Privacy Policy

1. Overview

This Privacy Notice describes how Hemingway Real Estate (Lux) S.C.Sp (together with its subsidiaries, “Hemingway Solutions”, “us”, “we” or “our”) gathers and uses personal information about you when you communicate with us and when you visit this website and any other of Hemingway Solutions’ websites that link to this Privacy Notice (collectively, the “Sites”); how we protect and share this information; and the rights you may have in relation to this information.

Please read this Privacy Notice carefully and consult our Terms of Use for more information about the general terms and conditions regarding your use of the Sites.

If you have any questions or concerns about this Privacy Notice, if you object to our uses of your personal information, or if you wish to exercise your rights under applicable law, please contact us in writing.

2. The Types of Information We Collect and How We Collect It

When you visit and browse the Sites or communicate with us, you may directly provide us with information, including personal information, and we will collect certain information automatically or through other sources. When we use the term “personal information” or “personal data”, we mean any information that can help us directly or indirectly identify you, as defined under applicable data protection law.

2.1 Information You Provide to Us

In order to access certain services provided via the Sites or to request certain information from Hemingway Solutions via the Sites, you may be required to provide certain personal information. Depending on how you interact with us and which Site you are visiting, we may collect the following categories of personal data from or about you:

  • Identifiers and similar information — such as name, address, date and place of birth, email address, telephone number, tax identification number, passport and other national identity details, Internet Protocol (“IP”) address, username, password, and other online identifiers;
  • Financial information — such as bank account details, signature, or other financial information;
  • Personal details — including characteristics such as gender or marital status, or information that might be considered special category data under applicable law (e.g., racial or ethnic origin);
  • Commercial information — including records of products or services purchased, obtained, or considered, investment histories, or sources of wealth;
  • Internet or other electronic network activity information — including interactions with our Sites or use of certain online tools;
  • Audio, electronic, visual or similar information — such as voicemail recordings;
  • Professional or employment-related information — including occupation, compensation, employer, title, certifications, and professional licence numbers; and
  • Inferences drawn from any of the above to create a profile reflecting your preferences or similar information.

Please note that some of this information may be considered special category data or sensitive data under applicable law. You may also be required to provide a username and password to access certain features. If you choose not to provide us with certain information, you may not be able to access certain services on the Sites.

2.2 Information We Collect Automatically

We also collect information about you automatically, which may include personal data. For example, when you visit the Sites, we collect your IP address, browser type, operating system, the pages you view on the Sites, the duration of your visit, the pages you view immediately before and after you access the Sites, and the search terms you enter on the Sites.

We generally collect this information using cookies and similar technologies. For more information, please review Section 3 (“Our Use of Cookies and Similar Technologies”) below. If you communicate with our employees and other staff members via email, telephone, or other electronic channels, our information technology systems may record details of those communications, sometimes including their content, for compliance and record-keeping purposes.

2.3 Additional Information Collection Practices

We may collect personal data about you from other sources such as our service providers or other vendors that assist with our business. Additionally, some of our third-party partners may ask you to provide personal data on their websites and may share such personal data with us, as governed by their respective privacy policies. We will link the information that we collect automatically with the information you provide us, and we may combine the information we collect online with information we collect offline or that is collected by third parties.

3. Our Use of Cookies and Similar Technologies

We use cookies, web beacons and other similar technologies for a variety of purposes such as to better understand, customise and improve the user experience of our Sites, services and offerings, and to market to you. We collect such information through the following technologies (collectively “cookies”):

  • Cookies — small data files stored on your browser or device, which may be first-party or third-party, and session-based or persistent;
  • Log Files — tools that track actions occurring on the site, and collect data including your IP address, browser type, location, Internet service provider, referring/exit pages, and date/time stamps;
  • Web Beacons — electronic files used to record information about how you browse the Sites; and

We use different types of cookies that provide various services, including:

  • Strictly Necessary Cookies — required for the operation of our Sites (e.g., enabling you to log into secure areas);
  • Analytics/Performance Cookies — allowing us to recognise and count visitors and to see how visitors move around our Sites;
  • Functional Cookies — used to recognise you when you return to our Sites and personalise content for you; and
  • Advertising/Targeting Cookies — used to deliver content we believe to be most relevant to you and to measure campaign effectiveness.

4. Links to Other Websites

The Sites may contain links to websites operated by third parties, and your personal data may be collected by those third parties when you use their websites. We do not accept, and hereby disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website. These links are provided for convenience only, and you access them at your own risk.

5. How We Use the Information We Collect

How we use your personal data may vary depending on how you interact with us and which Site you are visiting. Generally, we use information we collect about you primarily to provide services to you, communicate with you, and manage and improve our services, as permitted by applicable law. The lawful bases for our processing include the following:

  • Responding to your requests for forms, literature, or information, on the basis that it is in our legitimate business interests to respond to your requests;
  • Managing and administering customer services. In most cases this is to meet our contractual obligations to you. Where there is no such obligation, we have a legitimate interest in keeping our records accurate and up to date;
  • Processing transactions as necessary to meet our contractual obligations to you;
  • Providing you with the services you have requested, whether to comply with contractual obligations or to meet our legitimate business interests;
  • Preparing investor disclosure materials, as necessary to comply with our legal obligations and to meet our interests in managing our business effectively;
  • Improving the Sites and learning about how visitors use them, as necessary for us to improve the services we offer;
  • Maintaining security and preventing or detecting crime and fraud, as required by applicable laws or to meet our legitimate interests in maintaining security;
  • Communicating with you about our products and services and supporting our business development and marketing initiatives. Where required by applicable law, we will only send direct marketing on the basis that you have consented. You can opt out at any time (see Section 9);
  • Internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • With your consent (including explicit consent), as required under applicable law;
  • Complying with legal obligations; and
  • Protecting our rights, your rights, and the rights of others, including to establish, exercise or defend legal claims.

We may use information for any purpose if it does not identify you and cannot be combined with other information accessible to us to identify you.

6. How We Share the Information We Collect

6.1 In Connection with Third-Party Offers

We may share information about you with third parties when you engage in certain activities on the Sites that are sponsored by third parties, for example, if you choose to purchase products or services offered by a third party or elect to receive information or communications from a third party.

6.2 Service Providers

We engage companies that process information for us or act on our behalf in association with the operation of the Sites and our services. Hemingway Solutions takes reasonable steps to require these companies to collect, store, and use information about you only on our behalf and in accordance with this Privacy Notice. We share personal data with service providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business.

6.3 Analytics Providers

We may engage analytics providers to help us understand how users engage with the Sites. These providers may use cookies and similar technologies to collect information about your use of the Sites as well as information about your use of other websites over time. We share personal data with analytics providers on the basis that it is necessary to meet our legitimate interests in managing our business effectively.

6.4 Additional Sharing Practices

We may share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above.

We may disclose information when we believe in good faith that such disclosures:

  • are required by law, including to comply with a court order or subpoena, or in response to a law enforcement request;
  • will help to protect our rights or enforce our Terms of Use;
  • will support our detection, prevention, or response to fraud or intellectual property infringement;
  • are made at your direction or with your consent;
  • will help protect your safety or security, including the safety and security of your property; and
  • will protect the safety and security of the Sites, databases, and/or third parties.

We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganisation, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.

We do not sell your personal data.

7. Security Measures

We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

8. Updating Your Contact Information

You may update your contact information and/or modify your communication preferences by contacting us in writing. Additionally, we may provide tools on the Sites that facilitate such updates or modifications.

9. Your Choices and Rights

If you no longer wish to receive marketing materials from us, you can let us know by contacting us in writing or using the unsubscribe features that we provide in our marketing communications.

Subject to applicable law, you may have certain rights regarding your personal data. These may include the right to:

  • access your personal data;
  • rectify the information we hold about you;
  • erase your personal data;
  • restrict our use of your personal data;
  • object to the processing of your personal data in certain circumstances, including where we process personal data for direct marketing purposes or on the basis of our legitimate interests;
  • withdraw your consent to the processing of your personal data (where applicable);
  • receive your personal data in a usable electronic format and transmit it to a third party (right of data portability); and
  • lodge a complaint with your local data protection authority.

How to Exercise Your Rights

If you would like to discuss or exercise the rights you may have, please contact us in writing. We will review your request and respond in accordance with applicable law. The rights described herein are not absolute and we reserve all rights available to us at law.

10. International Data Transfers

Our activities and the jurisdictions in which we are established are such that we may process information collected via the Sites in, and subject to the laws of, countries which may not provide the same level of protection for your personal data as your home country.

In cases where your personal data is transferred to, stored, or processed in a country that is not regarded as ensuring an adequate level of protection for personal data under applicable data protection laws, we will seek to ensure that appropriate safeguards are in place. Such safeguards may include standard contractual clauses approved by the European Commission, or other transfer mechanisms recognised under applicable law. We will otherwise transfer personal data only in accordance with applicable laws, such as where the transfer is necessary for the performance of a contract between you and us, or for the establishment, exercise, or defence of legal claims.

For more information on the appropriate safeguards in place, or to obtain a copy, please contact us in writing.

11. Data Retention

We retain your personal data for as long as we have a relationship with you and for a period after our relationship with you has ended. When deciding how long to keep your personal data after our relationship with you has ended, we take into account how long we need to retain the information to fulfil the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal data to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.

12. Amendments to this Privacy Notice

We may change this Privacy Notice from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Notice to review any changes. Your continued use of the Sites after the effective date of any modification to the Privacy Notice will be deemed to be your agreement to the changed terms.

13. How to Contact Us

This Privacy Notice is available in alternative formats upon request. If you have any questions regarding this Privacy Notice or our privacy or data protection practices, or to request this Privacy Notice in an alternative format, please feel free send a letter to the address below. Hemingway Real Estate (Lux) S.C.Sp
80, Route d’Esch
L-1470 Luxembourg
Grand Duchy of Luxembourg

This Notice was last updated 30 March 2026 and supersedes any previously distributed Privacy Notice.