Privacy Policy

APL Holdings d.o.o. / LUXE Realty Company

Last updated: 01/09/2025

1. Introduction

APL Holdings d.o.o., also known commercially as LUXE Realty Company (hereinafter referred to as “LUXE,” “we,” “us,” or “our”), is committed to protecting the privacy and data of its website visitors, clients, and business partners in accordance with the Law on Personal Data Protection of Montenegro and the General Data Protection Regulation (GDPR) of the EU.

By using our website luxerealty.me, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.

2. Information We Collect

Full name, contact details (email, phone number), address
ID or passport number (for KYC and property transactions)
Financial data related to property purchases/sales
Preferences for properties, advertising or communication
Usage data (IP address, cookies, analytics, and device/browser info)

3. How We Use Your Information

Facilitate real estate transactions
Respond to inquiries and provide services
Conduct due diligence (e.g., anti-money laundering)
Send marketing, promotional, and property-related updates (with consent)
Improve our website and services

4. Legal Basis for Processing

Contractual necessity
Legal obligations
Legitimate interest (e.g., direct marketing)
Consent (when required)

5. Marketing and Communication

By registering with LUXE or providing your contact information, you agree to receive marketing communications regarding real estate listings, promotions, newsletters, and events. You can withdraw your consent at any time by contacting us or using the unsubscribe link in our emails.

6. Data Sharing and Disclosure

We do not sell your data. We may share your data with:

Trusted service providers (IT, CRM, legal consultants)
Real estate portals, as part of listing promotion
Regulatory authorities, when required by law
Other brokerage firms, when co-listing or cooperating

All third parties are required to uphold strict data protection standards.

7. Data Retention

We retain personal data only as long as necessary for the purposes stated, or as required by law (e.g., property records are retained per legal obligations).

8. Your Rights

Access, correct, or delete your data
Object to or restrict data processing
File a complaint with the Agency for Personal Data Protection and Free Access to Information (AZLP)

9. Security

We implement appropriate technical and organizational measures to protect your personal data, including encryption, secure servers, and restricted access.

10. Changes to this Policy

We may update this Privacy Policy. Updates will be posted on this page and take effect immediately upon posting.

Contact

APL Holdings d.o.o. / LUXE Realty Company
Jadranski put 28, 85310 Budva
Email: [email protected]
Phone: 068-094-450