Privacy policy

Privacy policy

 

1. Introduction

Global Estate Group attaches great importance to a safe, transparent and confidential collection and processing of your personal data. In particular, we wish to protect the details regarding, amongst others, our clients, subcontractors and suppliers against issues such as loss, leaks, errors, unauthorised access or unlawful processing.

By means of the present Privacy Statement we wish to inform you how we handle the personal data of our clients and all other natural persons who are in contact with us (hereinafter referred to as ‘you’).

“Personal data” is any form of information that enables you to identify yourself, directly or indirectly, as a natural person.

When processing your personal data, the Global Estate Group complies with the law, which is currently (i) EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons in connection with the processing of personal data and concerning the free movement of such data (Repealing Directive 95/46/EC) and (ii) the Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

More information on the protection of personal data can be obtained from the Belgian Commission for the Protection of Privacy, which was nominated as the Data Protection Authority as of 25 May 2018.

We invite you to read this Privacy Statement carefully, since it contains essential information regarding how and why your personal data is processed.

This statement is regularly updated. The most recent version of the statement is always available on our website.

2. Field of Application

This Privacy Statement applies to all services provided by us, and in general to all the activities we perform.

3. The Data Controller and his obligations

The Global Estate Group is the trading name for all our activities. In this context, both the service provider companies and the project companies should be regarded as joint data controllers [Trans: Term also given in Dutch]. They continuously strive to achieve common goals and use common resources in order to process personal data. The companies within the Global Estate Group are also referred to in the present Privacy Policy as ‘the Data Controllers’.

The Global Estate Group can also call on specialised service providers to process your personal data in the name of and in accordance with the instructions of the Data Controllers in accordance with this Privacy Policy. Only personal details that are strictly necessary will be handed on to such service providers. These specialist service providers will be hereinafter referred to as ‘the Processors’.

4. Categories of personal data

Below we provide an overview of the categories of personal data that may be processed by the Data Controller. It is possible that other data may also be processed if this is necessary or useful for the continuation of the contractual relationship.

This also indicates the context in which such data is obtained or processed. The table should be read together with the description of the purposes for which the data is processed.

Category

Examples

Context

Identity details of (prospective), purchaser or lessee

Name, address, land line or mobile telephone number, email address,
images taken by camera.

These details are provided by you and are processed when you are asked for information, when you become a client or when you register in order to use the service of the Data Controller (online), for the purposes of any identification or use. The camera images are made when you enter the site at De Cellen in Oostkamp, Kapellestraat
117.

Details about the real estate of the prospective seller

Property title, extract from urban development plan, soil certificate, test certificate for electrical installations, EPC certificate, information about sensitivity to excess current, post intervention file, information about the heritage value

These details are provided by you, or requested on your behalf by the authorities or by technical experts.

Details of a prospective lessee in relation to a proposal for a lease contract

Information about occupation or employment, solvency, family situation, salary, etc.

This data is collected using forms and contracts that you fill out on request.

Supplementary details for the conclusion of a lease agreement or a private sale agreement

Identity card, National register number

These details are provided by you. The national register number is only used in cases when provided for or required by law.

Information about the operations of the Data Controller with you

The information in relation to your contacts with the Data Controller by telephone, email, fax etc. and your interactions on the web pages with respect to the Data Controller, its services or partners, on social networks, etc.

These details come from contacts of any kind, even between you and the Data Controller (at meetings or events, subscriptions to a newsletter, social networks, etc.)

The Data Controller does not process any data that reflects your race or ethnic origin, nor your political views, religious or philosophical beliefs, membership of trade unions, health or life data or sexual orientation, genetic or biometric data.

We would like to draw your attention to the fact that you are responsible for all the data that you provide to us, and that we rely upon its accuracy. If your information is no longer up-to-date, we kindly request you to notify us by return.

You are not under obligation to communicate your personal data, but you will understand that the provision of certain services or types of co-operation becomes impossible if you do not consent to its collection and processing.

5. Purposes, and legal basis for processing

5.1 Client information

As part of our services and activities, we collect and process the identity and contact details customers and clients, their personnel, employees, officers and other useful contacts. The purpose of such processing is the implementation of the agreements with our clients, customer management, accounting and direct marketing activities, such as sending promotional or commercial information. The legal grounds are the implementation of the agreement, the fulfilment of legal and regulatory obligations (such as, for example, the “30bis” declaration of works) and/or any permission received.


Direct marketing activities by email (such as a newsletter or an invitation to events) are only allowed with your permission. This can then be withdrawn at any time.

5.2 The data of suppliers and subcontractors

We collect and process identity and contact details of our suppliers and subcontractors, as well as of other subcontractor(s) working for them, their staff, employees, officers and other useful contact persons. The purpose of this processing is the implementation of this agreement, the management of suppliers/subcontractors, accounting and direct marketing activities, such as sending promotional or commercial information. The legal grounds are the implementation of the agreement, the fulfilment of legal and regulatory obligations (such as, for example, electronic attendance registration, the “30bis” declaration of works [Trans: A Belgian social security declaration], the attendance list or other obligations in public procurement orders, etc.) and/or our legitimate interests, (such as for direct marketing). For electronic attendance registration, the IED data or the Limos number will also be processed where appropriate.

Direct marketing activities by email (such as a newsletter or an invitation to events) are only allowed with your permission. This can then be withdrawn at any time.

5.3 Details of personnel

We process the personnel data of our employees within the framework of our personnel management and payroll administration. Given its specific nature, this processing is regulated more extensively in the Data Protection Policy for employees.

5.4 Other data

In addition to the data of clients, suppliers/subcontractors and staff, we also process the personal data of other persons, such as potential new customers, prospects, useful contacts within our sector, network contacts, contacts with experts, etc. The purpose of such processing is the interests of our activities, direct marketing and public relations. The legal basis is the permission received or, in some cases, the execution of an agreement.

6. For what purposes is your personal data processed

6.1 Legal obligations

The Data Controller must comply with the legislation requiring it to process your personal data in the context of its activities in specific circumstances. These obligations may mean that the Data Controller must co-operate with the competent authorities and/or third parties and possibly transfer some of your personal data to them.

These include:

  • The obligation to contribute to the prevention of money laundering and the financing of terrorism
  • The obligation to respond to a formal request from Belgian taxation or judicial authorities.

The list of legal obligations for which the Data Controller must process your data is not exhaustive and is subject to change.

6.2 Contractual relationships between the Data Controller and you as a client

Before entering into contracts, the Data Controller may sometimes need to obtain and process certain data, in particular to:

  • Respond to your request,
  • Assist you in providing information and in concluding the contract,
  • Follow up a request evaluating the suitability and the risks in connection with a possible contract.

Within the context of current contracts or of contract management, the Data Controller must process a number of details, in particular in order to meet our administrative and accounting obligations.

In this context, your data can be sent internally to various departments, including departments not directly responsible for the relationship with you or the performance of a specific contract.

6.3 The legitimate interests of the Data Controller

The Data Controller also processes your data for the fulfilment of its legitimate interests. In so doing, it strives to find a fair balance between the need to process data and the respect for your rights and freedoms, including the protection of privacy.

Amongst other things, personal data is processed for:

  • Personalising our services.
  • The improvement of the quality of the service provided to you through:
    • Evaluation and improvement of processes, including campaigns, simulations and sales, using different means such as statistical analysis, satisfaction surveys and various other search methods.
    • Improvement of existing products (or those under development) on the basis of surveys with our clients, statistics, tests and feedback from clients via social networks (Twitter, Facebook) linked to the Data Controller.
  • Supervision of our activities, including volume of sales, the number of appointments in our offices, the number of calls and visits to our website, the nature of the questions asked by clients, etc.
  • Preparing studies and statistics, employing the anonymisation and pseudononymisation of the person involved.
  • The training of our staff through the use of practical examples for illustration purposes, including the recording of certain telephone conversations,... .
  • The retention of evidence (archives).
  • The establishment, exercise, defence and preservation of the rights of the Data Controller or all the people it represents, for example in procedures for the collection of monies or in disputes.

7. Duration of processing

Personal data is stored and processed by us for the period that is necessary as a function of the purposes of the processing, and as a function of the relationship (whether contractual or not) which we have with you, as described in the present Privacy Policy.

8. Rights

In accordance with and under the conditions of the Belgian privacy legislation and the provisions of the General Data Protection Regulation, we would inform you that you have the following rights:

The right of access and inspection: you have the right, within what is commercially reasonable, free of charge, to access the data that we hold about you, and to ascertain what it is used for.

The right of correction: you have the right to obtain correction (rectification) of any incorrect personal data, and also to complete any incomplete personal data.

The right to change or limit data: you have the right to request that we delete your personal data or limit its processing in circumstances and under conditions determined by the General Data Protection Regulation. We may refuse to change or limit any personal data that is required by us for carrying out a legal obligation, implementing the agreement or for our legitimate interests, and this will apply as long as such data is necessary for the purposes for which it was collected.

The right to data transferability: you have the right to obtain the personal data you provided to us in a structured, customarily used and machine-readable form. You have the right to transfer this data to another person responsible for its processing.

Right of objection: you have the right to object to the processing of your personal data for serious and legitimate reasons. However, please bear in mind that you cannot object to the processing of personal data that is required for us to perform a legal obligation, the implementation of the agreement or our legitimate interests, as long as this data is necessary for the purposes for which it was collected.

Right of withdrawal of consent: If the processing of the personal data is based on prior consent, you have the right to withdraw such consent. This personal data will then only be processed if we have a separate legal basis for so doing.

Automatic decisions and profiling: we confirm that the processing of the personal data does not include profiling, and that you are not subjected to any fully-automated decisions.

You can exercise the aforementioned rights by contacting Global Estate Services Comm.V. having its registered office at 8020 Oostkamp, Kapellestraat 117, registered at the RPR in
Ghent, Bruges Department under number 0806.194.120, VAT No. BE 0806.194.120. For this purpose you can send an email to 
gdpr@globalestategroup.eu.

We make every effort to handle your personal data in a careful and legitimate manner, in accordance with the applicable regulations. If you nevertheless believe that your rights may have been violated and you have not been able to obtain a response to your concerns within our company, you are free to submit a complaint to:

Commission for the Protection of Privacy
Drukpersstraat 35, 1000 Brussels
Tel. 02 274 48 00
Fax. 02 274 48 35
Email: commission@privacycommission.be

You can also apply to the court if you believe that you would suffer damage as a result of the processing of your personal data.

9. Transfer to third parties

Certain personal data collected by us will be passed on and possibly processed by third party service providers, such as our IT supplier, accountant, auditor, notary, trustee, as well as by the Government, (for example in the “30bis” declaration of works, electronic attendance registration or when competing for public procurement).

It is possible that one or more of the aforementioned third parties is located outside the European Economic Area (“EEA”). However, personal data will only be transferred to third countries with an adequate level of protection.

The employees, managers and/or representatives of the above-mentioned service providers or institutions and the specialised service providers appointed by them must respect to confidential nature of your personal data and may only use this data for the purposes for which is was provided.

If necessary, your personal data can be passed on to other third parties.
This may be the case, for example, if we are subject to total or partial reorganisation, id your activities are transferred or if we are declared bankrupt. It is also possible that personal data must be transferred pursuant to a court order or to comply with a specific legal obligations. In that case we will make reasonable efforts to inform you in advance about such communication to other third parties. However, you should also acknowledge and understand that in certain circumstances this may not always be technically or commercially feasible, or that legal restrictions may apply.

We will, under no circumstances, sell or make your personal data commercial available to direct marketing agencies or similar service providers unless with your prior consent.

10. Technical and organisational measures

We take the necessary technical and organisational measures in order to process your personal data to an adequate level of security and to protect it against destruction, loss, falsification, alteration, unauthorised access or accidental notification to third parties, as well as against other unauthorised processing of such data.

Under no circumstances can the Data Controllers within the Global Estate Group be held liable for any direct or indirect damage resulting from the incorrect or unlawful use of the personal data by a third party.

11. Access by third parties

For the purposes of processing your personal data, we provide access to your personal data to our employees, collaborators and officers. We ensure a similar level of protection by means of contractual obligations that are legally binding on such employees, collaborators and officers and which are similar to this Privacy Statement.

12. Still have questions?

If after reading this Privacy Statement you still have further questions or remarks regarding the collection and processing of your personal data, you can contact: Global Estate Services Comm.V., “GDPR”, Kapellestraat 117, 8020 Oostkamp or by email to gpdr@globalestategroup.eu.