Privacy protection policy - www.immovlan.be

** see also our Terms & Conditions updated on 2019-05-14. **

This Privacy Policy (hereinafter referred to as "the Policy") is established by Immovlan SA, whose registered office is located at Rue Royale, 100 in 1000 Brussels, and registered with the Banque Carrefour des Entreprises under No. 0432.916.146 (hereinafter referred to as « Immovlan »).

The purpose of this Policy is to inform you about how your data is processed by Immovlan through the www.immovlan.be website as well as through the Immovlan application.

The Immovlan application and website allows users to quickly and efficiently access information on real estate properties for sale or lease. In a few seconds, the user can consult all the information relating to the property that interests them and can also schedule a visit with the relevant agency of the announcement or the owner of the property.

By « personal data » we mean all personal data concerning you, in other words, any information that identifies you, directly or indirectly, as an individual.

In this context, Immovlan collects and processes your personal data in a transparent manner, in accordance with the law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter referred to as the "law on the protection of privacy"), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data repealing Directive 95/46/EC (hereinafter referred to as the "General Data Protection Regulation").

Immovlan is particularly concerned with the protection of your privacy and therefore commits to take all reasonable precautions required to protect your collected personal data against loss, theft, disclosure or unauthorised use.

1. In what context does Immovlan process your personal data?

The www.immovlan.be website - managed and operated by Immovlan - is an online platform for the publication of real estate offers in the broadest sense of the term and for bringing together the stakeholders in this field (owner, prospective buyer, prospective tenant, various service providers, notaries, etc.). As part of the operation of the www.immovlan.be, platform, Immovlan collects and processes personal data from its customers, users and prospects. Immovlan therefore acts as "controller" within the meaning of the law.

2. What categories of data are processed by Immovlan?

2.1.

As part of the operation of the www.immovlan.be website, Immovlan collects and potentially processes the following personal data:

Categories	Examples	Context
Personal identification data	Surname, first name, postal address, etc.	This data is collected during the registration process for our services, when creating an account, and when you want to contact us.
Electronic identification data	Phone number, e-mail, IP address, fax, etc.	Some of this information is collected via online forms when you register and when you want to contact us.
Professional data	Company name, registered office, company / VAT number, business telephone number, professional email address, function, status, representative's name	Some of this information is collected via online forms when you register as a professional (professional account).
Financial data	Bank account number and banking institution	Some of this information is collected via online forms when you register as a professional (professional account).
Data on real estate properties offered for sale / rental / searched	Category of properties, price range, geographical area, number of rooms, surface, floor, lift, terrace, garden, address, geolocation, etc.	This data is collected when you place a property for sale or lease and when you search for a particular property or type of property on the website.

2.2.

As part of the operation of the immovlan application, Immovlan collects and potentially processes the following personal data:

Categories	Examples	Context
Personal identification data	Surname, first name, country, etc.	During the registration process for our services and when creating an account (or updating the account).
Electronic identification data	Phone number, e-mail, IP address.	Some of this information is collected via the online forms linked to our application during your registration.
Electronic location data	Place of connection.	When you perform a search we locate you (with your agreement) to offer you properties available in your region.
Preference data on housing characteristics	Rental / sale / apartment / house, price range, area, post code / location.	Based on your research we can establish what style of property is good for you.
Lifestyle	Details on the consumption of goods or services, behaviour of the individual.	Depending on your research and requests we can establish your intentions (rental, purchase ...).
Habits, taste and preferences	"Like" tabs	Depending on the properties you mark with "Like", we can determine the type of property you prefer.

2.3.

It is possible that Immovlan may also collect non-personal data. Data defined as non-personal data is that which does not identify you (directly or indirectly). This data may therefore be used for any purpose whatsoever, for example to improve the www.immovlan.be website, the products and services offered by Immovlan or its partners.

2.4.

In the event that non-personal data is combined with personal data, so that identification of the persons concerned would be possible, this data will be treated as personal data until its linkage with a particular person is made impossible.

3. For what purposes does Immovlan process your personal data?

3.1. Principles

The legal basis for the processing of your data varies depending on the processing concerned, and more specifically on the purpose of the data. In principle, when collecting your data, Immovlan informs of the ways and means used to collect and process your data. Immovlan will inform you of the legal basis of the processing at such time.
For example, your data may be collected and processed for the execution of the contract between you and Immovlan which was entered into by the acceptance of the terms and conditions of this Website. When the processing is not necessary for the execution of a contractual relation, it can be based either on your explicit and informed consent, or on the basis of the legitimate interest of Immovlan as a company (especially freedom of enterprise and of information). In this respect, Immovlan always ensures that there is a balance between your interests and its own, for example by granting you a right of opposition. Your data may also be processed in accordance with a legal or regulatory requirement.

3.2. Processing carried out by Immovlan

3.2.1. Respect of our legal obligations

In some cases we are obliged to process your personal data in the context of legal obligations or when we collaborate with the competent authorities. In these cases, we pass on your personal data to fulfil our obligations.

3.2.2. Contractual basis

In execution of the contract between you and Immovlan, Immovlan carries out processing whose purposes can be described as follows:

• the use of the Website and the services provided therein, and more specifically: (a) the monitoring and management of the operational procedure for real estate property entered on our Site (for sale, rental, etc.); (b) and connecting seller/lessor/prospective buyer/prospective tenant/service providers/notaries/...;
• customer management;
• the issue, collection and verification of invoices;
• to provide you with an activity report;
• to answer your questions when you voluntarily contact us;
• to ensure the publication and visibility on www.immovlan.be of your real estate offers/ads and, where applicable, partner media (real estate portals, newspapers...).

3.2.3. Consent

Data that is collected on the basis of your express and informed consent is processed for the following purposes:

• to inform you about real estate offers/announcements (sale, rental, ...) according to your search criteria;
• in order to inform you about prospective buyers/tenants according to the desired action (sale/lease, ...);
• in order to connect you with a seller/lessor/prospective buyer or tenant/service providers/notaries/etc.;
• to offer you announcements that match your needs based on your search criteria, properties you like;
• to pass your contact information to the agencies associated with the Code displayed on the property advertisements you have consulted and/or the properties you have liked, so that they can contact you in relation to the said property or similar properties (transfer to third parties);
• to pass your contact data to our commercial partners, active in the real estate sector in the broad sense, so that they can contact you to offer you products and services that may interest you (transfer to third parties);
• to send you alerts with personalised ads based on your preferences;
• to inform you of new real estate listings matching your needs available on the app;
• to send you commercial and advertising communications;
• to contact you to let you know about new services we have.

3.2.4. Legitimate interest

The data that is collected on the basis of Immovlan's legitimate interests is processed for the following purposes:

• to answer your questions when you voluntarily contact us;
• to prevent and fight against fraud or attempted fraud on the www.immovlan.be website and related Immovlan applications;
• to ensure the technical management of the www.immovlan.be website and related Immovlan applications;
• to perform anonymous statistics on the browsing behaviour and habits of the Immovlan sites and applications and, where appropriate, its partners;
• to provide you with promotional information about the products and services of Immovlan and its partners (direct marketing);
• identification on the application;
• the personalisation of our services;
• the management of people registered on the application;
• the preparation of studies, models (risk, marketing and others) and statistics, using anonymisation and pseudonymisation techniques whenever possible;
• the preservation of security for property and persons, the fight against fraud or attempted intrusion, abuse or other offences;
• the training of our staff through the use of real situations for illustrative purposes (we try, as much as possible, to anonymise your personal data);
• Analysis of your previous searches in order to better customise our service offerings so they are relevant to you;
• to improve the quality of service;
• the retention of a list of people who no longer wish to be contacted;
• the improvement of existing services and user experience (registered or unregistered) of the application;
• the management of your requests relating to the application of your rights;
• the recognition, exercise, defence and preservation of our rights.

3.2.5. Profiling and automated processing

To ensure a better user experience, we use profiling to associate you with your different preferences.
As soon as it is possible, we will only use anonymised or pseudonymised data.
Profiling is any form of automated processing of personal data that uses this data to evaluate certain personal aspects of an individual, including the analysis or prediction of elements relating to work performance, economic status, personal preferences, interests, reliability, behaviour, location or movements of that individual.
In cases where we use your personal data to conduct profiling, we make sure that no decision is taken that has legal effects or which significantly affects you in a similar way.

3.3.

Immovlan may be required to perform processing that is not yet provided for in this Policy. In this case, Immovlan will contact the person concerned before reuse of their personal data, to inform them of the changes and give them the opportunity, if necessary, to refuse this reuse.

4. Is your personal data shared with third parties?

4.1.

As part of the execution of all or part of the purposes mentioned in Article 3, Immovlan may need to transmit some of your personal data to third parties. These Third Parties may be companies or individuals. These are, for example, business partners, IT service providers who maintain the website, or consultants... Immovlan selects these third parties with the utmost care, and in particular according to the guarantees they provide in terms of the protection of personal data.
A list of these third parties is kept up to date and available on the following page of this site: list of partners.

4.2.

No data is transferred to third parties who are established in a country outside European Union territory.

4.3.

It is also possible that Immovlan may be required to disclose your data, either by law or to comply with a court order, or order from a public authority.

5. Immovlan employees

Immovlan ensures that, for persons acting under its authority (employees), access to data and the ability to process it is limited to that which is required for the performance of their duties and the accomplishment of the tasks entrusted to them.
Immovlan informs persons acting under its authority of the provisions of the Privacy Act and the General Data Protection Regulation, as well as any relevant requirements regarding privacy and the protection of personal data.

6. What are your rights and how can you exercise them?

6.1. Right to withdraw your consent.

When the processing of your data is solely based on your consent, you may withdraw it at any time by writing to Immovlan. This withdrawal does not affect the lawfulness of the processing performed prior to the withdrawal of your consent. For example, when you sign up for a newsletter or automatic mailing, you can cancel your registration at any time by clicking on the link at the bottom of each email.

6.2. Right of opposition.

When the processing of your data is for direct marketing purposes, you may object to the use of your data for this purpose at any time.

6.3. Right of access and copy.

In any case, you may obtain a free copy (including electronic copy) of your personal data and, where appropriate, rectify, complete or delete data that is inaccurate, incomplete or irrelevant.

6.4. Right to portability of the data.

You may also, at any time, request to receive your personal data free of charge in a structured, commonly used and machine-readable format, in particular with a view to passing it to another controller.

6.5 Right of rectification.

You also have a right of rectification allowing you to request, at any time, modification of the information that is inaccurate, incomplete or obsolete.

6.6. Right to be forgotten.

You can obtain the deletion of your personal data when any of the following reasons applies:

• The data is no longer necessary for the purposes of the processing;
• You withdraw your consent to the processing of your data and our processing is based only on your legal consent;
• You oppose the processing;
• We processed your personal data unlawfully;
• If the data we have is incomplete, inaccurate or out of date;
• We must erase your personal data in order to comply with a legal obligation (of EU law or the law of the Member State) to which we are subject.

6.7. Right to limitation of processing.

In some cases, you may also ask us to limit the processing of your personal data.
Situations in which you can ask us to limit the processing of your personal data:

• If you dispute the accuracy of an item of personal data while we verify its accuracy;
• If we process your personal data unlawfully and you prefer that we limit this processing rather than erase your personal data.

Of course, if the limitation of processing is no longer applicable, we will inform you.

6.8. How can you exercise your right?

If you wish to exercise any of the rights described above, you must send your written request (including electronically), dated and signed, to Immovlan with proof of your identity. You will receive an answer as soon as possible, at the latest within a month. After this period, you may consider that the request has been rejected. If the request is rejected, the President of the Court of First Instance shall be informed of any request concerning the right to obtain the communication, rectification, deletion or limitation of personal data.

7. What is the retention period of your personal data?

The retention period of your personal data varies depending on the type of data and the regulations. In any case, it is never stored beyond the time required for the processing for which it was collected.
As part of the execution of a contract, we do not store your personal data longer than 10 years after the end of the contract.
If you are registered on the website and/or the application, we keep your personal data for the duration of your registration in order to offer you the best possible service.
If you have unsubscribed from the website and/or application, in this case we will keep your data for six months from when you unsubscribe. It will then be destroyed.
At the end of the retention period, Immovlan makes every effort to ensure that your personal data has been erased.

8. What security measures are taken by Immovlan?

Immovlan implements the appropriate technical and organisational measures to guarantee a level of security of the data collected and its processing with respect to the risks presented by the processing and the nature of the data to be protected, and adapted to those risks.
Immovlan always uses recognised industry standard encryption technologies for the IT sector. In any case, Immovlan implements appropriate security measures to protect your personal data against loss, theft, misuse or alteration of information received, disclosure or unauthorised use.
In the unlikely and unfortunate event that your personal data that we control is compromised due to a breach of information security, we commit to act promptly to identify the cause of the breach and to take appropriate remedial measures.
If necessary, according to the law in force, we will inform you of this incident.

9. Do you have a question or want to make a complaint?

9.1.

If you wish to respond regarding any of the practices described in this Policy, you may contact Immovlan at the addresses specified in section 10 « How to contact Immovlan ? ».

9.2.

You can lodge a complaint with the Data Protection Authority at the following address:

Autorité de Protection des Données
Rue de la Presse, 35
1000 Bruxelles
Tel. +32 2 274 48 00
Fax. +32 2 274 48 35
contact@apd-gba.be

9.3.

The law also allows you to bring an action to the court of first instance where you are domiciled. For more information on complaints and possible remedies, Immovlan recommends that you consult the following Data Protection Authority link: https://www.autoriteprotectiondonnees.be.

10. How to contact Immovlan

For any questions/requests/complaints, you can contact Immovlan via:
privacy@immovlan.be
+32(0)2 730 33 11
Immovlan S.A., Rue Royale, 100, 1000 Bruxelles – Belgique.

11. What happens if this Policy changes?

The contents of this Policy may be modified in accordance with the rules contained in Article 1 of the General Conditions of this Website.
The present version of the Charter is dated on 2019-05-14.
At the same date we updated our Terms & Conditions.

12. Applicable law and competent jurisdiction

This Policy is governed by Belgian law.
Any dispute relating to the interpretation or execution of this Policy will be subject to Belgian law and will come under the exclusive jurisdiction of the French-speaking courts of the judicial district of Brussels.