1. Title of this declaration

Your life is important to us.

Luxury Places ("we") attaches great importance to the protection of personal data and collects and processes personal data about you and others in a confidential manner in accordance with applicable legal provisions.

Most of the content on our website can be freely used. However, we use common technologies to measure and improve the performance of our website and collect data for this purpose.

In this data protection declaration, we describe how we process your data when you visit, browse, or use the website www.luxuryplaces.ch and/or when you use our services or when you are in contact with us within the framework of a contract, particularly in the context of the conclusion and execution of a brokerage contract, search mandate, property valuation, and/or real estate advice. The processing of data is limited to the necessary data and for the duration necessary for the provision of our services or for the duration provided by law.

By using our services, you accept this Privacy Policy.

2. Data Controller

Luxury Places SA is the data controller under this privacy policy. It is our responsibility to determine whether processing takes place, for what purposes it serves, and how it is designed.

Please note that if you provide us with personal data of third parties, we assume that you are authorized to do so and that the data is accurate. Please ensure that these individuals are aware of this Privacy Policy and only provide us with their personal data if you are authorized to do so.

For questions regarding the processing of your data and to exercise your rights, you can contact us as follows:

• By mail:

Luxury Places SA

Data Protection

Rue du Grand-Pont 2bis

1003 Lausanne

• By email:

info@luxury-places.ch

3. Definitions

By "personal data" also referred to as "data" herein, we mean all information relating to an identified or identifiable natural person, meaning that the identity of that person can be established from the data itself or through additional data.

"Sensitive personal data" is a subcategory of personal data that is specially protected by applicable data protection legislation. Sensitive personal data includes, for example, data revealing ethnic origin, data concerning health, data concerning religious or philosophical beliefs, biometric data for the purpose of uniquely identifying a natural person, and data relating to membership in a trade union.

The term "processing" refers to any operation performed on personal data, such as collection, storage, use, modification, communication, and erasure.

The term "communication" refers to the transmission of personal data or making it accessible by any means whatsoever.

4. Types of Data Collected

We collect the following basic data that we receive from you, from people you work for, or from third parties such as contractual partners, as well as from public sources such as public records or the internet:

1. Identity and contact data (e.g., name, first name, address, phone number, email address);
2. Customer data (e.g., date of birth, nationality, gender, marital status, profession, title, passport number, etc.);
3. Information about the real estate and/or search criteria for real estate (including details of your relationship with us);
4. Business data (data from commercial registers, land registers, interests in companies, employment, signing authorizations);
5. Financial information (e.g., bank details);
6. Marketing information (e.g., newsletter subscription, email alerts); client portal
7. Information provided for participating in meetings, seminars, or events;
8. For employees/job applicants online, basic data also includes social security number, marital status, curriculum vitae, bank details, job interview and evaluation reports, absences due to illness and other reasons;
9. Any other information about you that you provide to us.

We collect contractual data, which are data generated in the context of the conclusion and/or performance of a contract. This includes, for example, information about contracts (date of conclusion, type of contract, information about the contract in question), about contractual services, and contract administration (invoicing, technical support, payments, reminders, and debt collection, etc.), data relating to the period preceding the conclusion of the contract, information necessary for the performance of the contract. We collect this information from you, contractual partners, and third parties involved in the performance of the contract, as well as from third-party sources (such as credit information providers) and public sources.

Most of the content on our website can be used freely without having to provide personal data. However, we automatically collect data that is used for analysis purposes. In particular, we collect technical data (collection of IP address and other technical data to ensure the functionality and security of the offers available on our website).

The types of personal data that this website collects directly or through third parties include cookies, usage data, email address, phone number, first name, last name, company name, physical address, city, website, IP address, language, date and time, messages.

5. Purpose of Data Processing

We process personal data, particularly in the context of our professional real estate brokerage activities. The purposes for which we process personal data are always related to our professional activities, particularly for the following purposes:

1. To communicate with you, respond to your inquiries, and enable us to contact you in case of questions (by phone or during online meetings);
2. To conclude and execute contracts with you, with our clients, business partners, particularly in the context of real estate brokerage;
3. For the purchase of products or services from our suppliers, partners, or assistants;
4. For marketing, advertising, and relationship management (newsletter, events, invitations, etc.);
5. For the development of our offers, services, and websites, and other platforms on which we are present; communication with you; communication with third parties and processing of their requests (e.g., applications, media inquiries);
6. For market research, improving our services and business activities;
7. To ensure the operation of our business, in particular, IT, our websites, and other platforms, as well as computer security measures, buildings, facilities, and the protection of our employees and other persons and the assets entrusted to us;
8. To comply with laws, regulations, and recommendations of authorities;
9. In the context of our risk management and corporate governance, as well as for the exercise of rights and defense in legal disputes and administrative proceedings;
10. For other purposes, particularly within the framework of our internal processes and administration.

In the particular case where you have given us your consent for the processing of your personal data for specific purposes, we process your personal data within the framework and on the basis of this consent, to the extent that we do not have any other legal basis and where such a basis is needed.

6. Legal Basis for Processing

Based on the purpose of the processing activity (see point V. above), the processing of your information and personal data is carried out if:

1. It is necessary for the conclusion or performance of a contract related to the requested services or the performance of our obligations arising from such a contract, for example, when we process your data for the purposes mentioned in Sections Va - Vc (as well as for data transfers described in this Section VI);
2. It is necessary for the legitimate interests of Luxury Places SA, without unduly infringing on your interests or fundamental rights and freedoms;
3. It is necessary for us to comply with our legal or regulatory obligations;
4. Your information and personal data are processed with your consent, which we request from you from time to time (for example, when required by law), or which are processed with your explicit consent, possibly necessary, when it comes to sensitive personal data or special categories of personal data. You can withdraw your consent at any time with effect for the future by sending us a written notification (by mail) or, unless otherwise indicated or agreed, by sending us an email to the addresses listed in Section II.

When it comes to sensitive personal data or special categories of personal data necessary for the establishment, it is necessary for the performance of the service entrusted to us, or when the processing concerns personal data that are manifestly accessible to all.

Here are examples of the aforementioned "legitimate interests":

1. Pursuing certain purposes from Sections Vd to Vj;
2. Exercising our rights under Articles 26 and 27 of the Federal Constitution of the Swiss Confederation or Articles 16 and 17 of the Charter of Fundamental Rights of the European Union, including our freedom of business and right to property;
3. Disclosures mentioned in Section VII below, providing products and services to ensure a high and consistent level of service and satisfaction for our customers, employees, and other stakeholders;
4. Fulfilling our obligation to be accountable and to legal requirements worldwide, to the extent not already recognized as a legal basis by the applicable data protection legislation (e.g., in the case of the GDPR, laws in the EEA, and in the case of the LPD, Swiss law);
5. in all cases, provided that your privacy interests do not override these interests.

7. Data Sharing

As part of our business activities, website operations, legal obligations, protection of our legitimate interests, and other purposes stated in Section V, we may disclose your personal data to third parties, including the following categories of recipients:

1. Employees: We may share personal data within our agencies; if we do, the use and sharing of your personal data are subject to this statement;
2. Service Providers: We collaborate with service providers for data processing. These providers act on our behalf or as joint controllers of the processing with us. They may also receive data about you from us as independent controllers of the processing. These providers include subcontractors or agents who perform various essential functions for the operation of our business. They may include, for example, banks, insurers, counterparties and their representatives (guarantors, financiers, affiliated companies, reference persons, experts, etc.), as well as other involved parties such as hosting providers, email communication services, after-sales services, analytics, marketing, and advertising. They operate based on our instructions and in accordance with this statement and other appropriate confidentiality and security measures.
3. Contractual Partners: We ask these partners to send you or display advertisements based on your data only with your consent (for online advertising).
4. Authorities: We may disclose personal data to agencies, courts, and other authorities in Switzerland and abroad if we are legally obligated or authorized to make such disclosures or if it seems necessary to protect our interests.

8. Retention Period

Personal data is processed and stored as long as necessary to achieve our processing purposes, comply with legal retention periods, and meet our legitimate interests in documentation and evidence preservation, or when retention is a technical and/or legal requirement.

Once the retention period has expired or processing has ceased in the context of our usual processes, we will delete or anonymize your personal data.

9. Data Protection Measures

We take reasonable measures to ensure the necessary security of your personal data, ensuring their confidentiality, integrity, and availability. These measures are implemented considering the state of the art of technology, implementation costs, the nature of the data, and the risks of processing.

Our goal is to protect them against any unauthorized or unlawful processing, and to minimize the risk of loss, accidental alteration, communication, or unauthorized access.

10. Use of Cookies

Our website uses cookies to facilitate the use of our offering and improve your browsing experience by distinguishing you from other users. Some cookies remain stored on your device until you delete them, allowing our site to recognize your browser on your next visits. We do not intend to identify you, although it may be possible for us or third parties we engage to do so by linking with registration data.

We use the following types of cookies:

• Necessary Cookies: Some cookies are necessary for the operation of the website. For example, they ensure that you can navigate from one page to another without losing information entered into a form. These cookies may also enable the storage of information you have entered for future visits to the site (e.g., language settings, consents, automatic login functionality, etc.). These cookies exist only temporarily. If you block them, the website may not function properly.
• Performance Cookies: To optimize our website and related offerings to better suit user needs, we use cookies to record and analyze the use of our website, potentially extending beyond a session. For this purpose, we use third-party analytics services.
• Marketing Cookies: We and our advertising partners tailor advertising offerings to your interests, notably by limiting the number of times you see an ad or selecting relevant ads for you.

We currently use services from service providers and advertising partners (when they use data about you or cookies placed on your computer for advertising purposes) such as :

• Google Tag Manager - Enable tags for third-party scripts that may place cookies on the user's device.
• Cookie band - Save the response of the cookie band to hide it.
• Google Maps - Show Google Maps and include cookies linked to this service.
• Session - Used to know if you are logged to the website.

If you do not wish this, you can configure your browser at any time to inform you about the placement of cookies and allow you to permit them on a case-by-case basis. Disabling cookies may restrict the functionality of our website.

11. Your Rights

Regarding the processing of your personal data, you have the following rights if you are in Switzerland or the European Economic Area (EEA):

1. The right to know if we process your data and to access your processed personal data;
2. The right to correct or rectify inaccurate personal data;
3. The right to limit or object to the processing of your personal data;
4. The right to delete your personal data;
5. The right to data portability;
6. The right to withdraw your consent when our processing is based on your consent.

These rights are granted to you in accordance with the provisions of data protection law in Switzerland and the GDPR in Europe. Please note that these rights are not unlimited and may be subject to restrictions.

To prevent abuse, exercising your rights requires you to prove your identity (for example, by providing a copy of an identity document). To assert your rights, you can contact us at the addresses provided in Section 2.

You also have these rights against other parties who cooperate with us as independent data controllers. You can contact them directly if you wish to exercise your rights regarding their processing of your data.

You also have the right to enforce your rights in court or file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (www.edoeb.admin.ch).

12. Links to third-party providers

Our service may contain links to third-party websites. Accessing and using such linked websites is not subject to this Privacy Policy, but to the privacy policies of those third-party websites. We are not responsible for the information practices of these third-party sites.

13. Information not included in this policy

Further information regarding the collection or processing of personal data can be requested from us at any time. Please refer to the contact details provided in Section 2.

14. Changes to this privacy policy

We reserve the right to modify this Privacy Policy at any time. If the modifications affect processing activities based on your consent, we must obtain new consent from you when necessary.

If you continue to use the website after the modification, you will be deemed to have accepted the new Privacy Policy. It is strongly recommended to frequently check this page, referring to the date of the last modification indicated at the bottom.

Last updated: 02.05.2024