Privacy Policy for Real Estate Marketing

1. General Information

In this privacy policy, we explain which personal data we process about you.

In addition, we hereby inform you about your general rights in connection with the processing of your personal data (hereinafter also referred to as "data subject rights").


2. Information on the Controller and Data Protection Officer

The controller responsible for processing your personal data is:

STRABAG BRVZ GmbH & Co. KG
Siegburger Straße 241, 50679 Cologne
immobilienanfragen@strabag.com

The contact details of the controller's data protection officer are:

CML Construction Services GmbH
Data Protection
Service Department of STRABAG SE
Siegburger Straße 241
D-50679 Cologne
data-protection-group@strabag.com

3. Activities in which we process your personal data

We process personal data only to the extent permitted by law. These activities are explained below:


3.1. Visiting an External Website

If you enter your personal data on an external website, i.e., a website not operated by us, such as a real estate portal, your data will initially be processed by the operator of that website, who is responsible for data protection. The data privacy policy of the respective website operator applies to this processing of your data.

Your data will then be transmitted to us by the respective website operator. We will subsequently process your data as described below.


3.2. Processing Initial Property Inquiries

If your personal data is transmitted to us by the provider of an external website with real estate listings (see above), or if you contact us directly, e.g., by email, we will first send you an email to further clarify your interest in our properties and obtain your consent for further data processing for the purpose of marketing our properties.
As part of this processing, we process the personal data that you provide to us or that the website operator transmits to us. This typically includes the following data:
  • First name, last name, salutation, title
  • Business email address(es),
  • Business telephone number (landline and/or mobile),
  • Company name and legal form of the company or name of the public body for which you work,
  • Business address(es),
  • Your position or responsibilities within the company or public body,
  • Specific property for which you have submitted your inquiry
  • Content of your request,
  • Categories or general description of other properties you are interested in,
  • IP address of the accessing device, including the time of access, and
  • Information provided during the processing of your request.


Data processing is carried out to answer your initial inquiry. f) DS-GVO.

The legal basis for data processing is Article 6(1)(f) GDPR. We process your data to pursue our legitimate interest in processing and answering your initial inquiry.

We store your data for the duration of the processing of your inquiry. Unless a legal obligation to retain the data exists, we will delete your personal data if you have not responded to our last email or contact within at least six months. The same applies if you have not given your consent to further data processing within six months of our last inquiry.
If legal obligations to retain the data exist, the data will be deleted after the expiry of the last applicable retention period.


3.3. Sending Information Material and Telephone Contact

If you have given your consent, we will send you information material (e.g., property details) and/or information on the marketing status of the specific property you have identified or other properties that correspond to your chosen categories or general descriptions. We may also contact you by telephone to discuss information already sent to you about a property or to clarify your interest in other potentially suitable properties. Please note that due to the rarity of the types of properties we market, it may take several years before we send you (for the first time or again) information about a property that matches your selected categories or descriptions. Therefore, we reserve the right – irrespective of your right to withdraw your consent – ​​to contact you again every few years to inquire about your interest in receiving information and to confirm the accuracy of your data. As part of this sending of information material, we process the data mentioned above in section 3.2, provided you have given it to us.

The legal basis for processing your data is your consent pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR. You can withdraw your consent at any time, in whole or in part, with effect for the future. Further details can be found under “Your rights as a data subject.”

We store and process your data for as long as your consent is valid. We will delete your data (provided that it is not processed for other purposes and there is no legal obligation to retain it) either (i) after you have withdrawn your consent, (ii) we will no longer offer properties that meet your selection criteria in the future, or (iii) if you have not responded to our renewed request to confirm your interest in receiving information for at least six months.


3.4. Viewing and Contract Initiation

We also process your data listed in section 3.2 to enable you to view the property if you are interested, or to send you pre-contractual information and documents, e.g., a binding offer. The legal basis for this processing is the necessity of processing for the preparation and, if applicable, fulfillment of a contract with you pursuant to Art. 6 para. 1 sentence 1 lit. b) GDPR. We transfer your data within our group to the companies and departments involved in preparing the contract. If we have commissioned an external real estate agent to market the respective property, we also transfer your data to the agent's company. We store your data – regardless of any withdrawal of your consent – ​​until after the end of the contract and delete the data after the expiry of the last retention period.


3.5. Processing of your data for the execution of a purchase agreement

In connection with the conclusion and execution of a purchase agreement, we process the buyer's personal data. This includes, in particular, the data specified in section 3.2, as well as:

  • Identity card or passport data,
  • Existing powers of attorney or authorizations,
  • Payment data (e.g., bank details).


The processing is carried out for the initiation, conclusion, and execution of the purchase agreement. This includes, in particular, the transfer of ownership, payment processing, handling inquiries, warranty and liability claims, and compliance with statutory retention obligations. The legal basis for processing this data is Article 6(1)(b) GDPR. The data will also be transmitted to or collected by a notary public during the notarization of the contract.

To the extent that personal data is processed beyond the actual performance of the contract, this is done on the basis of Article 6 Paragraph 1 Sentence 1 lit. f) GDPR. Our legitimate interests consist in particular of the proper documentation of the conclusion of the contract, the assertion, exercise or defense of legal claims, and the prevention of economic disadvantages, for example through fraud prevention or securing evidence.

We store your data only as long as it is necessary for the fulfillment of the purpose for which it was collected or as long as your consent exists and no other legal basis for continued processing applies, in particular statutory or contractual retention periods. After the contract has been fulfilled, your data will be deleted taking into account the statutory retention obligations, unless there is a further obligation to retain it or storage is necessary for the preservation of evidence within the framework of the limitation periods.


4. Obligation to provide data and possible consequences of not providing it

When using our services, you must provide the personal data that is necessary to fulfill the purpose or that we are legally obligated to collect. Without this data, we will generally be unable to conclude or perform the contract with you.


5. Data Transfer

We generally do not transfer your personal data to third parties.

We only transfer your personal data to achieve the purposes listed in this privacy policy. This includes, in particular, transfers to contractual partners, such as hosting providers, shipping companies, or if we are legally obligated to transfer data, e.g., in investigations by law enforcement authorities or to affiliated group companies entrusted with processing.


6. Data Processing Outside the European Union

Processing generally takes place within the EU. Depending on the subject matter of the contract, in particular the destination country, data may be transferred to third countries (i.e., countries outside the EU/EEA) where data protection laws do not apply, provided this is permissible under data protection law.


7. Your Rights as a Data Subject

7.1. In the event that you

  • wish to lodge a complaint in connection with the processing of personal data,
  • have questions about the processing of your personal data by us, or
  • have questions about data protection in general,


please contact our Group Data Protection Officer at data-protection-group@strabag.com.

7.2. With regard to your personal data, you have the following rights, provided the respective legal requirements are met, which you can assert against us at any time:

  • Right of access (Art. 15 GDPR)
  • Right to rectification of inaccurate data (Art. 16 GDPR)
  • Right to erasure (Art. 17 GDPR)
  • Right to restriction of processing of personal data (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).


You can object to the processing of your personal data for direct marketing purposes at any time without giving reasons; this also applies to profiling insofar as it is related to such direct marketing.

Furthermore, you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on point (f) of Article 6(1) of the GDPR. In this case, the objection must be justified and we will no longer process your data unless our legitimate interests in the processing override your interests.


If the data processing is based on consent, you may withdraw your consent at any time with effect for the future. The withdrawal can be declared at any time, with regard to all or only individual processing based on your consent, and without giving reasons, with effect for the future, to the data controller (by email to: immobilienanfragen@strabag.com). The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.


8. Status / Update

We adapt the privacy policy to reflect changes in functionality or legal requirements. Therefore, we recommend that you review the privacy policy regularly. If consent is required, changes will only be made with your agreement.

Last updated: June 2026