Privacy Policy

1. Introduction

Xact Real Estate S.à r.l. ("Xact", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website xact.lu and use our services.

We comply with the General Data Protection Regulation (GDPR) (EU) 2016/679 and Luxembourg's data protection laws.

2. Data Controller

The data controller responsible for your personal data is:

3. Information We Collect

We collect information that you provide directly to us, including:

• Account Information: Name, email address, phone number, password when you create an account
• Property Listings: Property details, images, and descriptions you submit
• Contact Forms: Information you provide when contacting us or agents
• Communications: Messages sent through our platform
• Payment Information: When applicable, processed securely by our payment providers

Automatically Collected Information:

• IP address and device information
• Browser type and settings
• Pages visited and interactions on our website
• Referring website addresses
• Cookies and similar technologies (see our Cookie Policy)

4. How We Use Your Information

We use your personal data for the following purposes:

• To provide and maintain our services
• To process and manage property listings
• To facilitate communication between users and property agents
• To send you service-related communications
• To respond to your inquiries and provide customer support
• To improve and personalize your experience
• To comply with legal obligations
• To send marketing communications (with your consent)

5. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contract Performance: To provide our services and fulfill our contractual obligations
• Legitimate Interests: To improve our services and ensure security
• Consent: For marketing communications and optional features
• Legal Obligation: To comply with applicable laws and regulations

6. Data Sharing and Disclosure

We may share your information with:

• Property Agents: When you contact an agent about a property
• Service Providers: Third-party vendors who assist in operating our platform
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets

We do not sell your personal data to third parties.

7. Data Retention

We retain your personal data for as long as necessary to provide our services and fulfill the purposes described in this policy. Account data is retained until you request deletion. Property listings are retained for the duration they are active plus a reasonable period for legal and business purposes.

8. Your Rights

Under GDPR, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Request limitation of data processing
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at privacy@xact.lu.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure servers, and regular security assessments.

10. International Data Transfers

Your data is primarily processed within the European Union. If we transfer data outside the EU, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last Updated" date.

12. Contact Us & Complaints

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

You also have the right to lodge a complaint with the Luxembourg data protection authority (Commission Nationale pour la Protection des Données - CNPD) at cnpd.public.lu.