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I. Introduction

A. Who are we?

Realis Immo NV, with registered office at: Scheldestraat 9, 2000 Antwerp and registered with the Crossroads Enterprise Databank under number 0477.138.149 (hereinafter "Realis", "we" or "us") greatly values your privacy and it is important to us that your personal data is always treated with the necessary care and confidentiality.

We understand that you want to know why we ask you for your personal data and you may be curious about what we do with it. In this privacy policy (hereinafter "Privacy Policy"), we try to answer this question. If you still have questions after reading this Privacy Policy, please contact us via the contact information, as provided under "VI. Contact".

We hereby clarify that this Privacy Policy applies only to the personal data we process as the controller. This is the case when we, as explained below, determine the purpose and means (the "why" and "how") of the processing of your personal data.

B. What constitutes personal data?

This Privacy Policy is subject to (i) Regulation (EU) 2016/679 of 27 April 2016 regarding the protection of natural persons related to the processing of personal data and regarding the free traffic of that data and to withdrawal of Guideline 95/46/EG (General Data Protection Regulation) (hereinafter "GDPR") and (ii) the Act of 8 December 1992 for protecting the personal privacy with respect to the processing of personal data (hereinafter "Belgian Privacy Law" (together or separately (Privacy Law).

This Privacy law applies to every processing of personal data.
By "personal data" we mean the use of data that identifies you as an individual person directly or indirectly. In this Privacy Policy, you can read exactly what personal data is involved. The concept of "processing" is broad and includes collecting, saving, using or distributing that data.

C. Who and what does this Privacy Policy apply to?

This Privacy policy applies to our website www.realis.be (hereinafter the “Website”) and to the activities coupled with this or (commercial) associates related to or maintained by this. For example, as a result of contact via the Website, regarding questions or interest in our services, registration for our newsletter or for one of the events organised by us, a job application, etc.

This Privacy Policy must be read along with the other terms and conditions that apply to the Website, such as the “Conditions of Use” and the “Cookie Statement”.

The involved party (hereinafter “you”, “your”) that this Privacy Policy is addressed to – and whom we wish to inform as transparently as possible about the collection, use, protection and storage of personal data, as well as the rights they may exercise with respect to this processing – may be as follows:

  • Any visitor to the Website;
  • Job applicants;
  • Private and/or business clients (and the individuals associated with the business clients);
  • Individuals whose personal data we collect as a result of offering our services to clients (e.g. setting up sales contracts, notary, buyer)
  • Suppliers (including sub-contractors and the individuals that are associated with the suppliers or the sub-contractors);
  • Business contacts (consisting of potential clients and the individuals associated with them); or
  • Any other individuals that come in contact with us.

II. Use of personal data

A. When do we collect your personal data?

We collect and process your personal data as a controller when:

  • You contact or have contacted us:
    • E.g. you visit our Website;
    • E.g. you submit a request to exercise your rights;
    • E.g. you register for our newsletter or events;
    • E.g. you apply for a job with us;
  • We provide or have provided one of our services to you;
  • We may be able to provide services to you in the future;
  • You are our contact person for one of our clients or suppliers.

B. What personal data may we collect?

We may process the personal data below. Depending on the situation, we don’t always have the data below, however:

  • Your (personal) identification data: for example, your name, phone number, email, ID details, a copy of your ID, etc.;
  • Your National Register number (exclusively for drawing up a sales contract);
  • Your electronic identification data: for example, your IP address, browser type, connection times;
  • Your contact history: for example, sent and received communication, such as email messages;
  • Your financial details: for example, financial identification details, such as a bank account number; information regarding income, assets and investments; information regarding loans, mortgages, credits, etc. (primarily when drawing up a sales agreement);
  • Your personal characteristics: for example, age, sex, date of birth, place of birth, etc.
  • Your lifestyle: for example, your assets; lifestyle preferences;
  • Features of your dwelling: nature of the dwelling, ownership, classification of the dwelling, etc.;
  • Your work-related data: for example, regarding education and training; profession and occupation (primarily for recruitment and selection).

C. Special categories of personal data

In principle, we will not process special categories of data (i.e. data about racial or ethnic origin, political opinions, religious or philosophical views, membership in trade unions, genetic data, biometric data for clearly identifying a natural person, health or the sex life or sexual nature of a natural person), unless we have obtained explicit consent for this from you.

D. What is the legal basis we use for processing your personal data?

We process your data only for legitimate purposes and the processing is always based the processing regulations listed in the applicable Privacy Act, particularly the GDPR.

We support the processing of personal data on the following basis:

  1. The processing is necessary for entering into, executing or terminating an agreement with our clients and/or suppliers to that they can provide you with our services.
  2. The processing is necessary for complying with a legal or regulatory obligation we have, for example, in the context of the anti-money-laundering legislation(AML).
  3. The processing is based on our legitimate interests, which, in specific cases, carry more weight than any disadvantage regarding your rights and provided that specific conditions are met. For example, when we send marketing communications to you as one of our existing or prospective clients. Due to the nature of the available data and the fact that you are already purchasing our services or have done so in the past, we determine that any possible disadvantage to you is very minimal, while we believe that the information provided may be of interest to you. Where we do our processing based on these legal parameters, we will limit the effects this may have on your privacy by offering you the option to easily and immediately put a stop to it.
  4. The processing is based on your consent. This consent is assumed from the voluntary and direct provision of your personal data to us, either verbally, in writing or via an electronic web form/ message.
    You can withdraw your consent at any time, by contacting us. We ask you to always confirm a withdrawal by phone by following your call up in writing, or to withdraw your consent by email or letter. You can easily unsubscribe from the newsletter, using the unsubscribe link you can find at the bottom of every email we send.

E. What are the purposes for which we process personal data?

We use your personal data for the purposes described below or for which you have given your specific consent. We collect and process no more and no other data that that which is required for these purposes. If we wish to use your personal data for a purpose other than that for which we obtained the personal data, we will contact you before processing that data any further.

We collect your data for the following purposes:

  1. Operational purposes: for example, the optimisation of our Website, statistical purposes and market research, to keep our services user-friendly, answering your contact request and deliberating your job application;
  2. Business purposes: for example, to communicate with you about our services and to provide these and let you use them, to inform you about our policy and conditions of use; to develop and manage the relationships with our potential and existing clients;
  3. Commercial purposes: for example, for sending out marketing communication by email or post, for sending newsletters or to register you for one of the events organised by us;
  4. Legal or regulatory purposes: for example, we may use and save personal data for legal reasons and procedures, to comply with legislation and acts of government; or to be able to meet our internal and external audit requirements, information security or to protect or execute our rights, privacy, security or property of that of other individuals.

F. How long do we save your personal data?

We save your personal data no longer than is necessary for the purpose for which the data is collected or processed.

Because the time period for which the data can be kept depends on the purposes for which the data was collected, the storage period may vary in each situation. Sometimes, specific legislation requires us to keep the data for a particular period of time. Our retention periods for personal data are based on legal requirements and weighing your rights and expectation with what is useful and necessary for us to provide our services.

When it is no longer necessary to process your personal data, we will delete or anonymise your personal data. If this is not possible (technically or practically), for example, because your data has been saved in back-up archives or because we need them in a limited way for the administration that obtains information about involved parties that do not wish us to contact them again in the future, we will save your data, but we will not process it further and will remove it as soon as this becomes possible.

G. Who do we receive your personal data from?

We can obtain personal data directly from you, from public sources or from third parties (for example, via temp agencies or as a result of renting or buying address lists).

In addition, some data is collected automatically when people use our Website, through the use of cookies or comparable technologies. For more explanation about this, refer to our cookie statement.

If we obtain your data from external sources, in principle, you should already have been informed of the possible data transfer to us by this source. In any case, if we obtain your data from external sources and we implement these into our systems as the controller, we will inform you about the processing of your data at the latest at the time of our first contact.

H. How do we protect your personal data?

Data security is very important to us and we have taken the necessary physical and suitable technical and organisational (precautionary) measures to protect your personal data from loss or any form of unlawful processing.

In the event of a violation regarding personal data, we will comply with all applicable reporting requirements with respect to such a violation.

I. Who do we share your personal data with?

We will not share your personal data with any third parties, unless we are legally required to do so, you have consented to this, or if it is necessary in order to achieve one of our aforementioned purposes.

Where necessary, we hire external service providers, so-called “processors”, to support our operational purposes, such as providing our services, managing our CRM or IT-systems or to execute several other (internal) operational processes. These external service providers process the part of your data they need for our purpose. We will only share your personal data with these external service providers to the degree that is necessary for the purpose. The data may not be used by them for any other purposes. In addition, these service providers are contractually obligated to guarantee the confidentiality of your personal data, through a so-called “processor’s agreement”, which these parties have entered into.

Some of these external parties are located outside of the European Economic space (“EER”). When we transfer data to external parties outside of the EER, we ensure that transfers of personal data are done in compliance with the appropriate legislation and that there is a suitable level of security. Transfer of personal data outside of the EER to countries other than those the European Commission considers to offer an equivalent level of data protection (see: http://ec.europa.eu/justice/data-protection/internationaltransfers/adequacy/index_en.htm), is done based on agreements with standard contractual definitions accepted by the European Commission or other suitable guarantees in compliance with the applicable legislation.

III. Rights of the involved party

You have various rights with respect to the personal data collected about you. If you wish to appeal to one of the rights below, please contact us via the contact details (by email, phone or by post), as provided under "VI. Contact".

You have the following rights:

  • Right to access and copy: if you wish, you may see your personal data and obtain a copy of it;
  • Right to amendment or rectification: if you believe we have incorrect details for you, you may let us know and we will amend them for you;
  • Right of data deletion (right of oblivion): if you wish, you may ask us to remove your personal data. We may still need to process that data for other purposes;
  • Right to limitation of processing: if you believe that we have processed your data unlawfully or incorrectly, you may have this processing limited.
  • Right of objection: you may submit an objection against the processing of your personal data. If it is in the context of marketing, you may also submit an objection against the processing of your personal data. If it relates to marketing, however, we will stop the processing as soon as possible.
  • Right of transferability: if you wish to transfer your personal data, please contact us.

Execution of the aforementioned rights, however, is subject to certain exceptions in the general interest, to protect our interests and the interests of other individuals.

If you submit a request for the execution of your rights, we will first verify your identity by asking you for a copy of your ID. We do this to prevent your data from ending up in the wrong hands.

Exercising your rights is, in principle, free of charge. If your request turns out to be unjustified or excessive, we may charge a reasonable amount, considering the administrative costs incurred by us. In that same instance, however, we may also opt not to deny your request. In that case, you will be informed of the reason for this.

In any case, we will inform you at the latest within a period of four weeks (for simple requests) or 3 months (for complex or multiple requests) if we choose to follow up on your request.

IV. Complaint options for the involved party

Despite the fact that we do all we can to protect your privacy according to Privacy Protection legislation, you may disagree with the way we collect, use and/or process your personal data.

In this case, you may contact us, of course. In addition, there are also a number of other complaint options:

You may submit a complaint to the supervisory authority at:

  • letter: Data Protection Authority
     Drukpersstraat 35
    1000 Brussels
    Belgium
  • e-mail: contact@apd-gba.be
  • phone: +32 (0)2 274 48 00
  • fax: + 32 (0)2 274 48 35

If you suffer damage, you may also submit a claim to the authorised court.

For more information regarding complaints and options for appeal, we invite you to consult the website of the Data Protection Authority:  https://www.gegevensbeschermingsautoriteit.be/klacht-en-beroep.

V. Amendments

We reserve the right to amend or change this Privacy Policy unilaterally. The most recent version, however, is always available on our Website.

VI. Contact

You may address any questions regarding the processing of your personal data and any requests regarding the execution of your rights, or complaints regarding this, to us at:

  • letter: REALIS IMMO NV
    attn. Privacy Department
    Scheldestraat 9
    2000 Antwerp
    (KBO: 0477.138.149)
  • e-mail: contact@realis.be
  • phone: +32 3 259 02 10