Privacy policy

1. Controller

Controller within the meaning of Art. 4(7) GDPR: Suite Global Estate Owner: Hasan Kaçar Moltkestr. 9 87700 Memmingen Germany Phone: +49 176 28205172 Email: info@suiteglobalestate.com

2. Overview

We process personal data in accordance with the GDPR, the German BDSG and TDDDG, and only as far as necessary to run this website, answer your enquiries and broker properties. We do not sell personal data.

We process in particular: identification and contact data (name, phone number, email address), the content of your messages and enquiries (e.g. property of interest, budget, preferred appointment), technical data (IP address, browser, operating system, time of access) and the country derived from your IP address.

We use statistics and marketing services (Google Analytics, Meta Pixel) only with your prior consent via our cookie banner (see sections 5 and 6).

Legal bases are in particular Art. 6(1)(a) GDPR (consent), (b) (contract and pre-contractual steps, e.g. your enquiry), (c) (legal obligations) and (f) (legitimate interests, e.g. secure operation of the website). You may withdraw consent at any time with effect for the future.

3. Hosting, delivery and server log files

This website is hosted by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. When you visit, technically necessary data is processed (IP address, date and time, page requested, browser and operating system, referrer) to deliver the website and protect it against attacks (Art. 6(1)(f) GDPR).

Property photos and images are loaded from the Cloudflare R2 storage service or from our previous web server at Cloudways (infrastructure: DigitalOcean, server location Frankfurt am Main, Germany) and delivered via the network of Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA; your IP address is necessarily processed.

Data processing agreements pursuant to Art. 28 GDPR are in place with these providers.

4. Country detection, cookie and local storage

To show prices in your local currency and pre-fill the dialling code in forms, our host derives your country from your IP address. We store only the country code (e.g. "GB") in the cookie "sge-cc" (30 days). Your IP address is not stored for this purpose. When you first open the home page or switch language, we store the chosen language in the cookie "sge-lang" (12 months) so that you are not redirected again.

In your browser's local storage we keep only data you create yourself: chosen currency and area unit ("sge-prefs"), saved properties ("sge-fav"), comparison list ("sge-cmp") and your cookie choice ("sge-consent"). This data never leaves your device and can be deleted at any time in your browser settings.

Legal basis: § 25(2) no. 2 TDDDG (strictly necessary for the service you request) and Art. 6(1)(f) GDPR.

5. Consent (cookie banner) and Google Analytics

On your first visit we ask for your consent via a banner. Without consent, no statistics or marketing services are loaded. Your choice is stored for 12 months in your browser's local storage ("sge-consent"); you can change or withdraw it at any time via the "Cookie settings" link at the bottom of every page (Art. 7(3) GDPR).

With your consent (§ 25(1) TDDDG, Art. 6(1)(a) GDPR) we use Google Analytics 4 by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to analyse the use of our website statistically (e.g. pages viewed, time on site, device type, approximate location). Google Analytics 4 does not store full IP addresses; Google signals and ad personalisation are disabled. Cookies: "_ga", "_ga_*" (up to 2 years). Data may be transferred to Google LLC in the USA (EU-US Data Privacy Framework). Events such as sending an enquiry or clicking contact buttons are also recorded. Analytics data is deleted automatically after 14 months. A data processing agreement is in place with Google.

6. Meta Pixel

With your consent (§ 25(1) TDDDG, Art. 6(1)(a) GDPR) we use the Meta Pixel of Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland, to measure the effectiveness of our adverts on Facebook and Instagram (e.g. whether an enquiry was sent after clicking an advert) and to show adverts to people interested in our properties. IP address, browser information, pages viewed and events (e.g. "enquiry sent") are transmitted to Meta, which may link them to your account. Cookie: "_fbp" (up to 90 days).

We are jointly responsible with Meta for collecting and transmitting this data (Art. 26 GDPR; agreement: https://www.facebook.com/legal/controller_addendum). Meta alone is responsible for further processing: https://www.facebook.com/privacy/policy. Data may be transferred to Meta Platforms, Inc. in the USA (EU-US Data Privacy Framework).

6a. Google Maps, YouTube and 360° tours (two-click solution)

Property pages may include a map (Google Maps, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), a video (YouTube in privacy-enhanced mode "youtube-nocookie.com", also Google Ireland Limited) and a 360° tour by a third-party provider. This content is only loaded when you click the respective button (Art. 6(1)(a) GDPR, § 25(1) TDDDG). Only then are your IP address, browser information and the page visited transmitted to the provider; a transfer to Google LLC in the USA is possible (EU-US Data Privacy Framework).

The map shows only an approximate area (circle), not the exact location of the property. If you choose "Always load maps", we store this choice in your browser's local storage ("sge-map"); you can delete it at any time in your browser settings.

7. Contact form, appointment requests and CRM

When you contact us via the form or request an appointment, we process your details (name, phone number, email address, message, requested date, property concerned, chosen language and currency) to answer and advise you (Art. 6(1)(b) GDPR).

Enquiries received via the website, email, phone, WhatsApp or our adverts (e.g. lead forms on Facebook/Instagram) are recorded in our customer relationship management system (CRM) Bitrix24 to follow up your enquiry, suggest suitable properties and document our communication. A data processing agreement is in place with the provider.

For enquiries received via lead forms on Facebook/Instagram, we send Meta the lead ID assigned by Meta and the status of the enquiry (e.g. "qualified") via the Conversions API so that Meta can improve the delivery of our adverts (Art. 6(1)(f) GDPR; our legitimate interest is effective advertising). You can object to this at any time (Art. 21 GDPR).

To protect against automated spam, our forms contain a check field that is invisible to humans and a timing check. To limit mass submissions, we store a non-reversible check value (hash) of your IP address in our database for no more than 24 hours, not the IP address itself (Art. 6(1)(f) GDPR).

In addition, we use Cloudflare Turnstile by Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA, to check whether a form is sent by a human. Turnstile is only loaded when you use a form; your IP address, browser and device information and interaction signals are then transmitted to Cloudflare. Turnstile does not set advertising cookies; the data is used solely to prevent abuse (Art. 6(1)(f) GDPR; our legitimate interest is protection against spam and abuse). Transfers to the USA are based on the EU-US Data Privacy Framework. More information: https://www.cloudflare.com/privacypolicy/

8. Email, phone and WhatsApp

If you call or email us, we process your details to handle your request (Art. 6(1)(b) GDPR). Our emails are processed via Spacemail, a service of Spaceship, Inc., USA.

The WhatsApp buttons are plain links. Only when you click them is WhatsApp opened and your message transmitted via WhatsApp Ireland Limited, Merrion Road, Dublin 4, Ireland, under WhatsApp's privacy policy. If you prefer not to use WhatsApp, please use phone, email or the form.

9. Recording of phone calls

Phone calls with us may be recorded for quality assurance and documentation. We inform you before or at the start of the call; calls are recorded only with your consent (Art. 6(1)(a) GDPR). Recordings are accessible only to authorised persons and deleted once no longer needed.

10. Video consultations

For agreed video calls we use Zoom (Zoom Communications, Inc., USA), processing the data needed to hold the call (Art. 6(1)(b) GDPR). You can choose a phone call instead at any time.

11. Disclosure to third parties

We disclose your data only as far as necessary to handle your enquiry and broker a property, namely to:

• our staff and independent sales consultants handling your enquiry;
• sellers, developers and partner agencies in the destination country (e.g. for availability, viewings and reservations) — only if you are interested in a specific property;
• technical service providers (hosting, CRM, email) acting on our behalf under Art. 28 GDPR;
• authorities and public bodies where we are legally obliged to do so.

Where sales or cooperation partners process data under their own responsibility, they are themselves responsible for complying with data protection law.

12. Transfers to third countries

Some providers (Vercel, Cloudflare, Spacemail, Zoom and — only with your consent — Google and Meta) are based in the USA. Transfers are based on the European Commission's adequacy decision for the EU-US Data Privacy Framework where the recipient is certified, or on EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). Partners in destination countries outside the EU (e.g. Türkiye, United Arab Emirates) receive your data only where necessary to carry out the brokerage you requested (Art. 49(1)(b) GDPR).

13. Retention

We generally keep enquiries for up to 12 months after the last contact; longer only while support or brokerage is ongoing or statutory retention periods apply (e.g. 6 or 10 years under German commercial and tax law for business letters and accounting records).

14. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). You may withdraw consent at any time with effect for the future. An informal message to info@suiteglobalestate.com is sufficient.

You may also lodge a complaint with a data protection authority, in particular in the member state of your residence or place of work. Our competent authority is the Bavarian Data Protection Authority (BayLDA), Promenade 18, 91522 Ansbach, Germany, www.lda.bayern.de.

15. Obligation to provide data

Your name, phone number and email address are required to answer your enquiry. Without them we cannot contact you.

16. No automated decision-making

We do not use automated decision-making, including profiling.