WACLEMA SRL, whose registered office is located at 412F route d’Esch, 2086 Luxembourg (hereinafter “WACLEMA” or “We” or “Us”), is committed to protecting your privacy and your personal data.

The purpose of this document is to provide you with clear information on how We process the personal data you communicate to us via our website at (hereinafter “Website”), and also on the cookies used on our Website and the Terms and Conditions for using this Website.

We ensure that our practices in relation to protecting your personal data comply with the legislation applicable in the Grand Duchy of Luxembourg and with the General Data Protection Regulation (EC) 2016/679 of 25 May 2018 (hereinafter “GDPR”).


By browsing our Website, you acknowledge that you have read and accepted this Privacy and Cookie Policy and the Terms and Conditions for using our Website as set out below. We may at any time amend this Privacy Policy and the Terms and Conditions for using the Website. We therefore recommend that you check periodically to see whether any changes have been made to this document.


Data controller for your personal data

The company WACLEMA SRL, whose registered office is located at 412F route d’Esch, 2086 Luxembourg, registered in the commercial and companies’ register under number B231705, is the data controller for the data collected during the use of its Website at

Requests relating to the processing of your personal data can be sent to Us at the following email address:
We wish to draw your attention to the fact that We cannot be held liable for the privacy and confidentiality policies of the third-party websites to which our Website may refer you (links). You are liable for any use you make of third-party sites (which may be linked to our Website). In such cases, we recommend that you consult the privacy and confidentiality policies of these third-party sites.

The personal data processed and the purposes of the processing

Subject to the Cookies (see below), We process only the personal data that you choose to communicate to us when using our Website in order to contact Us or send Us requests.
The personal data that We may collect and process is as follows:

Cookies on our Website

Cookies are small data files that can be sent from a website to the User’s computer (usually via the browser), where they are stored before being resent to the website the next time the User visits it. A cookie cannot collect any other data from your computer’s hard disk, nor can it transmit any computer viruses.

Some cookies are essential in that they are strictly necessary to allow you to connect to the website or to enable us to provide a service which you have expressly requested (e.g. contact form). If you decide to deactivate the use of some cookies, WACLEMA may, for technical reasons, be unable to provide you with certain services or to provide them in the way you were expecting.

Google Analytics

With your consent, our Website uses the functional “ga”, “gid” and “gat” cookies used by Google Analytics, the website analysis service provided by the US company Google.

We use these cookies to monitor and obtain reports on how visitors use the Website. Our cookie durations are limited to 2 years for “ga” cookies, 24 hours for “gid” cookies, and 10 minutes for “gat” cookies.

Google can provide this information to third parties only if it is legally obliged to do so or if third parties process the information on behalf of Google. We have no influence over this. We have not authorised Google to use the analytical information obtained for other Google services. By default, we anonymise the IP addresses sent to Google Analytics in order to protect your anonymity. The information is transferred and stored by Google on servers in the United States. Google complies with the principles of the data protection loop and is a member of the Privacy Shield programme set up by the US Department of Commerce. This means that that there is an appropriate level of protection for the processing of personal data.

Activating and deactivating cookies – Withdrawal of consent

When you visit our Website, a banner appears informing you of the presence of cookies and allowing you to give your consent for the functional cookies listed above.

You can withdraw your consent at any time via the banner on the Website.

You can also configure your browser so that it does not accept cookies. This change must be made for each browser and on each computer. You can find more information on activating, deactivating and removing cookies using your browser's help function.

Personal data retention period

Your personal data (excluding cookies) will be retained for a period of 36 months from the date you last used our Website, and for the length of time required for us to comply with the legal obligations imposed on Us.

Recipients of your personal data

Your personal data will be processed within the limits and for the sole purposes referred to above, by service providers of WACLEMA who act on behalf of WACLEMA, namely Unibra Real Estate SA (a company under Belgian law whose registered office is located at Boulevard du Souverain, 68 bte 9, 1170 Brussels), INOWAI RESIDENTIAL SA, providers of external ITC (Information and Communication Technology) services, and the businesses responsible for managing and maintaining its information systems.


We do everything we can to ensure the security, integrity and confidentiality of the personal data transmitted on/via our Website and to prevent it from being accessed by unauthorised third parties. However, no internet communication is guaranteed to be completely secure.

In addition, the subcontractors who provide services related to our information systems are obliged to respect the confidentiality of the personal data processed on our behalf.

Your rights concerning your personal data

You can exercise the following rights concerning your data at any time:

  1. the right to information: you have the right to know whether We hold personal data about you and, if so, i) to obtain a copy provided that this does not infringe the rights and freedoms of others, and ii) to obtain the information listed in Article 15.1 a) to h) of the GDPR;
  2. the right to rectification and deletion: you have the right to update and correct any of your personal data that is incorrect or incomplete;
  3. the right to erasure (to be forgotten): subject to a legal obligation requiring Us to process your data and subject to any processing required to establish, exercise or defend rights in court, you have the right to ask for your personal data to be erased where:
    o this data is no longer necessary for the purpose for which it was collected,
    o the processing was based solely on your consent and you have withdrawn your consent,
    o you object, for reasons relating to your specific situation, to a processing of your data which we base on our legitimate interest or you object to the processing of your data for direct marketing purposes and there are no legitimate or overriding grounds for continuing the processing,
    o the personal data is subject to illegal processing,
    o the erasure is necessary to meet a legal obligation,
  4. the right to restriction of processing: you have the right to restrict the processing of your personal data in the situations laid down in Article 18.1 a) to d) of the GDPR;
  5. the right to object: you can object, for reasons relating to your specific situation, to a processing of your data which is based on our legitimate interest or to the processing of your data for direct marketing purposes if there are no legitimate or overriding grounds for continuing the processing,
  6. the right to data portability: in the situations and under the conditions laid down in Article 20 of the GDPR, you have the right to receive your personal data in a structured, commonly used and computer-legible format so that you can transfer it to another data controller.

Withdrawing your consent

Where the processing of your data is based solely on your consent, you can withdraw your consent at any time, without charge, by sending an email to
Withdrawal of your consent does not nullify the lawfulness of the consent-based processing prior to the withdrawal.

Making a complaint against the control authority

You can file a complaint against the control authority. For Luxembourg, this authority is the Commission Nationale pour la Protection des Données [National data protection commission] (https ://

Contacting us or exercising your rights concerning your personal data

For any contact request or to exercise your rights concerning the protection of your personal data, please email us at


Terms and conditions

Accessing the website (hereinafter the Website) is free of charge for visitors (hereinafter “User”). Use of the Services is not subject to any guarantee on the part of WACLEMA. By using the Website Services, you accept these Terms and Conditions for using the Website. Users of the Website declare that they are aware of the risks relating to the technical characteristics of the internet. WACLEMA is therefore unable to offer any guarantees in terms of either the confidentiality of the exchanges or the possible interception of the information exchanged via the Website.


The Website contains links to other websites. WACLEMA does not have any control over the content or practices of such sites, nor can it assume liability in relation to their content. The presence of these links does not mean that WACLEMA approves of the information contained on these sites. Consequently, WACLEMA cannot be held liable for any dispute that may arise between a website referenced on the Website and a User of the Website.

The information, products and services appearing on this Website may include commercial or technical inaccuracies. WACLEMA will make all reasonable efforts to correct any inaccuracies brought to its attention. The User remains solely liable for any commitments they make. WACLEMA does not guarantee the accuracy, reliability or completeness of all the information obtained directly or indirectly on/by the Website and cannot therefore be held liable for all the information, products and services that appear on the Website.

It is for the User of the Website to exercise caution when using the information contained on the Website and to undertake all necessary checks before entering into any commitments.

Using the site

Where, as a User, you post messages or information, in any form, on the Website or email them to WACLEMA, the company reserves the right to use such messages and/or information freely (apart from personal data). As the sender, you acknowledge that you alone are liable for the content and the security of such messages and/or information. These messages and information may be processed by WACLEMA in a non-confidential way, without acknowledging the rights of ownership in respect of their sender.

Under no circumstances may this Website be used in violation of these Terms and Conditions to infringe the legal or public policy regulations or for other unauthorised purposes.

Intellectual property

The entire content of the Website (“the Content”), including all the information, messages, images and all other elements, belong to WACLEMA or is placed on the Website by Advertising Agency Plug with the permission of the copyright holders and holders of other intellectual property rights. The content of the Website may not be reproduced or communicated without the prior written express permission of WACLEMA and the advertising agency Advertising Agency Plug.

Applicable law and competent court

These Terms and Conditions are subject exclusively to Belgian law. As a User of the Website, you acknowledge that Belgian law is applicable to all disputes that may arise as a result of using the Website. In the event of a dispute, you accept the exclusive competence of the courts in the place where the registered office of WACLEMA is situated. If a court decides that one of the provisions in these Terms and Conditions is invalid or inapplicable, this will not affect the validity or applicability of the other provisions in these Terms and Conditions.