PRIVACY POLICY

PRIVACY POLICY

Leasinvest Real Estate Comm. VA/SCA (CBE n° 0436.323.915) (hereafter: we, us or abbreviated named “Leasinvest”) is committed to protecting and respecting your privacy.

This policy (hereafter: the “Privacy Policy”) sets out the basis on which any information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your information and how we will use it. By visiting www.leasinvest.be you are accepting and agreeing to the practices described in this Privacy Policy. 

Our Privacy Policy contains the following sections:
1.   Information we collect from you;
2.   Cookies;
3.   Uses made of your information;
4.   Legal basis
5.   Disclosure of your information;
6.   Transfer of your information;
7.   Your rights;
8.   Security of collected information;
9.   Retention of your information;
10. External websites/apps;
11. Agreement with collection and use of your information – changes to our Privacy Policy;
12. Identity of data controller – contact details. 

1.   Information we collect from you 

We will collect and process the following information about you:

Information you give us.
This is information about you that you give us by filling in forms on www.leasinvest.be or other project-linked websites of Leasinvest (hereafter: our websites), through certain apps (hereafter: the applications) for example in the context of the access control and/or parking management of our buildings, or by corresponding with us by phone, email or otherwise. It includes information you provide to us when you complete an online contact form, subscribe to the periodic/annual reports and/or press releases, when you are a user of one of the aforementioned applications, when you conclude certain cooperation agreements with us (such as lease contracts, service agreements, contracting agreements), etc.The information you give us may include your name and surname, address, email address, phone number, company name, job title and, if applicable, financial data(purely for billing reasons). 

Information we collect about you.
Partly because of the use of the cookies mentioned below, the following data can be collected in an automated manner, for each of your visits to our websites and/or when using one of our applications:
-      technical information, including the Internet Protocol (IP) address used to connect your device (computer, tablet, smart phone, …) to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
-      your device ID;
-      information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our websites (including date and time), products/services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer services;

Information we receive from other sources. 
This is information we receive about you if you use any other website/application than ours that advertises (eg real estate agents with regard to the available spaces in our buildings) or uses our services. We are working closely with third parties (including, amongst others, business partners, real estate brokers, sub-contractors in technical matters, for payment and delivery services, advertising networks, analytics providers, search information providers) and we will collect and process the information we receive from themwith a view to handling your request. 

2.    Cookies 

Our websites and/or our applications uses cookies. This helps us to provide you with a good experience when you browse on our websites and/or when you use our applications and also allows us to improve our websites and/or our applications. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

3.   Uses made of your information

We use the information we hold about you in the following ways:

Information you give to us. 
We will use this information:
-      to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
-      to provide you with information about other goods and/or facility services we offer (directly or indirectly) and that are similar to or in line with those that you have already used or enquired about (eg offer shuttle services, ironing services, cleaning companies, electricity supplier, ...);
-      to review and assess your job application;
-      to notify you about changes to our servicesor of events that may have an impact on your business (eg the execution of works in the neighbourhood);
-      to ensure that the content from our websites and/or our applications are presented in the most effective manner for you and for your device;

Information we collect about you. 
We will use this information:
-      to administer our websites and/or our applications for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
-      to improve our websites and/or our applications to ensure that content is presented in the most effective manner for you and for your device;
-      to allow you, where appropriate, to participate in interactive features of our service (such as a carpooling system), when you choose to do so;
-      as part of our efforts to keep our websites and our applications safe and secure;
-      to measure or understand the effectiveness of the services we deliver to you and others, and to provide you with even more relevant services;
-      to make suggestions and recommendations to you and other users of our websites and/or our applications about goods or services that may interest you or them;

Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for following purposes:
-      to improve our services to you and to other customers;
-      to measure or understand the effectiveness of services we deliver to you and others, and to provide you with even more relevant services;
-      to make suggestions and recommendations to you and other users of our website and/or our applications about goods or services that may interest you or them;

4.    Legal basis

Your information is being collected and processed on the following legal bases:
-      If it is necessary for performing the contractwe have with you, e.g. communication in the context of building management, as a service provider in the business centers, in the context of the access control and the parking management of the buildings, for invoicing purposes;
-       If it is necessary for pursuing our legitimate interests, considering these interests are not overridden by your fundamental rights and freedoms, e.g. we use your informationto know your preferences so as to be able to better personalize our product offerings, to prevent fraud and to secure our websites, or
-      When you consented to this, e.g. if you have given your prior express consentthereto we may use your email address for sending you press releases and/or newsletters.

5.   Disclosure of your information

You agree that we have the right to share your information with selected third parties including:
-  our affiliates/other entities within the Leasinvest group(among which Leasinvest Immo Lux SA, Leasinvest Immo Austria GmbH, Porte des Ardennes Pommerlach SA, Porte des Ardennes Schmiede SA, Leasinvest Services SA/NV);
- public authorities (including judicial and police authorities);
- banks and insurers;
- our professional advisors (e.g. auditors, lawyers, real estate estimators, brokers);
- providers of recruitment related services;
- our suppliers of IT related services, e.g. SIMAC SA/NV, Yardi Systems BV;
- our business partners and service providers in the field of building management (property manager, monitoring on energy consumption, …
- our suppliers of marketing related services;
- providers of online payment services;
- analytics and search engine providers that assist us in the improvement and optimisation of our site, e.g. Google;

We will also disclose your information to third parties:
- in the event that we sell or buy any business or assets, in which case we may have to disclose your information to the prospective seller or buyer of such business or assets in order to guarantee the continuation of the services;
- if Leasinvest or substantially all of its assets are acquired by a third party, in which case information held by it about its customers may be one of the transferred assets;
- if we are under a duty to disclose or share your information in order to comply with any legal obligation or to protect the rights, property, or safety of Leasinvest, our customers, or others. This includes exchanging information with public authorities (including judicial and police authorities) in the event of, for example, a cyber security incident;
- if that is appropriate to achieve any of the purposes set out in section 3 of this Privacy Policy.

6.   Transfer of your information 

We may transfer your information to a destination outside the European Economic Area (the EEA) if that is appropriate (i) to achieve any of the purposes set out under section 3and/or (ii) to disclose your information to a third party in accordance with section 4 and 5 of this Privacy Policy.

If we transfer your information outside of the EEA, we will make sure that your information is protected by the following safeguards:
- the laws of the country to which your information is transferred ensure an adequate level of data protection (Article 45 GDPR); or
- the transfer is subject to data protection clauses approved by the European Commission (Article 46.2 GDPR) or is subject to the EU-US Privacy Shield;
- the transfer is based on Binding Corporate Rules (Article 47 GDPR); an approved Code of Conduct (Article 40 GDPR); an approved certification mechanism (Article 42 GDPR); an approved data transfer agreement (Article 46.3 GDPR); data protection clauses adopted by the [country] data protection authority (Article 46.2 GDPR).

If you wish to receive more information relating to the transfers of your information and/or the safeguards that have been implemented (including on how to receive a copy thereof), you can contact us through the contact details set out in section 12 below.  

7.   Your rights 

You have certain rights regarding the information we hold about you. These rights can be exercised by contacting us as set out below:
- you have the right to access the information we keep about you – this is because we want you to be aware of the information we have about you and to enable you to verify whether we process your information in accordance with the applicable data protection laws and regulations;
- you have the right, under certain circumstances and subject to some exceptions as mentioned below, to block or suppress further use of your information. When the processing is restricted, we can still store your information, but we can no longer use it;
- if your information is inaccurate or incomplete, you have the right to request the rectification of your information;
- you have the right, under certain circumstances and subject to some exceptions as mentioned below, to request the deletion or removal of your information from our systems;
- you have the right to lodge a complaint about the way we handle or process your information with your national data protection authority;
- if our processing of your personal information is based specifically on your consent, you have the right to withdraw that consent at any time. This includes, among other things, your right to withdraw consent (‘unsubscribe’) to our use of your information to receive press releases and/or newsletters;

However, as mentioned above, there are exceptions where we cannot respond to your request and may need to retain certain information, for example for contractual reasons, for legal and/or administrative purposes (e.g. keeping of accounting records). 

For all requests set out above, please send us an email at privacy@leasinvest.be with “data privacy request” in the subject line and include a copy of your identity card or another proof of your identity (e.g. driver’s license) to help us prevent unauthorised individuals from accessing, changing or deleting your information. We will respond to your request as soon as practically possible and no later than within 30 days. If we need more than one month (from receipt of your request) to respond to your request, we will come back to you and let you know.

8.   Security of collected information

We have implemented a number of security features throughout our websites and our applicationsin order to prevent the unauthorized release of or access to collected and/or received information. We have endeavoredand taken all reasonable measures to have secure and reliable websites and applications createdfor you, but note that the confidentiality of any communication or material transmitted to or from us or any other party via our websites and/or our applicationsor email cannot be guaranteed. We cannot accept any responsibility or liability for the security of information transmitted via these methods.

All information you provide to us is stored on secured servers. Any payment transactions will be encrypted.Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites and/or our applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyoneand change your password immediately or as soon as there is any indication that its confidentiality can no longer be guaranteed. 

9.   Retention of your information

The information we hold about you will be retained in a manner consistent with the applicable data protection legislation. In any event, your information shall not be kept longer than is necessary to achieve the purposes stated in this Privacy Policy.

In particular, we will only keep:
- your information for as long as needed in order to serve our cooperation, to execute our agreement with you, to complete all invoicing and payment processes ;
- your information relating to your online query and/or registration for as long as needed to provide you with the requested information(e.g. after the one-off dispatch of the periodic/annual report, after sending information about available space), unless you have registered on a mailing list (e.g. for press releases) and until you have unsubscribed (via the available "unsubscribe" application at the bottom of each message);

unless:
- the processing of your information is necessary in connection with any actual or potential dispute (e.g. we need this information to establish or defend legal claims), in which case we will keep your information until the end of such dispute; and/or
- the retention is necessary for us to comply with any legal or regulatory obligation (e.g. for tax purposes)or to prove the fact that we have fulfilled your request for deregistration in due time, in which case we will keep your information for as long as required by that obligation.

10.External websites 

Our websites and/or our applications may, from time to time, contain links to and from websites and/or applications of our partner networks, advertisers and affiliates. To the extent that hyperlinks or banner advertisements incorporating hyperlinks are utilized to access third party websites and/or applications, you should be aware that these third party websites and/or applications are not controlled by us and have their own privacy policies. Therefore, they are not subject to this Privacy Policy and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites and/or applications. 

11.Agreement with collection and use of your information – changes to our Privacy Policy 

By using one of these websites and/or our applications, you acknowledge that you have read the terms of this Privacy Policy and that you agree with the collection and the use of your informationas set out above. 

We may amend this Privacy Policy from time to time. Any substantial changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, be notified to you by email. Please check frequently to see if our Privacy Policy has been updated or changed in the meantime.Your continued use of this website and/or our applications following the posting of changes to this Privacy Policy will indicate your acceptance of these changes. This Privacy Policy was most recently updated on May 22nd 2018.  

12.Identity of data controller – contact details

The data controller under this Privacy Policy is the statutory manager of Leasinvest Real Estate Comm.VA/SCA, being Leasinvest Real Estate Management NV/SA, with company number NN0466.164.776, and incorporated at 2000 Antwerpen, at Schermersstraat 42.

Questions, comments and requests regarding the Privacy Policy must be addressed to Leasinvest Real Estate Management NV/SA, Attn. to Legal Department, Schermersstraat 42, 2000 Antwerpen, phone number: +32 (0)3 238.98.77, email: privacy@leasinvest.be.