# Manager of a real estate co-ownership: Insufficient legal basis for data processing

- Type: Enforcement
- Source: National Commission for Data Protection (CNPD)
- Date: 2022-12-13
- Original: https://www.enforcementtracker.com/ETid-1647
- Canonical: https://overview.legal/posts/47762
- Topics: Controllers, Personal Data, IP Address, Processing, Data Controller, Supervisory Authorities, Processing Agreement

## Summary

The DPA of Luxembourg has imposed a fine of EUR 1,500 on a manager of a real estate co-ownership. The controller had disclosed personal data to unauthorized third parties without having a legal basis for such disclosure. In addition, the controller did not respond to requests from data subjects to exercise their rights in a timely manner.

## Full text

The DPA of Luxembourg has imposed a fine of EUR 1,500 on a manager of a real estate co-ownership. The controller had disclosed personal data to unauthorized third parties without having a legal basis for such disclosure. In addition, the controller did not respond to requests from data subjects to exercise their rights in a timely manner.

GDPR Articles: Art. 5 (1) a) GDPR, Art. 6 (1) GDPR, Art. 12 (3), (4) GDPR, Art. 15 (1) b), c) GDPR
Industry: Real Estate

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Generated by overview.legal · https://overview.legal/posts/47762 · 2026-08-22