Alzette Solo Privacy Policy

Controller and contact

Alzette S.à r.l., 3 Côte d'Eich, L-1450 Luxembourg, [email protected], is the controller for account, billing, security, and support data. For questions or personal-data requests, write to [email protected].

Roles for co-ownership data

For data about co-owners, lots, general meetings, proxies, attendance, minutes, and co-ownership documents, the syndicat des copropriétaires normally acts as controller. Alzette is intended to act as processor on the syndicat's documented instructions, in accordance with Article 28 GDPR. Before any processing of that data in the public paid service, the applicable data-processing agreement must be concluded. The syndicat must have a lawful basis and inform the people concerned.

Data categories

• Account and contact data: name, email address, credentials, and sign-in settings.
• Building and co-ownership data: address, units, lots, ownership shares, owners, contact details, notices, proxies, attendance, minutes, and information needed for communication.
• Documents and messages: uploaded files, related records, support exchanges, and chat messages where these functions are used.
• Technical and notification data: security logs, device or browser information, activity events, preferences, and delivery by email or push notification.
• Payment and billing data: order information, payment status, invoice, and refund. Complete card data is handled by the payment provider.

Purposes and legal bases

• Provide Solo, administer accounts, and send necessary sign-in links, emails, and notifications, based on performance of the contract.
• Process billing and refunds and keep required records, based on performance of the contract and applicable legal obligations.
• Prevent unauthorised access, investigate incidents, and improve reliability, based on Alzette's legitimate interest in service security.
• Process co-ownership data on the syndicat's instructions and under the applicable data-processing agreement. Any other use requires a separate lawful basis.

Recipients, processors, and transfers

Authorised Alzette personnel, users designated by the co-ownership, and providers needed to operate the service may receive data according to their roles. This includes the payment provider, hosting and storage providers, email, push-notification, and support services. Before the public paid service, the applicable data-processing agreement must identify the relevant processors and subprocessors as well as transfer safeguards. Where a transfer outside the European Economic Area is needed, an appropriate transfer mechanism, such as standard contractual clauses, must be used.

Retention, deletion, and export

Data must be kept for the duration of the account or relationship with the co-ownership and then only for the period needed for billing, security, legal claims, or legal obligations. Co-ownership documents and data must be deleted or returned under the syndicat's instructions and retention duties. A deletion request cannot remove records Alzette is legally required to keep. A detailed retention schedule and export of available data must be provided before the public paid service, subject to identity and access-right checks.

Security and incidents

Alzette applies appropriate technical and organisational measures, including access management, logging, environment separation, and backup measures. No system is entirely risk-free. Where a personal-data breach concerns Alzette's processor role, Alzette informs the syndicat without undue delay so it can assess its obligations. Where Alzette is controller, it applies the relevant notification procedures.

Your rights and complaints

Under the GDPR, you may request access, rectification, erasure, restriction, objection, or portability where those rights apply. For co-ownership data, Alzette will pass the request to the syndicat as controller and assist under the applicable agreement. You may also lodge a complaint with the Commission nationale pour la protection des données, 15 Boulevard du Jazz, L-4370 Belvaux, or through cnpd.public.lu.

Changes to this policy

If the processing described here changes materially, Alzette will update this policy and provide any required information before the change takes effect.