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Privacy Policy

Important Note at the Beginning:

According to Article 7(3) of the General Data Protection Regulation (GDPR) (2016), which states, "The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal." At any time, and in whole or in part, the user can revoke their consent as well as any other settings they made when visiting our website https://geohomegroup.com and all its associated sub-pages (hereinafter collectively referred to as "our website"). Similarly, data relating to cookies is collected via the “CookieYes” PSI consent management platform (hereinafter referred to as the “CMP tool”). Information, in this context, on the use of cookies and other tracking technologies ("trackers") as well as the processing of personal data in this regard, and consent to and the possibility of revocation can be found in our "Cookie Policy."

This Privacy Policy is effective as of September 23, 2024.

I. Responsible Party ("Controller") and Your Rights as a Data Subject

1. The Responsible Party

Geohome real estate and general maintenance (hereinafter also referred to as "Geohome real estate and general maintenance," "Geohome," or "we") is responsible for the data processing governed by this Privacy Policy. According to Article 4(7) of the GDPR, which defines a controller 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," Geohome real estate and general maintenance can be considered a controller. Geohome real estate and general maintenance operates in compliance with Article 13(1)(a) and Article 14(1)(a) of the GDPR, which require a data controller to provide the data subject with certain information at the time of data acquisition.

Please Note:

According to Article 28 of the GDPR, the licensee must be qualified as a third party to process personal data on behalf of the primary controller. The responsibility for data processing, respectively with regard to the web presence of the licensing partners of Geohome real estate and general maintenance (hereinafter referred to as the "company's web presence") which is also accessible via our website, lies with the licensees mentioned. In this context, they are responsible for data processing such as contact inquiries, and, in particular, for data processing with regard to the search for, sale/letting, and valuation of real estate. This complies with 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 a 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 may mean that the controller can transfer personal data to a licensee if the licensee is providing a service or performing a function of benefit to the data subject. This also falls under Article 6(1)(f): this article 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 particular case would relate to the provision of real estate sale/letting and valuation.

An up-to-date overview of these licensing partners can be found on the Geohome real estate and general maintenance website.

Unless otherwise stated, our licensing partners are legally and commercially independent companies and are not part of the Geohome real estate and general maintenance group of companies. Nor are the (main) licensing partners directly or indirectly contractually bound to this group of companies. When we refer to "Geohome real estate and general maintenance," we are referring to the companies listed in Section I of this Privacy Policy. This is in accordance with Article 26 of the GDPR, which states that under joint data controllership, there must be a provision of information to data subjects about the joint processing of their personal data. This is further reinforced by Article 14, which mandates that controllers provide individuals with additional information about the joint processing of their personal data, such as the identity of the other controllers. Geohome real estate and general maintenance is therefore completely transparent with regard to third-party data processing.

To find out which licensing partner is responsible for the data processing of the company's web presence you are currently visiting, please refer to the respective data protection notices in the imprint at the bottom of the respective company's web presence.

2. Data Protection Officer

According to Article 28 of the GDPR, the appointment of a Data Protection Officer may be required if sensitive information is obtained, however, Geohome real estate and general maintenance does not collect any data that would fall under the "sensitive" category.

3. Your Rights as a Data Subject

The concept of a “data subject” and the associated rights are primarily defined in the GDPR, specifically in Article 4(1) for the definition and Articles 12-23 for data subject rights. You can exercise your data protection rights against Geohome real estate and general maintenance insofar as the company is responsible for data processing in relation to our website. Geohome real estate and general maintenance adheres to such an agreement.

You have the following data subject rights under Articles 12-23 of the GDPR:

You have the right to obtain information about the processing of your personal data (e.g., the source of this data, the purpose of the processing, and the modalities of data processing) as stipulated in Article 12. Furthermore, under certain circumstances, you have the right to object to the future processing of your data, as well as the right to restrict the use or deletion of said data as outlined in Articles 17, 16, and 21 relating to conditional deletion rights. Finally, you can at any time stop the sending of advertising material, the execution of market research, or commercial communication as stipulated in Article 21(2), which states: "Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing." Similarly, Geohome real estate and general maintenance adheres to Article 13 of the e-Privacy Directive (2002/58/EC) which expresses that the use of electronic contact details for the purposes of direct marketing is permitted only in respect of subscribers or users who have given their prior consent. In summary, you have the right to:

  • Information (in accordance with Article 12)
  • Correction (in accordance with Article 16)
  • Deletion (or the right to be forgotten) (in accordance with Article 17)
  • Restriction of processing (in accordance with Article 18)
  • Data portability (in accordance with Article 20)
  • Object to the processing of your personal data (in accordance with Article 21)
  • Lodge a complaint with the supervisory authorities (in accordance with 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 in compliance with Article 21(2) and 21(3) of the GDPR, which state: "Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes."

In accordance with Article 7(3) of the EU General Data Protection Regulation (hereinafter referred to as “GDPR”), you can at any time revoke your initial consent to us. Once consent has been revoked, we will no longer continue processing the data. The definition of “consent” in the GDPR is found in Article 4(11). It states: “Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” This in turn shows that for consent to be valid under the GDPR, it must be free, clear, specific, and informed.

Please note that your right to the deletion of your data is subject to certain limitations. For example, we do not have to or are not allowed to delete data that we are required to retain due to statutory retention periods. Also excluded from your right to deletion is data that we need to assert, exercise, or defend legal claims. These mentioned limitations on this right are stipulated in Article 17(3) of the GDPR. The regulation states that the right to erasure shall not apply to the extent that processing is necessary for one of the following reasons:

  • For exercising the right of freedom of expression and information.
  • For compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject 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 compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject 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 archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 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 how we process your data, you can turn to a supervisory authority, in particular in the Member State of your residence, place of work, or the place of the alleged infringement as protected by Article 77 of the GDPR, which states, "Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation."

We reserve the right to disclose information about you if we are requested to do so by law enforcement agencies or other legal authorities. Legal basis: Article 6 I sentence 1 lit. c GDPR (legal obligation) which also includes the following statement "processing is necessary for compliance with a legal obligation to which the controller is subject." This indicates legal freedom of disclosure in external legal obligation scenarios related to law enforcement.

II. Collection and Processing of Personal Data When You Visit Our Website

Article 15 of the GDPR sets forth 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 a copy of the personal data, free of charge, in an electronic format1. This means the data controller needs to disclose the individual data subject's data that is being processed.

1. What Data Do We Process From You (hereinafter referred to as "you" or the "user")?

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

  • Email address, first name, last name, title, address, telephone number, property data, participation in events and webinars, hereinafter referred to as "data" or "personal data," which you have provided to us in the event you use individual services offered by Geohome real estate and general maintenance via our website (e.g., in the context of contact inquiries, newsletter dispatch, webinars, as well as the determination of the market price of real estate); mandatory fields are marked with an "asterisk"; (Geohome real estate and general maintenance provides full transparency on the types of data collected in accordance with Article 15, Article 14, and Article 13(1) of the GDPR) (*For reference only - Article 14 is most prominent as it states that the controller must provide the data subject with information about the source of the data, the categories of personal data concerned, and the purpose of the processing, among other details.)
  • Personal data (hereinafter also referred to as "user data") that the user's internet browser sends each time it accesses the website and is stored as part of log files, also known as server log files. This data includes: the IP address (Internet Protocol address) of the accessing computer; the name of the accessed page; the date and time of access; the URL from which the user accesses the page; the amount of data transferred; the status message for successful access; the session ID number; (For reference only - The GDPR does not explicitly mention "server log files" or "IP address" in its text. However, they would be covered under the general categories of personal data that the GDPR seeks to protect. This falls under the scope of Article 4(1), which defines personal data as any information relating to an identified or identifiable natural person, and Article 5(1), which discusses the principles of data processing, including lawfulness, fairness, transparency, data minimization, accuracy, storage limitation, integrity, and confidentiality. Similarly, Article 4(1) introduces the broad concept of online identifiers that can be applied in the context of using electronic communication services.)
  • Personal data in the form of location data (GPS data, so-called "Locate Me" function), which is sent by your internet browser each time you activate this setting on the browser by default or based on the application. This similarly falls under the framework of Article 4(1), which defines personal data as any information relating to an identified or identifiable natural person.
  • (For reference - The GDPR does not mention GPS data, but it is understood to include any information that can directly or indirectly identify an individual. This includes location data, which would cover GPS. This means that the collection and use of GPS data need to comply with all relevant GDPR provisions. This may include obtaining the individual's consent before collecting this data (as per Article 7), providing clear information about how this data will be used (Articles 13 and 14), and ensuring appropriate security measures are in place to protect the data (Article 32). The individual also has the right to access, rectify, and erase this data, and to object to its processing (Articles 15-21).

2. Purpose of Processing

The GDPR makes it necessary for organizations to state the purpose of data collection in Article 13(1)(a) and Article 14(1)(a). These articles state that organizations must provide data subjects with clear and concise information about the purposes for which their personal data is being collected and processed. This information must be provided at the time the personal data is collected, or at least within a reasonable period of time after the data is collected. Additionally, the “purpose limitation” principle in Article 5(1)(b) also underscores the need for clear purposes, as it states that data must be “collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.” Geohome real estate and general maintenance therefore adheres to the aforementioned legal provisions by clearly stating the purpose of data collection.

We process the personal data of our website users (https://geohomegroup.com) for the following purposes:

  • The provision of online offers for private ads and third-party ads (the legal basis is the legitimate interest of Geohome real estate and general maintenance in marketing its own services as well as the services of the Geohome real estate and general maintenance companies as described above); this explicitly follows Article 6(1)(f) of the GDPR, which states that “Processing is lawful only if and to the extent that at least one of the following applies:... the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.” Thus, marketing must fall under the category of “legitimate interest” without overriding the data subject’s interests. This is further reinforced by Recital 47 of the GDPR, which mentions that "The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest."
  • To fulfill user contact requests to Geohome real estate and general maintenance (the legal basis is the fulfillment of a contract as well as in the event of the passing on of user data, your consent or the legitimate interest of Geohome real estate and general maintenance to pass on the contact or service requests within the Geohome real estate and general maintenance group to this relevant Geohome real estate and general maintenance company (licensing partner) which is responsible in terms of expertise and/or geographic location);
  • If applicable, for the purpose of fulfilling the property valuation request as described by the user, as well as the implied interest in selling the property as presented through the valuation request. This represents a legitimate interest and a fulfillment of the contract, both of which are legal bases for processing personal data under Article 6(1)(b) (contract) and Article 6(1)(f) (legitimate interests). In this case, it would be the legitimate interest of Geohome real estate and general maintenance, UAE, to market its services to the data subject. (The legal basis is (a) the fulfillment of a contract as well as, (b) your consent in the event that we need to share your contact details with (1) an appropriate licensing partner of the Geohome real estate and general maintenance group based on expertise or geographic location and this falls under Article 6(1)(a). This article specifies the legal basis for processing personal data based on the data subject's consent. In this case, the consent would be for Geohome real estate and general maintenance, UAE, to share the data subject's contact details with the licensing partners or the company that technically executes the valuation. (For the definition, please see section 3 below)) or (2) the company that technically executes the valuation and (c) the legitimate interest in marketing our services or your consent in the event that your contact details are used for direct marketing); this also refers to Article 6(1)(f) (legitimate interests) for the company’s marketing activities. Direct marketing also refers specifically to Article 21(2), which gives individuals the right to object to the processing of their personal data for direct marketing purposes at any time.
  • The organization of webinars (the legal basis is the fulfillment of a contract by Geohome real estate and general maintenance, and in the event of the passing on of your contact details to the lecturer, your consent); the fulfillment of a contract can be justified under Article 6(1)(b), which allows the processing of personal data when it is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract. If an individual's contact details are passed on to the lecturer, their consent is required. This falls under Article 6(1)(a), which permits the processing of personal data since the data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • The sending of an email newsletter from Geohome real estate and general maintenance or the Geohome real estate and general maintenance group containing our offers as well as own and third-party ads to the extent permitted by law or based on given consent (the legal basis is either your consent or the legitimate interest of Geohome real estate and general maintenance in direct marketing, as long as the marketing is carried out in compliance with the data protection and competition law requirements of the applicable national regulations); this is covered under Article 6(1)(f), which states that data processing is lawful if it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Article 6(1)(a) also applies where consent to data processing constitutes lawfulness.
  • To improve and operate the website (the legal basis is the legitimate interest of Geohome real estate and general maintenance to constantly improve the quality of the website and ensure user-friendliness); the processing of personal data to improve and operate the website can be considered a legitimate interest of the company. This is covered under Article 6(1)(f) of the GDPR, which states that processing is lawful if it is necessary for the purposes of the legitimate interests pursued by the controller. No overriding interests are perceived on this basis.
  • For processing purposes related to cookies and other tracking technologies, please refer to our Cookie Policy.

In summary: The legal basis for the processing of your personal data is Article 6 I sentence 1 lit. a GDPR if the processing is based on consent, Article 6 I sentence 1 lit. b GDPR if the processing is based on a contractual (possibly pre-contractual) relationship, and Article 6 I sentence 1 lit. f GDPR if the processing is based on a legitimate interest of Geohome real estate and general maintenance. If the processing of personal data is necessary to comply with a legal obligation to which Geohome real estate and general maintenance is subject, Article 6 I sentence 1 lit. c GDPR is the relevant legal basis.

If the legal basis is your consent, you have the right to revoke your consent at any time without affecting the lawfulness of the processing of your personal data that was carried out based on the consent until the revocation. If the legal basis is a legitimate interest, you also generally have the right to object to the processing of personal data relating to you at any time for reasons arising from your particular situation. In this regard, Article 21 of the GDPR applies.

3. Disclosure of Your Personal Data

Article 13(1)(e) and Article 14(1)(e) of the GDPR require the data controller to provide information about the recipients or categories of recipients of the personal data, if any. In cases where it is not practical to list every recipient individually, the GDPR permits referring to categories of recipients. Similarly, Article 30(1)(d) requires controllers to keep a record of the categories of recipients to whom the personal data has been or will be disclosed. This record must be kept for at least 5 years after the processing activities have ceased. Due to the size and complexity of data processing by the Geohome real estate and general maintenance group of companies, it is not possible to individually list every recipient of your personal data in this data protection policy, which is why, as a general rule, only categories of recipients are referred to.

Within the Geohome real estate and general maintenance group of companies, your data will be disclosed to the relevant Geohome real estate and general maintenance companies or entities that require the data to fulfill our contractual and legal obligations and to achieve legitimate interests in the context of this website service or based on your consent. This includes Geohome real estate and general maintenance companies that support the provision of our website, direct marketing, or other IT infrastructure, that provide webinar events, that perform property valuations, or that send newsletters. Article 6(1)(f) allows processing if it is necessary for the purposes of the legitimate interests pursued by the controller or a third party. Article 13(1)(e) and Article 14(1)(e) stipulate that the data controller must inform the data subject of the recipients or categories of recipients of the personal data. Geohome real estate and general maintenance therefore complies with this.

In addition, as a general principle, we will not pass on your personal data to third parties (i.e., companies that do not belong to the Geohome real estate and general maintenance group or relevant Geohome real estate and general maintenance companies) unless this is necessary for the fulfillment of the contract (Article 6(1)(b) GDPR, which allows data processing when it is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.), if we or the third party have a legitimate interest in the transfer, or if there is a legal obligation, or if you have given your consent (in accordance with Article 6(1)(f) GDPR, which allows data processing for the purposes of legitimate interests pursued by the data controller or a third party), if your data is transferred to third parties based on a legitimate interest, this will be explained in this Privacy Policy. Third parties to whom we may disclose your personal data, regardless of our performance, include external advisors (such as lawyers and accountants), public authorities within their jurisdiction to comply with legal obligations and/or to protect our rights (such as tax authorities, police, public prosecutors, and courts) (Article 13(1)(e) and Article 14(1)(e), which state that the data controller must inform the data subject of the recipients or categories of recipients of the personal data.), potential buyers or acquirers of all or part of our assets and/or activities, and other third parties where you direct us to disclose the data or provide your consent in accordance with Article 6(1)(a). The mention of potential buyers or acquirers of assets is covered under Recital 48, which recognizes that controllers may have a legitimate interest in transferring personal data within a group of undertakings for internal administrative purposes, including the processing of personal data of customers or employees.

In summary:

  • If your contact request relates to offers from other companies of the Geohome real estate and general maintenance group of companies, Geohome real estate and general maintenance will transfer the personal data you entered to the company concerned based on a so-called legitimate interest within the Geohome real estate and general maintenance group of companies in accordance with Article 6(1)(f) relating to the concept of verifying the legitimate interest of the data controller and third parties.
  • On the other hand, if your contact request relates to offers from other companies of the Geohome real estate and general maintenance group (i.e., our licensing partners), we will pass on your personal data from the Geohome real estate and general maintenance group of companies with your prior consent as covered under Article 6(1)(a) which states that processing is lawful if “the data subject has given consent to the processing of his or her personal data for one or more specific purposes.” Furthermore, Article 7 of the GDPR provides conditions for consent. It states that the request for consent must be presented in a mann2er that is clearly distinguishable from other matters, in an intelligible and easily accessible form, using clear and plain language.

4. Transfer of Data to Countries Outside the European Economic Area (EEA)

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

The recipients of personal data may be located outside the EEA/UK. When personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which 3the personal data is transferred ensures an adequate level of protection (Article 45 of the GDPR) or that the transfer is subject to appropriate safeguards (e.g., standard contractual clauses) as agreed upon by the EU and the data recipient (Article 46 of the GDPR) unless the GDPR provides for an exemption (Article 49 of the GDPR). Furthermore, where necessary, we intend to agree on additional measures with the recipients to ensure an adequate level of data protection.

Under Article 30, organizations are required to keep a record of processing activities, which can include these safeguards. Article 12 also states that the controller shall take appropriate measures to provide any information referred to in Articles 13 and 14 and any communication under Articles 15 to 22 and 34 relating to processing, in a concise, transparent, intelligible, and easily accessible form, using clear and plain language. Copies of the appropriate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available upon request. Please note that these copies may be redacted to the extent necessary to protect trade secrets or other confidential information in accordance with the broader scope of the Trade Secrets Directive (EU) 2016/943.

5. Storage and Deletion of Your Data

Geohome real estate and general maintenance will retain your personal data for the necessary period of time to fulfill the purposes for which the data is collected, including any retention period required by applicable law (e.g., retention of accounting records). The handling of data retention periods is covered in the GDPR under Article 5(1)(e) which states that personal data must be: 'kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject ('storage limitation').'

6. Tracking Pixels and Analytics Tools

Collection of Information via Tracking Technologies
We prioritize your privacy and believe in transparency. As part of our commitment to upholding these principles, we provide details on the tracking technologies applied to our platform and how they interact with your personal data.

Google Analytics: We use Google Analytics to better understand user interaction.