When you purchase a real estate property, sell us products or services, want to obtain information about the IMMOBEL Group, use our services or visit our website [www.immobelgroup.com] (the “Website”), we will collect some personal information about you.
The purpose of this privacy policy (the “Policy”) is to inform you on how we, IMMOBEL Group and the entirety of its subsidiaries, (the Public Limited Company, Compagnie Immobilière de Belgique “IMMOBEL”, “our” or “us”), collect your personal data in this way, why we collect it, with which third parties we share it and for how long we keep it, as well as what rights you have and how you can exercise them.
“Personal data” is any information relating to an identified or identifiable natural person who, alone or in combination with other information, identifies a specific person (for example: a name, an identification number, location data, a identifier online, or to one or more specific elements specific to its physical, physiological, genetic, psychic, economic, cultural or social identity).
“Data processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
This Privacy Policy was last updated in July 2023.
1. Who are we?
IMMOBEL is responsible for the processing of your personal data (data controller), its head office is located at 1000 Brussels, 1 boulevard Anspach, and it is registered in the Crossroads Bank for Enterprises (CBE) under the number: 0405.966.675. You can contact us using the general contact information below:
Tel.: 02 422 53 11
Email: [email protected]
This Privacy Policy sets out the basis on which any personal data IMMOBEL collects from you, or that you provide, will be processed by IMMOBEL.
2. What personal data do we process?
Personal data collected by IMMOBEL will be recorded, used and protected in accordance with the Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (GDPR), and any corresponding or equivalent national laws or regulations.
2.1 Categories of personal data
2.1.1 Personal data that you provide to us
The details marked with an asterisk (*) are mandatory and essential for entering into any contract. You are therefore required to supply us with these personal details; otherwise it will not be possible to enter into a contract.
2.1.1.1 General information such as, but not limited to, the following:
- Your surname*, first name*, title*, language* and date of birth.
- Your postal address,* email address*, landline and/or mobile number*.
- Any personal information that you provide to us voluntarily and without obligation (e.g.: family composition, profession, etc.).
- With your consent, your preferences for communication and marketing purposes.
- Copy of your ID Card.
2.1.1.2 If you are a professional, the following information, among others:
The contact details of your company/association/institution: name, postal address, landline and/or mobile number, email address, your VAT and business number, legal form.*
2.1.1.3 Information related to real estate property, including but not limited to the following:
- The type of real estate properties for which you have expressed an interest
- The real estate properties that you currently own or rent
- The real estate properties that you have rented or purchased in the past
2.1.2 Personal data that we collect about you
2.1.2.1 Information from third parties, including but not limited to the following:
We can also, when permitted by law, collect personal data about you from public databases, social media or the owners of marketing files, which will help us to update your personal data, to improve the quality of or complete the same, in order to help us better understand the type of properties that may interest you.
2.1.2.2 Automatic collection of personal data
When you visit the Website, we also collect personal data, especially when you fill out forms in order to obtain information about a real estate project or financial information, or even automatically through the use of cookies and similar technologies.
We collect the following personal data:
- when you fill in the forms via the Website or other channels (for example, if you express an interest in the real estate projects that we are developing or if, as an investor or interested person, you have asked us to provide you with financial information about our group); and
- when you sign a contract with a view to purchasing a real estate property; and
- when you contact us, for example when you write to our customer services; and
- when you sign a contract with us with a view to selling a product or service to IMMOBEL; and
- Automatically, on the Website, through the use of cookies and similar technologies. You can learn more about this subject here: https://www.immobelgroup.com/en/cookie-policy
3. Why is your personal data processed?
We process the aforementioned personal data for the following reasons:
- In the context of contractual or pre-contractual relations with suppliers, customers and prospective customers, in order:
- to deal with your requests for information about our current or future projects;
- to manage the contractual relationship;
- to create, accept and follow-up your real estate purchase, the after-sales service;
- for accounting purposes;
- in order to tackle potential fraud, offences and breaches, and for handling disputes and potential legal proceedings; etc.
- On the basis of our legitimate interest, in order:
- to follow up of your requests for information;
- to update, correct and consolidate your personal data, using useful information from external partners that may be available where appropriate;
- to contact you if we experience difficulties responding to one of your requests;
- to check or improve the quality of your contacts with IMMOBEL based on your answers;
- to improve our products or services, adapt our events, websites or mobile apps according to the preferences of our visitors, customers or prospective customers, or in order to improve security;
- send you financial information about our IMMOBEL;
- in order to tackle potential fraud, offences and breaches, and for handling disputes and potential legal proceedings; etc.
- On the basis of our legitimate interest and/or with your consent, in order:
- to send you marketing material according to your communication preferences, such as, for example, send you newsletters to which you have subscribed;
- to send you reminders concerning your real estate properties, renew any service or contract that we offer and that is about to expire;
- inform you in a generalised or personalised way about IMMOBEL's offers of products and services;
- send you information about events organised by IMMOBEL;
- for the purposes of participating in satisfaction or market surveys about our products and/or services or about the real estate market;
- to process job applications; etc.
- Based on the law, in order:
- to comply with our legal and regulatory responsibilities (in particular with regards to financial information);
- to respond to legal proceedings or requests for information from government authorities or other third parties;
- to prevent and detect criminal offences and fraud, or to protect your rights, or those of others;
- to fulfil legal guarantees; etc.
From time to time, we may combine the personal data collected on the Website or via other channels with data collected from third parties (such as marketing agencies) in order to help us determine which real estate properties interest you. We may then use this data in order to send you the relevant information. We may also work with third parties to show you personalised advertisements on social networks or, if you have agreed to the use of cookies, when you browse on the Internet or visit other sites (see IMMOBEL’s cookie policy on this subject https://www.immobelgroup.com/en/cookie-policy). If you no longer wish to receive marketing material from us, you can object to it. To this effect, we refer you to the "What rights do you have?" section 12 below.
4. Lawful basis for processing your personal data
The personal data that we collect is processed according to the legal bases below:
4.1 IMMOBEL executes a contract or pre-contractual measures with you (art. 6, paragraph 1, point b) of the GDPR)
The personal data is processed for the purposes of executing the contracts that we enter into with you. The personal data may also be processed in order to implement measures and operations within the context of pre-contractual relations, for example when you request an offer for a real estate property, in the framework of lease agreements, sales contracts, employment agreements, etc.
4.2 IMMOBEL pursues its legitimate interests, on the condition that these interests do not conflict with your fundamental rights and freedoms (art. 6 paragraph 1, point f) of the GDPR)
We also process your data whenever this processing is necessary in order to protect our legitimate interests or those of the third parties with whom we have shared your personal data, and especially to help us find the information, products and services most likely to be of interest to you and to send or show you information, offers and advertisements for these products or services; to personalise your experience of our products and services if you do not object to the use of your personal data for this purpose.
4.3 IMMOBEL processes personal data with your consent (art. 6 paragraph 1, point a) of the GDPR)
With your consent, we may collect and process technical information such as cookies and similar technologies that we describe in the “Cookie Policy” and/or use your personal data for marketing by email. In principle, you may revoke this consent at any time. See the "What are your rights?” section 12. on this subject below.
4.4 IMMOBEL processes personal data to comply with regulatory requirements (art. 6, paragraph 1, point c) of the GDPR)
We will also use your personal data if these are necessary for us to comply with the legal obligations to which we are subject, and in particular our obligation to make available to the public all of information necessary for the transparency, integrity and smooth running of the markets. It may therefore turn out to be necessary to use your data in order to comply with the statutory and regulatory provisions to which we are subject.
5. When will IMMOBEL contact you?
IMMOBEL may contact you:
- in relation to any contractual relation you have engaged with IMMOBEL;
- in relation to any service, activity or online content you have signed up for;
- in relation to any correspondence we receive from you or any comment or complaint you make about IMMOBEL products or services;
- in relation to any job application;
- in relation to our legal rights and obligations;
- in relation to any personalized services you are using;
- in relation to any contribution you have submitted to IMMOBEL, e.g. on IMMOBEL message boards or via text or voicemail message;
- to invite you to participate in surveys about IMMOBEL services (participation is always voluntary);
- for marketing purposes, as set out in article 6.
6. Will you be contacted for marketing purposes?
IMMOBEL will only send you marketing emails or contact you when you have agreed to this. You will always be able to unsubscribe by following the procedure set out in article 12. From time to time we may also contact you to ask your opinion on certain issues affecting IMMOBEL.
7. Is your personal data shared with third parties?
Your personal data is not sold or passed on to third parties for commercial purposes. We are only permitted to transfer your personal data to third parties if one of the following applies:
- you give your prior formal consent in this respect;
- we have a legal obligation to transfer your personal data in the context (of preventing) fraud and abuse;
- we call upon third parties to perform a part of the contract that we have entered into with you, in which case, we ensure that these third parties also respect this privacy policy.
Specifically, your personal data is or may be shared with the following third parties, for the reasons listed below:
- companies or other organisations that we have subcontracted to provide services on our behalf, such as web hosting companies, direct mail suppliers, suppliers of analyses, events services and suppliers of information technologies;
- partner companies, when it is necessary in order to provide you with a product or service that you have requested.
IMMOBEL may also share your personal information with other IMMOBEL Group companies in the European Union.
When we transfer your personal data, we will ensure that it is only used for the purposes described in this notice. In addition, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service.
8. Transferring your personal data in the European Economic Area
Your personal data will be processed in accordance with the Belgian legislation on data protection and may be transferred within the European Economic Area ("EEA").
9. For how long is your personal data kept?
Your personal data may not be kept longer than is necessary in order to fulfil the objectives for which it was collected and to satisfy our legal obligations.
Independently of this period for which we keep your personal data, we also delete your personal data if you explicitly ask us to do so, by notifying us using the contact details appearing above.
10. Other websites or social networks
When you surf on the website or social networks, they may also offer you the possibility of sharing or following information about IMMOBEL, the Website or the products and/or services available, using the third party social network function (for example, the "share", "like" or "follow" buttons).
We offer this function in order to generate interest in the Website or our social networks among the members of your networks, and to enable you to share and to follow the opinions, news and recommendations on the Website or the social networks with your contacts. However, you should be aware that the sharing of personal data with a social network may result in such information being collected by the social network supplier and in the public dissemination of the same, including via internet search engines. We advise you to always carefully read the privacy policy of any website you access or social network through which you share information, in order to understand their privacy practices.
11. How do we protect your data?
Your personal data is only accessible to persons who need it in order to perform their task. These people have a duty of confidentiality and must ensure that all of the technical and organisational measures we have implemented to assure the security and confidentiality of your personal data are respected.
12. What rights do you have?
You have different rights that you may exercise by contacting us using the contact data shown above.
- the consultation of personal data about you that has been processed by us;
- the rectification of inaccurate/incomplete personal data, where applicable, as well as, in some cases, the restricted processing of your personal data or objection to the processing of the same;
- the right, under certain circumstances, to request the deletion or removal of your information from our systems;
- the transfer of your personal data, either by supplying it to you in a readable format, or when we send it directly to the third party service provider that you have designated;
- the objection to the use of your personal data for the purposes of direct marketing;
- the withdrawal of a consent previously given for the purpose of processing your personal data;
- the filing of a complaint to the supervisory authority, if you are not satisfied with our processing of your request or claim, using the following contact details:
Autorité de protection des données
Rue de La Presse, 35, 1000 Bruxelles
+32 (0)2 274 48 00
[email protected]
13. How can you exercise your rights?
If you have any questions or complaints regarding the use of your personal data, you can contact us using the contact details shown above.
If you want to withdraw your consent for the use of your personal data and/or if you no longer wish to receive marketing communications from the IMMOBEL Group, you can contact us at any time by sending your request to:
Postal address: Immobel - Privacy - 1 boulevard Anspach, 1000 Brussels
Email: [email protected]
Telephone: +32 (0)2 422 53 99
We may amend this Policy from time to time. If we make substantial or important changes to the way in which we wish to use your personal data, we will communicate this to you by supplying a visible notice on the Website or by contacting you directly. If you surf on the Website and you do not agree with these changes, please refrain from using the website.