PERSONAL DATA PROTECTION POLICY

    This policy was most recently updated on 14 september 2019

    PROCESSING MANAGER

    BBR Belgique private limited company is registered at the address 1060 Saint Gilles, Rue Faider, 15 (hereafter “BBR Belgique”) and registered at the Banque Carrefour des Entreprises under business registration number 0876 914 246.

    Email address: info@emaprod.com.

     

    YOUR PERSONAL DATA

    BBR Belgique uses information technology to serve you to the best of its ability and optimise its organisation. In this context, we are led at various times to process information about you and/or members of your family, such as:

    • personal details (e.g. surname, first name, telephone number, email address, address, post code, town).
    • the dates your requests were made via the forms available on the website emaprod.com.
    • your preferences and interests (e.g. main home, second home, rental property, price of property sought, number of rooms, living space, surface area of annexes, price per m2, choice of investment: tax exemption, building for heritage, having a supplementary income at retirement, other).
    • financial and tax information (e.g. monthly net household income, annual taxable income, contribution, loan term, loan rate, insurance rate, household composition, first-time buyer qualification, income tax reference no2, monthly payment required, family circumstances, number of dependents, monthly savings capacity).
    • your questions/comments/communication;
    • any claims you may have and any data you send to us if we contact you, including by email, online or on social networks.

     

    PROCESSING PURPOSES

    The personal data you provide to BBR Belgique, in particular via the forms on the website www.emaprod.com and visits to the site, can be processed for the purposes listed below.

     

     

    1. Managing our relationship with our prospects and our clients before, during and after acquisition of a property:

     

    • Knowing and managing the preferences of our prospects and clients:

    We cross-check, analyse and combine data, for example:

    • qualification of our prospect and client database (by “qualification”, we mean regularly updating our database);
    • segmentation operations based on the history of actions carried out on our websites and your browsing habits;
    • carrying out studies and analysis of prospect and client questionnaires and comments;
    • establishing commercial statistics and scores, and carrying out reporting;
    • providing context data to the push tool when an internet user visits our website.

    The aim of these operations is to have a better understanding of your needs and wishes and to build your prospect or client profile to avoid, as far as possible, sending you offers that are irrelevant or unsuited to your interests and, generally, to avoid disturbing you.

    In particular, these operations allow us to create a profile in order to:

    • customise our communication to carry out marketing, brand promotion and prospecting activities, send you offers and send you customised relational messages and, generally, to ensure that you in any ongoing contact you are treated in a customised way;

     

    • adapt and improve our products and services in order to better respond to your requests and those of our clients in general;

     

    • optimise the services and products we offer by helping us to predict and anticipate the future needs and behaviours of our prospects and clients.

     

    • Communicating with our prospects/clients outside our contractual relationship or requests for pre-contractual measures:

    The treatment of your personal data allows us to communicate with you, notably for:

    • managing internet users’ requests made on the website www.emaprod.com (requests for brochures, information, subscription to the newsletter, requests for meetings, requests to be updated about previews as well as any other request made by internet users) and respond to these requests;
    • responding generally to your requests for information, etc., reaching us via other channels (e.g. telephone call from an individual concerned);
    • informing you about our business, particularly any new service or product, sending you our newsletters, promotions, offers, particularly by email or contacting you by telephone (except of course if you have not given us permission to send you promotional emails);
    • managing requests to unsubscribe from newsletters, promotions and satisfaction surveys.

     

    • Managing the contractual relationship and everything involved, in particular:

    We treat your data as part of the pre-contractual and contractual relations, which includes, among other things:

    • responding to your requests for pre-contractual measures (e.g. requesting a contract offer);
    • fulfilling concluded contracts;
    • communicating as part of the request for pre-contractual measures or concluded contracts;
    • managing invoicing.

     

    • Managing complaints

    By processing your personal data we can manage any potential complaint that you may wish to make to us.

     

    1. Protection of BBR Belgique’s rights in court

    BBR Belgique may be required to process the data of the individuals concerned in order to assert or defend its rights in court (e.g. recovering an unpaid invoice or any other legal process, including administrative tribunals).

     

    1. Securing and improving your use of our website www.emaprod.com, notably:

    We process your data for the following purposes:

    • improving navigation, notably by adapting the pathways and content offered to internet users;
    • setting up security and prevention of fraud.

     

    1. Taking into account your rights to the protection of your personal data

    As set out in detail below (see title “Your rights” below), the protection of your personal data is important to us. We also process your personal data to enable you to exercise your rights with regard to us.

     

    GROUNDS & DURATION OF PROCESSING

    The grounds for processing set out above rest on the following legal grounds. The durations are indicated with regard to these grounds.

    1. Managing our relationship with our prospects and our clients before, during and after the acquisition of the property:

     

    • Profile management:

    Depending on the case, profiling is justified on one or other of the following grounds:

    • the fulfilment of pre-contractual measures taken at the request of the individual concerned (e.g. demand for goods) or the fulfilment of the concluded contract in order to provide the goods and service most suitable for the individual concerned;

     

    data is kept for the duration of the pre-contractual and/or contractual relationship and until the end of the limitation period of the actions potentially arising from the pre-contractual or contractual relationship, in order to be able to prove the rights and obligations of the parties but also to fulfil the legal obligations applicable to these relations, e.g. for archiving invoices and/or accounting purposes;

     

    • except for this case: the treatment is based on the explicit consent of the individual to enable BBR Belgique to offer services and products that are as relevant as possible to its prospects and customers, as explained in detail in Article 1.1 above; the individual concerned may, however, oppose the processing of his or her data on this basis if his or her interests or fundamental liberties and rights prevail over the aforementioned legitimate interests of BBR Belgique;

     

    the data used for these prospecting purposes is kept for a duration of three years dating from the last contact with the individual, including a click by the individual on a hypertext link relating to an action by BBR Belgique.

     

    • Communicating with our prospects/clients outside contractual relations or requests for pre-contractual measures:

    Sending the electronic newsletter and any promotional email or telephone call is undertaken on the basis of the consent of the individual concerned, he or she being able to withdraw his or her consent at any time by sending a request to the email address info@emaprod.com or via BBR Belgique private limited company’s registered postal address, which is 1060 Saint Gilles, Rue Faider, 15. The request must specify that it is a request concerning BBR Belgique. The latter reserves the right to verify the identity of the applicant to protect the individual concerned. Consent can also be withdrawn directly by clicking on the link provided for this purpose in each of BBR Belgique’s promotional emails.

    Non-digital prospecting methods (e.g. sending postal mail) are based on the legitimate interests of BBR Belgique, which are to freely market its products and services to the public; the individual concerned may, however, oppose the processing of his or her data on this basis if his or her interests or fundamental liberties and rights prevail over the aforementioned legitimate interests of BBR Belgique.

    The data used for these prospecting purposes is kept for a duration of three years dating from the last contact with the individual, including a click by the individual on a hypertext link relating to an action by BBR Belgique.

     

    • Managing the contractual relationship and everything involved, in particular:

    The processing of personal data here is based on the need for the fulfilment of the contract to which the individual concerned is party or when necessary for the fulfilment of the pre-contractual measures taken at the request of the individual concerned (e.g. request for offer in due form).

    The data is kept for the duration of the pre-contractual and/or contractual relationship and until the end of the limitation period of the actions potentially arising from the pre-contractual and/or contractual relationship, in order to be able to prove the rights and obligations of the parties but also to satisfy the legal obligations applicable to these relationships, e.g. for archiving invoices and/or accounting purposes;

     

    • Managing complaints:

    The processing of the data about individuals concerned making complaints may be necessary for the fulfilment of a contract to which the individual concerned is party or may be necessary for the fulfilment of pre-contractual measures taken at the request of the individual concerned (e.g. request for offer in due form).

    The data is kept for the duration of the pre-contractual and/or contractual relationship and until the end of the limitation period of the actions potentially arising from the pre-contractual and/or contractual relationship, in order to be able to prove the rights and obligations of the parties but also to satisfy the legal obligations applicable to these relationships, e.g. for archiving invoices and/or accounting purposes;

    Apart from the two cases mentioned above, the processing of the data about individuals making complaints is based on the legitimate interests of BBR Belgique, which consists of being able to follow up in the best way possible and, if necessary, to take the appropriate measures towards those who, internally, may have committed an error, in order to improve its internal procedures so that the situation giving rise to the complaint does not happen again and, generally, improve its service to individuals. The individual concerned may, however, oppose the processing of his or her data on this basis if his or her interests or fundamental liberties and rights prevail over the aforementioned legitimate interests of BBR Belgique.

    The data used for the purposes mentioned in the previous paragraph are kept for a duration of five years dating from the last contact with the individual.

     

    1. Protection of BBR Belgique’s rights in court:

    BBR Belgique may process the data of individuals concerned where such processing is necessary for the establishment, exercise or defence of a right to legal proceedings, including administrative justice.

    The data processed in this context is kept for the time necessary to bring the dispute to its final completion and in compliance with legal obligations, including archiving and accounting, which may require a longer period for all or part of the data retained.

     

    1. Securing and improving your use of the website emaprod.com:

    The processing of the data about individuals concerned with a view to securing and improving the website www.emaprod.com is based on the legitimate interests of BBR Belgique, which consists in particular of being able to better protect its visitors, its business and in promoting its services and image on the internet. The individual concerned may, however, oppose the processing of his or her data on this basis if his or her interests or fundamental liberties and rights prevail over the aforementioned legitimate interests of BBR Belgique.

    This data is kept for a duration of one year counting from the time it was collected.

    If applicable, please note that the regulations in force may, if applicable, require the processing of your personal browsing data by BBR Belgique, in particular for investigation purposes, and for longer periods than that indicated in the second paragraph.

     

    1. Taking into account the rights of individuals concerned regarding their personal data

    The legitimate interests of BBR Belgique require the taking into account and defence of the personal data of the individuals concerned.

    This consideration and protection is also a legal obligation, based in particular on Regulation 2016/679 of 27 April 2016 relating to the protection of individuals with regard to personal data and to the free movement of this data (abbreviated as: GDPR).

    This processing, which is consubstantial for the purposes enumerated above, ceases at the same time as them.

     

    YOUR RIGHTS

    General rights of the individual concerned

    Any individual concerned shall have, under the conditions defined by the applicable regulations, and in particular GDPR:

    • the right to withdraw at any time his or her consent to the parties to the Processing implemented by BBR Belgique based on the aforementioned consent;
    • the right to obtain confirmation from BBR Belgique that his or her personal data is or is not being processed and, where it is, access to such personal data and to a number of pieces of information on the processing operations (processing purposes, categories of personal data concerned, recipients to whom the personal data has been or will be communicated, the envisaged duration for retaining the personal data or, where this is not possible, the criteria used to determine this duration, etc);
    • the right to obtain from BBR Belgique, as soon as possible, the rectification of any inaccurate personal data concerning him or her;
    • the right to obtain from BBR Belgique, as soon as possible, the deletion of personal data concerning him or her;
    • the right to obtain from BBR Belgique, the limitation of processing;
    • the right to receive personal data concerning him or her that he or she has provided to BBR Belgique, in a structured, commonly used and legible format, and the right to transmit this data to another processing manager without BBR Belgique interfering with this;
    • the right not to be the subject of a decision based exclusively on automated processing, including profiling, producing legal effects that affect or significantly affect him or her in a similar way.

     

    Right of opposition

    Any individual concerned also has:

    • the right to stop, at any time, BBR Belgique, for reasons relating to his or her particular situation, from carrying out the processing of personal data concerning him or her when such processing, including profiling, is based on its legitimate interests,

     

    • the right to object, at any time, to the processing of personal data concerning them for the purposes of prospecting, including profiling insofar as it is linked to such prospecting.

     

    Exercise of rights

    Subject to providing proof of identity, the Customer may exercise the rights described above free of charge by writing to BBR Belgique, at the following email address: info@emaprod.com or at the following postal address: BBR Belgique private limited company, whose registered address is at 1060 Saint Gilles, Rue Faider, 15.

    In case of manifestly unfounded or excessive requests, in particular because of their repetitive character, BBR Belgique can:

    • require the payment of reasonable charges which take into account the administrative costs incurred in providing the information, undertaking communications or taking the requested action;
    • or refuse to follow up these requests.

    It is the responsibility of BBR Belgique to demonstrate the manifestly unfounded or excessive nature of the request.

     

    Right of complaint to the Data Protection Authority

    Anyone concerned has the right to lodge a complaint with the Data Protection Authority (www.autoriteprotectiondonnees.be).

     

    Protection of personal data in case of death

    The individual concerned can, at any time, define, modify and revoke guidelines relating to the storage, deletion and communication of his or her personal data after his or her death. The individual concerned thereby has the right to appoint a third party to whom the data concerning him or her may be communicated after his or her death. He or she then undertakes to inform this third party of his or her action.

     

    RECIPIENTS

    In order to fulfil the above purposes, we may share your personal data with:

    • the entities of the BBR Belgique group, in particular to offer you the best service and to enable you to benefit from our full range of products, services and benefits;

     

    • the service providers who perform services on our behalf;

     

    • commercial, banking and insurance partners;

     

    • administrative and legal authorities or State agencies, public bodies, on request and within the limits of what is permitted by law;

     

    • certain regulated professionals such as auditors, accountants, lawyers or notaries.

     

    HOSTING

    The Personal Data of the Individuals Concerned is hosted by BBR Belgique, which can itself call on a qualified subcontractor with servers located outside and within the territory of the European Economic Area.

    These hosting solutions offer security to ensure the confidentiality, availability and integrity of the data. Any subcontractors chosen also undertake, under the same conditions, to save or arrange for the data of the Individuals Concerned to be saved in conditions that guarantee their safety and integrity, and to preserve them from any losses that may have occurred on the servers.

    Where necessary, the appropriate guarantees are provided for in accordance with Article 46 of the General Data Protection Regulation. It is possible to obtain a copy via the following email address info@emaprod.com or the following postal address: BBR Belgique private limited company, whose registered address is at 1060 Saint Gilles, Rue Faider, 15.