Privacy Policy.

LUPO Partners is a cross-border consulting firm operating between Poland and French-speaking Europe, covering Luxembourg, France, Belgium, and Switzerland. We provide services in real estate investment and business development.

We collect personal data only when you actively provide it to us. This includes:

Via the contact form

• First name and last name
• Email address
• The content of your message, including details about your project or inquiry

Via email or direct communication

• Contact details you share with us
• Information about your investment project or business mandate

Automatically when you visit our website

• IP address and browser type
• Pages visited and time spent on our site
• Device and operating system information
• Cookies and similar tracking technologies (see Section 7)

We do not collect sensitive personal data (such as health data, political opinions, or biometric data) and we do not knowingly collect data from individuals under the age of 16.

We process your personal data for the following purposes:

• To respond to your enquiry or contact form submission
• To assess your project and determine whether LUPO Partners can assist you
• To manage our client and prospect relationships
• To send you relevant information about our services, where you have consented to this
• To improve the performance and content of our website
• To fulfil any legal or regulatory obligations that apply to us

We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

Under the GDPR, we process your personal data on the following legal grounds:

• Consent (Art. 6(1)(a) GDPR) when you contact us voluntarily via our form or subscribe to our communications.
• Pre-contractual steps (Art. 6(1)(b) GDPR) when your inquiry relates to a potential mandate or service engagement with LUPO Partners.
• Legitimate interests (Art. 6(1)(f) GDPR) for website analytics, service improvement, and the establishment or defence of legal claims.
• Legal obligation (Art. 6(1)(c) GDPR) where processing is required to comply with applicable law.

We do not sell, rent, or trade your personal data. We may share your data with:

• Trusted IT and hosting service providers who support the operation of our website and communications infrastructure, under strict confidentiality agreements
• Professional advisors (lawyers, accountants) where necessary for the performance of our services
• Public authorities or regulatory bodies, where required by law

Your personal data will not be transferred outside the European Economic Area (EEA) without appropriate safeguards in place.

We retain your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by law:

• Contact form submissions: retained for up to 2 years from the date of your last interaction with us
• Active client or mandate data: retained for the duration of the engagement and up to 5 years thereafter for legal and accounting purposes
• Data processed on the basis of consent: retained until you withdraw your consent
• Website analytics data: retained for up to 13 months

Once data is no longer required, it is securely deleted or anonymised.

Our website uses cookies, small text files stored on your device, to improve your browsing experience and help us understand how visitors use our site.

Essential cookies

Required for the website to function. These cannot be disabled.

Analytics cookies

Help us understand how visitors interact with our site (e.g. pages visited, time spent). Used only with your consent.

You can manage or disable cookies at any time through your browser settings. Disabling certain cookies may affect the functionality of the website.

As a data subject located in the European Union or European Economic Area, you have the following rights:

• Right of access You may request a copy of the personal data we hold about you.
• Right to rectification You may ask us to correct inaccurate or incomplete personal data.
• Right to erasure You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected.
• Right to restriction of processing You may ask us to limit the processing of your data in certain circumstances.
• Right to data portability You may request to receive your data in a structured, commonly used, and machine-readable format.
• Right to object You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to withdraw consent Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at: privacy@lupopartners.com. We will respond within one month as required by the GDPR.

You also have the right to lodge a complaint with the relevant data protection supervisory authority in your country of residence.

We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures are reviewed and updated regularly.

While we take every reasonable precaution, no method of transmission over the internet is entirely secure. We cannot guarantee absolute security, but we are committed to addressing any breach promptly and in accordance with our legal obligations.

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. The most recent version will always be available on our website, with the effective date clearly indicated at the top of this page.

We encourage you to review this policy periodically. Where changes are material, we will notify you directly where we hold your contact details.