Privacy Policy

01 — Introduction

Who We Are and What This Policy Covers

MERGVS S.à r.l. ("MERGVS", "we", "us", or "our") is an immersive digital property marketing company registered in Luxembourg. We operate from Luxembourg City, with active presence in Milan and Istanbul. Our registered address is: MERGVS S.à r.l., 2 Place de Paris, L-2314 Luxembourg.

This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit our website at mergvs.com, contact us, or engage our services. It applies to all data subjects regardless of location, and complies with the EU General Data Protection Regulation (GDPR), the Luxembourg Data Protection Act, and where applicable, Italian (GDPR as transposed) and Turkish (KVKK) data protection legislation.

Our Data Protection contact: privacy@mergvs.com

02 — Data We Collect

What Personal Data We Collect

We collect only the minimum personal data necessary for the purposes described below:

• Contact information: Name, email address, phone number, and any message content you submit via our contact form or email.
• Professional information: Agency name, brokerage affiliation, and property details you share when enquiring about our services.
• Usage data: IP address, browser type, pages visited, and time on site, collected automatically via server logs and analytics.
• Communication records: Records of correspondence between you and MERGVS, including emails and WhatsApp messages where applicable.

We do not collect sensitive personal data (e.g. health data, racial or ethnic origin, political opinions) and we do not knowingly collect data from persons under the age of 16.

03 — Legal Basis and Purpose

Why We Process Your Data

We process personal data on the following legal bases under GDPR Article 6:

• Contract performance (Art. 6(1)(b)): To provide our services, respond to enquiries, and fulfil obligations under agreements with clients and partners.
• Legitimate interests (Art. 6(1)(f)): To maintain and improve our website, prevent fraud, and conduct business communications. Our legitimate interests do not override your rights.
• Consent (Art. 6(1)(a)): Where you have explicitly opted in to receive marketing communications. You may withdraw consent at any time.
• Legal obligation (Art. 6(1)(c)): Where required to comply with applicable law.

04 — Data Sharing

Who We Share Your Data With

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

• Service providers: Hosting, email delivery, and analytics providers who process data on our behalf under Data Processing Agreements.
• Professional advisers: Legal, accounting, and compliance advisers under confidentiality obligations.
• Legal authorities: Where required by law, court order, or regulatory requirement.

Any transfers outside the European Economic Area are subject to appropriate safeguards (Standard Contractual Clauses or adequacy decisions).

05 — Retention

How Long We Keep Your Data

We retain personal data only as long as necessary for the purposes for which it was collected:

• Client and partner records: 7 years from the end of the business relationship (Luxembourg commercial law requirement).
• Contact form enquiries (no engagement): 12 months from receipt.
• Website analytics: 26 months (anonymised thereafter).

06 — Your Rights

Your Rights Under GDPR

You have the following rights in relation to your personal data:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your data where there is no legitimate reason to continue processing it.
• Restriction: Request that we restrict processing in certain circumstances.
• Portability: Receive your data in a structured, commonly used, machine-readable format.
• Objection: Object to processing based on legitimate interests or for direct marketing purposes.
• Withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing.

To exercise any of these rights, contact us at privacy@mergvs.com. We will respond within 30 days. You also have the right to lodge a complaint with the Luxembourg data protection authority, the Commission Nationale pour la Protection des Données (CNPD), at cnpd.public.lu.

07 — Cookies

Cookies and Tracking

Our website uses strictly necessary cookies to ensure basic functionality. We do not use advertising or tracking cookies without consent. Analytics cookies, where used, are configured to anonymise IP addresses and are subject to consent. You may adjust your browser settings to refuse cookies, though some site features may be affected.

08 — Security

How We Protect Your Data

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include encrypted communications (TLS), access controls, and staff training. No method of transmission over the internet is completely secure; we cannot guarantee absolute security but we commit to prompt notification in the event of a breach affecting your rights.

09 — Updates

Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in law or our practices. The "Last updated" date at the top of this page indicates when the most recent revision was made. Continued use of our website after an update constitutes acceptance of the revised policy.

10 — Contact

Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or our data processing practices:

• Email: privacy@mergvs.com
• Post: MERGVS S.à r.l., 2 Place de Paris, L-2314 Luxembourg