Privacy Policy
We take the protection of your personal data very seriously. This policy explains how we collect, use and protect your information.
1. Introduction and Commitment
The CMO.lu S.à r.l.-S undertakes to protect and respect your privacy. This privacy policy explains how we process the personal data we collect when you use our website viager.lu or our services.
We strictly comply with the General Data Protection Regulation (GDPR) and the Luxembourg law on the protection of personal data.
🛡️ Our Commitment
- • Total transparency on the use of your data
- • Maximum security of your personal information
- • Strict respect for your rights and preferences
- • No sale or transfer of your data to third parties
2. Data Controller
Data controller:
The CMO.lu S.à r.l.-S
4 Rue Josy Printz
5841 Hesperange
Grand Duchy of Luxembourg
Email: dpo@viager.lu
Telephone: +352 20 42 04 70
Data Protection Officer (DPO):
For any question relating to the protection of your data, you can contact our DPO at the address: dpo@viager.lu
3. Personal Data Collected
📋 Identification data
- • Surname and first name
- • Postal address
- • Telephone number
- • Email address
- • Date of birth (for life annuity calculations)
🏠 Property data
- • Location of the property
- • Type and characteristics of the property
- • Area and condition of the property
- • Value estimate
- • Life annuity preferences (vacant/occupied)
💻 Technical data
- • IP address
- • Browser type and version
- • Operating system
- • Pages visited and duration of visit
- • Cookies and trackers
Minimisation principle: We only collect the data strictly necessary to provide you with our life annuity expertise services and personalised support.
4. Purposes and Legal Bases
🏠 Life Annuity Estimate and Advice
Purpose: Carry out life annuity estimates and provide personalised advice
Legal basis: Performance of pre-contractual measures / Legitimate interest
Duration: 3 years after last contact
📞 Client Communication
Purpose: Respond to your requests and ensure commercial follow-up
Legal basis: Consent / Performance of the contract
Duration: Duration of the contractual relationship + 5 years
📊 Service Improvement
Purpose: Analyse site usage and improve our services
Legal basis: Legitimate interest
Duration: 25 months (analytical cookies)
⚖️ Legal Obligations
Purpose: Compliance with legal obligations (anti-money laundering, etc.)
Legal basis: Legal obligation
Duration: According to legal obligations (5 to 10 years)
5. Sharing and Transfer of Data
🚫 Principle: No Sale of Data
We never sell your personal data to third parties. Your information remains confidential and is only shared in the strictly necessary cases listed below.
Authorised sharing only:
- 🏦 Professional partners: Notaries, real estate experts, financial institutions (only with your explicit consent)
- 💻 Technical providers: Web hosting, analysis tools (subject to strict confidentiality agreements)
- ⚖️ Legal authorities: On judicial or administrative request within the legal framework
🌍 International Transfers
Certain technical services may be hosted outside the EU (e.g. Google Analytics, web hosting). These transfers are governed by standard contractual clauses approved by the European Commission.
6. Cookies and Trackers
Our site uses cookies to improve your experience and analyse our audience. You retain full control over these cookies.
✅ Essential Cookies
Necessary for the operation of the site. Impossible to disable.
Duration: Session
📊 Analytical Cookies
Audience measurement (Google Analytics). You can refuse them.
Duration: 25 months
🎯 Preference Cookies
Remember your choices on the site. You can manage them.
Duration: 12 months
⚙️ Cookie Management
You can modify your cookie preferences at any time via:
- • The cookie banner on your first visit
- • Your browser settings
- • Our preference centre (link at the bottom of the page)
7. Data Security
The security of your personal data is our absolute priority. We implement appropriate technical and organisational measures.
🔒 Technical Measures
- • SSL/TLS encryption (HTTPS)
- • Certified secure hosting
- • Regular encrypted backups
- • Firewalls and antivirus
- • 24/7 monitoring
👥 Organisational Measures
- • Limited access to data (least privilege principle)
- • Regular staff training
- • Strict password policy
- • Access controls and traceability
- • Incident management procedures
🚨 In the Event of an Incident
In the event of a data breach likely to create a risk to your rights, we will inform you within 72 hours in accordance with the GDPR.
8. Your Rights
In accordance with the GDPR, you have important rights concerning your personal data. Here is how to exercise them:
👁️ Right of Access
Know the data we hold about you
✏️ Right of Rectification
Correct or complete your data
🗑️ Right of Erasure
Request the deletion of your data
⏸️ Right of Restriction
Restrict the processing of your data
📦 Right to Portability
Retrieve your data in a readable format
🚫 Right to Object
Object to the processing on legitimate grounds
🤖 Automated Decision
Not be subject to a decision based solely on an algorithm
❌ Withdrawal of Consent
Withdraw your consent at any time
📧 How to Exercise Your Rights
To exercise your rights, contact us:
- Email: dpo@viager.lu
- Post: The CMO.lu S.à r.l.-S - DPO, 4 Rue Josy Printz, L-5841 Hesperange
- Response time: 1 month maximum
- Documents to attach: Copy of your identity document
⚖️ Right to Complain
If you consider that your rights are not being respected, you can lodge a complaint with the National Commission for Data Protection (CNPD):
cnpd.lu - Tel: +352 26 10 60 - 1
9. Retention Period
We retain your personal data only for the period necessary for the purposes pursued, in accordance with legal obligations.
👤 Client Data (Prospect)
3 years after the last contact if there is no contractual relationship
📋 Contractual Data
Duration of the contract + 5 years (commercial limitation period)
📊 Analytics Data
25 months (Google Analytics cookies)
⚖️ Legal Obligations
5 to 10 years depending on the nature (anti-money laundering, taxation)
On expiry of these periods, your data is automatically deleted from our systems in a secure manner.
10. Modifications to this Policy
This privacy policy may be modified to reflect changes in our services or in the regulations. We will inform you of any significant change by email or via a notification on our site.
We encourage you to consult this page regularly to stay informed of our data protection practices.
Current version: 2.0
Last update: 22 September 2024
Next planned revision: 22 September 2025
11. Contact Us
For any question concerning this privacy policy or your personal data:
📧 Data Protection Officer
Email: dpo@viager.lu
Guaranteed response: 48 business hours
📞 Direct Contact
Telephone: +352 20 42 04 70
Hours: Mon-Fri 9 a.m.-6 p.m.
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