Privacy Policy

This Privacy Policy is valid from 1st January 2025.

I. Responsible Entity ("Controller") and Your Rights as the Data Subject

1. Responsible Entity

Property Square Real Estate & General Maintenance (hereinafter also referred to as "Property Square Real Estate & General Maintenance", "PSQ", "we" or "us") is responsible for the data processing governed by this Privacy Policy.

As per Article 4(7) of the GDPR, which defines the responsible entity as "the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data." PSQ may be construed as a responsible entity. PSQ acts in compliance with Article 13(1)(a) and Article 14(1)(a) of the GDPR, which requires the data controller to provide the data subject with certain information at the time the data is obtained.

Please note:

According to Article 28 of the GDPR, a licensee is to qualify as a third-party data processor that processes personal data on behalf of the primary controller. The responsibility for data processing, respectively in connection with the company web presences of the license partners of Property Square Real Estate & General Maintenance (hereinafter the "Company Web Presences") which can also be accessed via our Website rests with named licensees. They are, in this context, responsible for data processing such as contact inquiries and, in particular, for data processing in connection with the search, sale/rental and valuation of properties. This adheres to Article 6(1)(b) of the GDPR. This article allows controllers to process personal data if it is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

In the context of third-party licensees, this could mean that a controller could transfer personal data to a licensee if the licensee is providing a service or serves a function of utility to the data subject. This likewise falls under Article 6(1)(f), which allows controllers to process personal data if it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party which, in the given instance, would pertain to the provision of sale/rental and valuation of properties.

The current overview of any applicable license partners can be found on the PSQ Website.

Unless otherwise stated, our license partners are legally and commercially independent companies and are not part of the PSQ group of companies, as well as the (master) license partners which are by contract directly or indirectly linked to this group of companies. When we refer to "PSQ", we refer to the companies listed in Section I.1 of this Privacy Policy. This adheres to Article 26 of the GDPR, which states that under joint controller-ship of data there ought to be provision of information to data subjects pertaining to joint processing of their personal data. This is further reinforced by Article 14, which necessitates controllers to provide individuals with additional information about the joint processing of their personal data, such as the identity of the other controllers. PSQ is thus committed to transparency in regard to third-party data processing.

To find out which license partner is responsible for the data processing of the Company Web Presence that you are currently visiting, please refer to the respective data protection notices or the imprint at the bottom of the Company Web Presence in question.

2. Data Protection Officer

In accordance with Article 28 of the GDPR, appointment of a Data Protection Officer may be required in certain circumstances. PSQ will assess whether the appointment of a Data Protection Officer is required based on the nature and scope of personal data processing carried out by the Company and applicable law.

3. Your Rights as a Data Subject

The concept of a "data subject" and the associated rights are primarily defined in the General Data Protection Regulation (GDPR), specifically in Article 4(1) for the definition and Articles 12–23 for the rights of data subjects.

You may exercise your data protection rights against Property Square Real Estate & General Maintenance insofar as the Company is responsible for data processing in connection with our Website. PSQ adheres to applicable data protection requirements.

In summary, you have a right to:

• Information, as per Article 12
• Correction, as per Article 16
• Deletion (or request to be forgotten), as per Article 17
• Restriction of processing, as per Article 18
• Data portability, as per Article 20
• Object to the processing of your personal data, as per Article 21
• Complaint to supervisory authorities, as per Article 77(1)

In addition, you have the right, at any time, to object to the processing of your personal data for direct marketing purposes. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes as per Articles 21(2) and 21(3) of the GDPR.

According to Article 7(3) of the EU General Data Protection Regulation ("GDPR"), you may at any time revoke your initial consent towards us. Once consent is revoked, we will no longer continue to process the data where consent is the applicable legal basis, subject to any legal requirements that may require continued processing.

The definition of "consent" in the GDPR is found in Article 4(11). Consent must be freely given, specific, informed and unambiguous.

Please note that your right to the deletion of your data is subject to certain restrictions. For example, we do not have to or are not allowed to delete data that we are required to retain due to applicable legal retention periods. Data that we need to assert, exercise or defend due to legal claims are also excluded from your right of deletion.

The aforementioned restrictions to this right are enshrined in Article 17(3) of the GDPR. The right to deletion does not apply if processing is necessary for one of the following reasons:

• To exercise the right of freedom of expression and information.
• For compliance with a legal obligation which requires processing by applicable law or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
• For public interest reasons in the area of public health where applicable.
• For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), insofar as the right referred to in Article 17(1) is likely to render impossible or seriously impair the achievement of the objectives of that processing.
• For the establishment, exercise or defense of legal claims.

If you have a complaint about the way we process your data, you have recourse to the relevant supervisory authority as provided under applicable law.

We reserve the right to disclose information about you if we are required to do so by law enforcement bodies, regulatory authorities, courts or other lawful authorities.

II. Collection and Processing of Personal Data When Visiting Our Website

Article 15 of the General Data Protection Regulation (GDPR) stipulates the right of access and specifies that data subjects have the right to obtain from the data controller confirmation as to whether or not personal data concerning them is being processed, where and for what purpose.

Furthermore, the controller shall provide access to personal data in accordance with applicable law.

1. What Data Do We Process From You?

When you use our Website, we may process personal data, in particular:

• Your e-mail address, first name, last name, title, address, telephone number, property data, participation in events and webinars, and other information provided to us by you when you use individual services offered by PSQ via our Website, including contact inquiries, newsletter subscriptions, webinars, property valuations and other real estate-related services. Mandatory fields are marked with an asterisk where applicable.
• Personal data transmitted by your Internet browser each time you access the Website and stored as part of log files, also known as server log files. This data may include the IP address of the accessing computer, the name of the accessed page, date and time of access, URL from which the user accesses the page, the volume of data transmitted, status message for successful access and session ID number.
• Personal data in the form of location data, such as GPS data or a "Locate Me" function, where you have voluntarily activated or permitted such functionality through your browser, device or application.

We process personal data in accordance with applicable data protection laws and principles, including principles relating to lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality.

2. Purpose of the Processing

PSQ provides information regarding the purposes for which personal data is collected and processed.

We process the personal data of users of our Website (propsq.com) for the following purposes:

• Provision of online offers for our own and, where legally permitted, third-party advertising, based on applicable legal grounds.
• Fulfillment of user contact requests submitted to Property Square Real Estate & General Maintenance, including responding to inquiries relating to real estate sales, leasing, property management, valuation and other services.
• Where applicable, fulfillment of a valuation request concerning a property described by the user, as well as related services concerning the potential sale or rental of the property.
• Where applicable, organization of webinars, events, seminars and other activities. Where contact details need to be shared with an external lecturer, service provider or other third party, this will be done where legally permitted and, where required, with the user's consent.
• Sending e-mail newsletters containing PSQ offers, real estate opportunities and other marketing communications, to the extent permitted by applicable law or based on consent where required.
• Optimization and operations of the Website, including improving its functionality, quality, security and ease of use.
• Responding to customer inquiries and providing requested information, products and services.
• Complying with applicable legal, regulatory, accounting and reporting requirements.
• Protecting the rights, property and interests of PSQ, its clients, users and other relevant parties.

For the purposes of processing in connection with cookies and other tracking technologies, please refer to our Cookie Policy.

In summary, the legal basis for the processing of your personal data may include consent where processing is based on consent, contractual necessity where processing is necessary for the performance of a contract or steps prior to entering into a contract, legitimate interests where applicable, and compliance with legal obligations.

If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing of your personal data carried out based on the consent before its withdrawal.

Where processing is based on legitimate interests, you may also generally have the right to object to processing of personal data relating to you for reasons arising from your particular situation, subject to applicable law.

3. Disclosure of Your Personal Data

PSQ may disclose personal data to recipients or categories of recipients where necessary for the purposes described in this Privacy Policy and as permitted by applicable law.

Within the PSQ group of companies, where applicable, your data may be disclosed to PSQ-related companies or entities that require the data to fulfill contractual and legal obligations and to pursue legitimate interests in connection with Website services or based on your consent.

This may include entities or service providers that support the operation of our Website, direct marketing, IT infrastructure, events, property valuations, customer communication, newsletters and other services.

In addition, as a general principle, we will only pass on your personal data to third parties, including companies that do not belong to the PSQ group, where this is necessary for the fulfillment of a contract, where we or the third party have a legitimate interest in the transfer, where there is a legal obligation, or where you have given your consent where required.

Third parties to whom we may disclose your personal data may include:

• External professional advisers, such as lawyers, accountants and consultants.
• Technology, hosting, website and IT service providers.
• Marketing and communications service providers.
• Property developers, owners, landlords or other relevant real estate parties where necessary to fulfill your request and where legally permitted.
• Public authorities and regulatory bodies within their jurisdiction.
• Tax authorities, police, prosecutors and courts where legally required.
• Potential purchasers or acquirers of all or part of our assets and/or activities.
• Other third parties where you instruct us to disclose data or provide consent where required.

If your data is transferred to third parties based on legitimate interest, this will be explained in this Privacy Policy where required by applicable law.

4. Transfer of Data to Non-EEA Countries

In addition to the above paragraph "Disclosure of Your Personal Data", the following applies:

Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK and applicable data protection law requires safeguards, we will take appropriate measures to ensure that your data protection rights are adequately protected.

Where applicable, transfers may rely on an adequacy decision, appropriate safeguards such as standard contractual clauses, or another legally recognized transfer mechanism.

Copies of applicable safeguards may be made available upon request, subject to applicable confidentiality and legal restrictions.

5. Storage and Deletion of Your Data

Property Square Real Estate & General Maintenance will retain your personal data for the time necessary to achieve the purposes for which the data is collected, including any retention period required by applicable law, such as retention of accounting, contractual or regulatory records.

Personal data will generally not be retained for longer than is necessary for the purposes for which it is processed, unless a longer retention period is required or permitted by applicable law.

Where data is no longer required and there is no legal basis for continued retention, PSQ will take reasonable steps to delete, anonymize or otherwise securely dispose of the data.

6. Tracking Pixels and Analytics Tools

Information Collection via Tracking Technologies

We prioritize your privacy and believe in transparency. As part of our commitment to these principles, we provide information regarding tracking technologies that may be implemented on our platform and how they may interact with your personal data.

Google Analytics: We may utilize Google Analytics to better understand user interaction with our Website. Google Analytics may use cookies and similar technologies to collect information regarding website usage and visitor behavior. Where required by applicable law, the relevant cookies or tracking technologies will only be activated after obtaining the appropriate consent.

Facebook Pixel / Meta Pixel: We may use Meta/Facebook Pixel technology to measure the effectiveness of our advertising campaigns and understand interactions resulting from our advertisements. The use of such technology will be subject to applicable consent requirements.

Snap-chat Pixel: We may use Snap-chat Pixel to measure the performance of advertising campaigns on Snap-chat and understand user interactions originating from our advertisements.

Google Ads: We may use Google Ads conversion tracking and related technologies to evaluate and optimize advertising campaigns and understand interactions between advertisements and our Website.

TikTok Pixel: We may use TikTok Pixel to measure the efficiency of advertising campaigns and understand user engagement resulting from TikTok advertisements.

Yandex Metrics: Where implemented, Yandex Metrics may provide analytics regarding Website traffic and user behavior. Its use will be subject to applicable privacy and consent requirements.

VK Pixel: Where implemented, VK Pixel may be used to monitor the effectiveness of VK advertising campaigns and understand interactions with our Website.

Microsoft Clarity: We may use Microsoft Clarity or similar analytics tools to gain insights into user behavior and improve the Website's user experience. Such tools may collect information relating to interactions such as clicks, mouse movements and scrolling actions, subject to applicable privacy and consent requirements.

Where cookies or other tracking technologies require consent under applicable law, users may manage their preferences through our cookie consent mechanism.

For more information regarding cookies and tracking technologies, please refer to our Cookie Policy.