Lucy Estates
Privacy Policy
Lucy Estates processes only the personal information needed for property and consultation enquiries.
1. Purpose and basis
With your consent under Article 15(1)(1) of Korea's Personal Information Protection Act, we use personal information to review and answer property enquiries, arrange reasonable follow-up and prevent spam or misuse.
2. Information processed
- Required: name, email, preferred country, city or location, intended use, enquiry details and consent
- Optional: budget range and preferred timing
- Generated with a submission: property reference, source page, language, submission time and request identifier
- Abuse prevention: HMAC-derived IP and email identifiers, request counters and expiry times
- Do not include resident registration, passport, bank account or card information in an initial enquiry.
3. Retention and deletion
Enquiry emails are retained for up to one year after the response or consultation ends and then deleted during regular reviews. Electronic files are deleted without undue delay using methods intended to prevent recovery; information required by law is stored separately.
The abuse-control database does not store raw IP or email values. HMAC identifiers and counters expire under TTL controls after a 10-minute IP window or a 24-hour email window.
4. Third-party disclosure
Lucy Estates does not disclose personal information to third parties without consent or another lawful basis. Temporary operational notices contain no visitor information or enquiry content.
5. Processing provider and overseas transfer
These overseas processing and storage activities are necessary to respond to the consultation you request and to take pre-contractual steps under Article 28-8(1)(3) of Korea's Personal Information Protection Act.
- Brevo SAS (dpo@brevo.com): required, optional and submission information is encrypted in transit to France, Germany and Belgium when submitted, and retained for one month for email delivery and transmission logs
- Google LLC (Google Workspace): enquiry contents are encrypted in transit and processed in the United States and the countries in Google's official data-centre and subprocessor lists dated 27 August 2026 for email receipt and storage, for up to one year after the consultation ends. Full deletion from Google systems may take up to 180 days after a deletion request
- Google LLC (reCAPTCHA Enterprise): IP address, browser and device information and verification tokens are processed at submission in the United States and the countries in the official Google Cloud subprocessor list dated 27 August 2026. Lucy Estates-accessible assessment logs are retained for 30 days; Google service data is retained only as needed for security and service delivery and deleted under Google's deletion terms
6. Spam prevention
We use Google reCAPTCHA and request-rate checks. If you do not wish to use the overseas processing or the required technical processing, the web enquiry cannot be submitted.
7. Your rights
You may request access, correction, deletion, restriction of processing or withdrawal of consent using the contact below. We verify the request and respond without undue delay under applicable law.
A child under 14 should enquire through a legal representative, who may exercise the same rights using the contact below.
8. Safeguards and updates
Lucy Estates applies access controls, encrypted transmission and delivery-log review. Material changes to this policy will be posted on this page before they take effect.
Change history: first effective 9 August 2026; updated 27 August 2026 to clarify the privacy officer, recipient, overseas processing and retention controls.

