Privacy Policy

The controller for personal data processed through this website is FORMA31 ([LEGAL NAME TO BE CONFIRMED]), [BUSINESS ADDRESS TO BE CONFIRMED], RCS [RCS / REGISTRATION TO BE CONFIRMED].

Contact for privacy matters: info@forma31.lu (mailbox being activated — until then, the contact page indicates current channels).

The controller identity above contains placeholders that must be completed before this policy is final. ⚖ This clause requires verification by a Luxembourg lawyer before launch and before adoption in binding contracts.

When you submit a package request through this website, we collect the information you provide:

—Identity and contact: first name, surname, email address, international phone number, and (optionally) agency name.

—Property information: address, postal code, locality, property type, surface, condition, furnishing, occupancy status, access/practical notes and general notes.

—Appointment preferences: requested dates, availability type and times (including any alternative slot).

—Your configured package: selected services and the computed package price, plus a request identifier.

—Submission metadata reasonably required for security and operation of the service (such as submission time and technical anti-abuse signals).

The website itself does not use analytics or advertising trackers (see the Cookie Policy).

We process this data to: respond to your request, assess feasibility and availability, prepare and confirm the appointment, plan and deliver the requested media services, communicate with you about the request, and protect the service against abuse.

Legal bases under the GDPR: processing necessary for steps prior to entering into a contract and for performing the resulting service (Article 6(1)(b)) for the request, quotation, scheduling and delivery workflow; legitimate interests (Article 6(1)(f)) for proportionate security, anti-spam and record-keeping of correspondence; legal obligations (Article 6(1)(c)) where accounting or tax law requires retention of commercial documents.

We do not rely on consent for the normal processing of your request — the checkbox on the form asks you to confirm you have read this policy, and to acknowledge the appointment-confirmation process; it is not used to manufacture a consent basis. Where any future processing genuinely requires consent (for example optional marketing or publishing identifiable material), it will be requested separately and specifically.

Your request is transmitted by email. Our transactional email provider (Resend, Inc.) processes the message content on our behalf to deliver the notification to FORMA31 and the acknowledgement to you.

The website is hosted on infrastructure provided by our hosting provider (planned: Vercel Inc.). Hosting providers process technical data required to serve the site.

We do not sell personal data and do not share it with third parties for their own marketing.

Final processor list and data-processing agreements to be confirmed at launch. ⚖ This clause requires verification by a Luxembourg lawyer before launch and before adoption in binding contracts.

Email delivery and hosting providers may process data on infrastructure outside the EU/EEA (for example in the United States). Where that occurs, transfers rely on appropriate safeguards such as the EU–US Data Privacy Framework or Standard Contractual Clauses, per the providers' current documentation. The exact transfer mechanisms will be confirmed with the final provider configuration. ⚖ This clause requires verification by a Luxembourg lawyer before launch and before adoption in binding contracts.

We keep personal data no longer than needed for the purposes above. As a framework:

—Requests that do not lead to a confirmed job: kept for a limited period to answer follow-ups, then deleted. [RETENTION PERIOD TO BE CONFIRMED]

—Confirmed jobs and related correspondence: kept for the duration of the engagement and any applicable legal claims periods. [RETENTION PERIOD TO BE CONFIRMED]

—Invoicing/accounting records: kept for the statutory retention period under Luxembourg law. [STATUTORY PERIOD TO BE CONFIRMED WITH ACCOUNTANT]

—Security logs: kept briefly and proportionately for abuse prevention.

Exact periods are flagged for confirmation with legal/accounting advisers before launch. ⚖ This clause requires verification by a Luxembourg lawyer before launch and before adoption in binding contracts.

Fields marked as required on the request form (identity, contact details, property information and appointment preferences) are needed to assess and schedule the requested service; without them we cannot process the request. Optional fields (agency name, occupancy, notes) may be left empty — they simply help us prepare better.

Under the GDPR you have the right to access, rectify and erase your personal data, to restrict or object to processing, and to data portability, within the conditions of the Regulation.

To exercise these rights, contact us via the details in section 1. We may need to verify your identity.

You also have the right to lodge a complaint with the Luxembourg supervisory authority: Commission nationale pour la protection des données (CNPD), 15 Boulevard du Jazz, L-4370 Belvaux — cnpd.lu.

The website transmits data over HTTPS, validates all submissions server-side, applies proportionate anti-abuse measures, and avoids storing request data in a website database — requests are delivered by email to FORMA31's operational mailbox. Access to that mailbox is restricted to the people who need it to handle your request.

We will update this policy as the service evolves (for example when the final legal identity, providers or retention periods are confirmed). The date above reflects the latest revision.