Commercial information (for example, if you want to receive communications or newsletter by email from the Group).
    • Information regarding connection, geolocation and/or browsing data (for example, the location data, the device identification, etc.).
    • Economic and financial data: details of your bank account and your address for billing purposes when you contract a charged service.

    As a “atHome partner” we will collect:

    • professional identification, in the event that you contract any of our services as a Professional Client (legal entity), we will process the following information relating to the natural person(s) representing you: name, surname(s), National ID Card/passport, telephone number, contact email address and, in some cases, documents proving your representation.
    • Economic and financial data: details of your bank account and your address for billing purposes.

    As a “Candidate” we will collect:

    • Identification data (e.g., name, address), Contact data (e.g., phone number, e-mail address).
    • Personal details (e.g., date of birth, nationality, civil status).
    • Information regarding your Academic curriculum such certifications; professional experience, career, and current employment; publications; membership status (associations, charities) and Leisure activities and interests.
    • Other personal information such the criminal record extract will be collected/ checked for some specific job positions only if you are the selected candidate.

    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 enjoy those services or functionalities.

    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:

      As a User we will process your personal information:

      • To manage your registration and grant you access to various functionalities, products, and services available.
      • To provide you with our real estate online services such buy, rent and make an appointment with an Agency, etc.
      • To estimate your property. We offer you to enter your properties details to get an online estimation for free. You can also confirm your property value with one of our agent partners in your zone for free. If you refine with an agent, this information is sent to those agencies selected by you to obtain a valuation based on the information you have provided.
      • To sell your property. This service offers you to list your properties on the website or get a detailed analysis of your property and sell it at the best price with the best agency. Please note that if you have requested this service, our Property Advisor will probably contact you by telephone or email to present the results.
      • To provide you with the move services and get free moving quotes
      • To provide you with our Customer Support services and process your request.
      • atHome will also process your data to issue invoices for services rendered, if applicable.

      For the contracting and provision of some services, it will be necessary for atHome to share your personal data with third party companies, so that they can deal with your request and provide you with the services.

      As atHome partner we will process your personal information:

      • To create an account by registering via www.athome.lu/pro/v2/login and manage your professional access as a user of the website or application, grant you access to its various functionalities, products, and services available to you.
      • As a representative or contact person, we manage your personal data to perform, maintain and conclude the commercial relationship agreement. This purpose includes processing your data, mainly to contact you for invoicing, provide 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 services.
      • To provide you with the Publication of your listing ads on our Website , Apps and in others social media and partner’s portals, unless you expressly indicate otherwise, we will process your data to issue invoices for services rendered.

      As a candidate, we will collect and process your personal information you have provided by sending an application, by responding to a job posting, by submitting your CV, etc. through the different recruitment portals for the purpose of selecting and recruiting new collaborators.

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

      • our tax accounting obligations.
      • When your request is related to the exercise of your rights on which we inform you below, or to claim on our products or services, we are legally permitted to process your data for compliance with our legal obligations.
      • If you have contracted a paid service, are a Private Advertiser or a representative or contact person of a Professional Advertiser, we will also process your data to handle any claims you may owe us for our services
      • The processing of criminal records extract from some candidates is a legal obligation Art. 6. (1) c GDPR) to which the controller is subject.

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

      • 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 a 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.
      • By sending a contact request for a property via our website and if you have provided your telephone number, we consider that we have a legitimate interest in contacting you by phone in order to improve our services and to offer you an appointment with one of our brokers, if necessary. You have the right to object by ticking the box "I object to receiving a phone call from atHomeGroup SARL in connection with my request" and you may at any time indicate your refusal to receive further solicitations by sending an e-mail to privacy@athome.eu.
      • We also consider that we have a legitimate interest to carry out the necessary verifications to detect and prevent potential fraud or fraudulent uses of the Platform. We understand that the processing of these data is positive for all the parties involved: for you, as it allows us to put in place measures to protect you against attempted fraud perpetrated by third parties; for Us, as it allows us to avoid unauthorized uses of the Platform; for all our customers and society, as it also protects their interest by ensuring that fraudulent activities are discouraged and detected when they do occur.
      • To 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, services reminders, or updates.
      • 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 to us such 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.
      • In accordance with the GDPR, we have carried out what is known as a “balancing test“. This is an internal analysis to confirm that our processing activities based on legitimate interest do not harm the interests of data subjects in the protection of their personal data. In any case, you have the right to object, at any time and by sending us a 4written request, on grounds relating to your particular situation, to the processing of your personal data based on the legitimate interests we pursue.

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

    • To create an alert, share your favorites and receive the new listing by email you have provided.
    • 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 Assurance S.a.r.l, atHome Finance and Taxx S.a.r.l. In this case, if you have given your prior consent, our colleagues will share some personal information with the relevant Group’s department or Entity in order to provide you with the services.
    • To receive communications to make a real estate project successful from the entities within the group (atHomeGroup S.a.r.l., atHome Finance S.a.r.l., atHome Assurance S.a.r.l., and Taxx S.a.r.l.) regarding insurance products, other finance services and Taxx S.a.r.l. services which could be interesting for your real estate project.
    • If you accept the use of analytical, preferences, automatic personalization, and advertising cookies, atHome will be able to create profiles based on your behaviour. Specifically, in order to carry out this activity, atHome will process the data obtained from the observation of your browsing habits on the Website and Apps, as well as the monitoring and analysis of your behavior when you browse in these environments. We will also carry out an analysis of your interests to determine which of our products and services best fit your profile, in order to show you recommendations within the Website and Apps that match your preferences. This processing involves the acceptance of cookies in terms of consent. For more information, you can consult our Cookies Policy.
    • Show you ads on the Internet which you may see when visiting websites and apps, for example, on social media. The ads you see may be random, but on other occasions they may be ads related to your preferences or browsing history.(If you want information about the use of your data and how advertising works on social media, we recommend you review the privacy policies of the social media sites on which you have profiles).

    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, estimation), we may be unable to fulfil our role or to comply with your requests.

    V. How do we share and 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, we are however required to communicate certain information to third parties:

    • To our partners such Real Estate Agencies, building contractors, Real Estate Partners and/ or private reference advertisers, integral Maintenance services, etc. when you request the corresponding support service.
    • 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.

    Data processed on behalf and Transfer of personal data to a Third Country

    • atHomeGroup S.à.r.l. uses some cloud-based recruitment software and recruitment portals as processors to process your Personal Data as a candidate.
    • atHomeGroup S.à.r.l. also contracts third parties such tax and legal consultants and archiving in any case in close relation and within the limits of the performance of their respective tasks and activities.
    • The Group also uses some IT providers for the management and maintenance of our information systems.
    • For service efficiency purposes, some of these providers can be located in territories outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union. In such cases, we inform you that we transfer your data with adequate safeguards and always keeping your data safe, using the most convenient international data transfer tools, in example the Standard Contractual Clauses and any relevant supplementary measures. You may consult the content of such Standard Contractual Clauses through the following link: https://commission.europa.eu/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

    VI. How long will your personal data be kept?

    • To manage your Website/ Apps user registration, we will process your data for the time during which you remain a registered user (meaning, until you decide to unsubscribe).
    • In the context of online services such simulation or estimation, we will retain your data for 6 months unless the user continues using the services. After that, the data will be anonymized and used for statistics reports.
    • For customer support services, we will process your data for the time necessary to meet your request or application.
    • ForAnalysis 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.
    • Marketing purposes: We will process your data until you unsubscribe or cancel your subscription for marketing purposes. Likewise, we will show you personalised ads until you change your device, browser and or cookies settings so that permission to do so is revoked.
    • In the context of recruitment process, atHomeGroup does not keep your personal data longer than necessary for managing recruitments applications. Your data will be deleted 12 months after the recruitment process has been finished unless you have given your consent to keep your cv for further opportunities. However, if you finally are hired, your data will remain as part of the employment file. We will not keep any criminal record except in case of specific job positions typified by law.
    • We will also keep your data for as long as necessary for the achievement of the purposes such a legal obligation imposes such retention.

    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 sending an e-mail to privacy@athome.eu 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 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.

    Should you not wish us to send information to third parties to show you ads, you can do it through several means such as changing your preferences on your device, browser and/or cookies settings, reviewing the privacy policies and settings of the social media sites on which you have profiles or sending us an email to the above mentioned email address informing us of your request.

    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 https://cnpd.public.lu/fr/support/contact.html

    VIII. Data Security

    atHomeGroup 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.

    atHomeGroup 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, atHomeGroup 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.

    Google Analytics

    For the purposes explained above, our platform uses the web analysis service Google Analytics, which is offered for users from Europe, the Middle East and Africa (EMEA) by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

    Google Analytics uses cookies and similar technologies to analyze our website based on your user behavior. Google will process the information obtained in order to evaluate your use of the website, to compile reports on website activity for the website operator and to provide other services relating to website activity and internet usage. The data arising in this context can be transmitted by Google to a server in the USA for evaluation and stored there. The IP address is shortened before the evaluation (IP anonymization) so that no conclusions can be drawn about your identity.

    The following data are processed by Google Analytics:

    • Anonymized IP address.
    • Referrer URL (previously visited page).
    • Pages accessed (date, time, URL, title, length of stay).
    • Downloaded files.
    • Links to other websites clicked.
    • if necessary, achievement of certain goals (conversions).
    • Technical information: operating system; Browser type, version, and language; Device type, brand, model, and resolution.
    • Approximate location (country and possibly city, based on anonymous IP address)

    Google Ads Conversion Tracking and Ads Remarketing (formerly AdWords)

    Our platform uses the "Google Ads" service, which is provided for users from the European Economic Area and Switzerland by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

    With Google Ads, customer actions defined by us (such as clicking on an ad, page views, downloads) are recorded and analyzed using “Google Ads conversion tracking”. We use “Google Ads Remarketing” to show you individualized advertising messages for our products on partner websites from Google. We also use the functions of "GA Audience" in this context. Both services use cookies and similar technologies for this.

    The data arising in this context can be transmitted by Google to a server in the USA for evaluation and stored there. In the event that personal data is transferred to the USA, we have concluded standard contractual clauses with Google.

    If you have not consented to the use of Google Ads, Google will only display general advertising that was not selected based on the information collected about you on this website. In addition to revoking your consent, you also have the option of deactivating personalized advertising in the advertising settings on Google.

    Non-personalized ads from Google Ads Manager

    We also use Google Ads Manager for Non-personalized ads which are not based on a user’s past behavior. The users are targeted using contextual information, including coarse (such as city-level, but not ZIP/postal code) geo-targeting based on current location, and content on the current site or app or current query terms.

    Google disallows all interest-based audience targeting, including demographic targeting and user list targeting. Although non-personalized ads don’t use cookies or mobile ad identifiers for ad targeting, they do still use cookies or mobile ad identifiers for aggregated ad reporting and to combat fraud and abuse.

    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.

    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 platform (Website and app)

    1) User registration and password

    When you register on the Web and Apps you will define a username and password that will allow you to log in, at any time, as a "Registered User" and, therefore, manage your relationship with atHome. The password can be changed.

    It is essential that you keep your password confidential at all times and do not make it available to third parties. It would be advisable not to use the same password for all your personal accounts so that, in the event of any third party accessing them without your consent or unlawfully, they cannot access the different accounts you have on different sites.

    2) Use of message archiving and internal chat messaging

    In order to optimize your experience, atHomeGroup 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 atHomeGroup 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 atHomeGroup 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.

    3) atHome/tools

    You have the possibility to use the login or sign in through a social network or another collaborator that enables this service (social login) when it is available on our login/sign in screen, either to link the social login to your account or by registering a new one. In that case, your login credentials, your name, and email / phone number (you might need to authorize it), will be imported from your social network or collaborator account. The use of this functionality may imply that you provide certain information about your activity to the social network or the collaborator. In any case, we recommend that you review your privacy settings and the privacy policies of the collaborator or social network to learn how these third parties process your data.

    What happen when you integrate your Facebook account with the atHome/tools software?

    When you integrate your Facebook account with our atHome tools software, we export relevant information to give you a better experience of our service.

    What data do we receive when you integrate with your Facebook account?

    We will receive your Facebook profile account such your name, surname, email address and telephone number

    Who will have access to your data once you integrate with your Facebook account?

    You, having integrated your Facebook account, and us, as users at administrator level, we will only import the information that is relevant for the integration with atHome/tools.

    4) Form + Invite

    a) "Send to a friend" form

    atHomeGroup S.à.r.l. will not process your user’s friend’s personal data provided in the "Share" form for any purposes.

    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 platform.

    XII. Google OAuth

    Information We Collect

    When you use Google OAuth to log into our Services, we collect the following information: Google Account Information: We may collect your name, email address, profile picture, and any other information that you have made publicly available in your Google account. OAuth Tokens: We collect OAuth tokens to authenticate your Google account and provide you with secure access to our Services.

    How We Use Your Information

    The information we collect through Google OAuth is used for the following purposes:

    • Authentication and Security: To authenticate your identity and provide secure access to our Services.
    • User Experience: To personalize and enhance your user experience by using your Google account information, such as your profile picture and name.
    • Communication: To send you notifications, updates, and other information related to your account and our Services.
    • Improvement of Services: To analyze and improve the performance and functionality of our Services.

    Sharing of Information

    We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information. We may share your information in the following circumstances:

    • Service Providers: We may share your information with third-party service providers who assist us in operating our Services, conducting our business, or serving our users, so long as those parties agree to keep this information confidential.
    • Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

    Data Security

    We implement a variety of security measures to maintain the safety of your personal information when you log into our Services using Google OAuth. These measures include:

    • Encryption of data during transmission and at rest.
    • Regular security assessments and audits.
    • Access controls to restrict access to personal information to only those employees and service providers who need it to perform their job duties.

    Data Retention

    We will retain your information for as long as your account is active or as needed to provide you with our Services. If you wish to cancel your account or request that we no longer use your information to provide you Services, please contact us at privacy@athome.eu. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

    Your Consent

    By using Google OAuth to log into our Services, you consent to this Privacy Policy.