2. The Housing Company Ltd. attaches great importance to the protection of your personal data and fully respects your privacy. The Housing Company Ltd. treats and protects your personal data in a lawful, proper and transparent manner.
When processing your personal data, The Housing Company Ltd. clearly complies with the law, currently the Belgian law of 8 December 1992 and as of 25 May 2018 the European regulation no. 2016/679 of 27 April 2016 concerning data protection (better known as ‘GDPR’ or ‘AVG’) or any other legislative act amending it. More information on the protection of personal data can be obtained from the Belgian Commission for the Protection of Privacy, called the Data Protection Authority from 25 May 2018.
3. We invite you to read this statement carefully so that you know and understand The Housing Company Ltd.’s policy in this area.
This statement will be updated regularly. The most recent version of the statement is available on our website. We will inform you through the usual channels of communication if significant changes have been made.
II. Who is responsible for the processing?
4. At The Housing Company Ltd. is the responsible party for the processing of your data:
The Housing Company Ltd.
Heirbaan 45, 3110 Rotselaar
Company number BE 0439.719.707
Professional liability insurance and financial guarantee: BA and guarantee via NV AXA Belgium Polisn° 730.390.160.
Phone: 016/585 233
The Housing Company Ltd. is therefore your interlocutor and is the one who must answer to the Data Protection Authority regarding the processing of your personal data. The Housing Company Ltd. determines the purposes for which your personal data are processed, as well as the means used and the processing characteristics.
III. Which categories of personal data does The Housing Company Ltd. process?
6. Below is an overview of the categories of personal data that The Housing Company Ltd. can process. Other data may also be processed, if necessary or useful for the continuation of the contractual relationship with The Housing Company Ltd..
Hereby the context in which The Housing Company Ltd. obtains or processes these data is indicated. This table should be read together with the description of the purposes for which The Housing Company Ltd. processes the data.
Identity data of the client (seller or landlord), identity data of candidate buyer or tenant.
Name, address, place and date of birth, nationality, fixed or mobile telephone number and email address.
These data are provided and processed by you when you request information, become a client, conclude an intermediation contract or register to use the services of The Housing Company Ltd. (online), for any identification or use. This data can be obtained, among other things, by reading your identity card.
Data about the real estate of the client (seller or landlord).
Title of ownership, urban development extract, soil certificate, inspection certificate of the electrical installation, EPC certificate, information on overcurrent sensitivity, post-intervention file, information on heritage value.
This information will be provided by you, or requested by The Housing Company Ltd. from the government or technical experts on your behalf.
Information about the prospective renter related to a proposal for a rental agreement.
Information on occupation and employment, solvency, family situation, pay, etc.
This data is collected using forms and contracts that you fill in at your request.
Additional data for the conclusion of a rental agreement or private sale agreement
National registration number
This data will be provided by you.
The national number will only be used in cases provided for or required by law.
Data of co-owners (or their tenants)
Name, address, place and date of birth, nationality, fixed or mobile telephone number and email address.
This information is provided by you as co-owner to The Housing Company Ltd. when The Housing Company Ltd. acts as property manager.
Data related to the execution of the property manager’s services.
Payment transactions, including names and account numbers, communication and references, card numbers, etc.
These data relate to your transactions as a co-owner coordinated by the steward.
Data about the transactions of The Housing Company Ltd. with you.
The information related to your contacts with The Housing Company Ltd., by telephone, email, fax, etc. and your interactions on the web pages concerning The Housing Company Ltd., its services or its partners, on social networks, etc.
These data come from contacts of any kind between you and The Housing Company Ltd. (at meetings or events, subscription to a newsletter, social networks, etc.).
Data about the behaviour and preferences of the client
Information about your behaviour and preferences regarding the use of communication and relationship channels, information about your personal choices and lifestyle, private or professional projects, hobbies etc.
These data are the result of choices you have made or analyses carried out by The Housing Company Ltd. in accordance with this statement and its legal obligations.
7. The Housing Company Ltd. does not process data revealing your racial or ethnic origin, or political opinions, religious or philosophical beliefs, trade union membership, health or life data or sexual orientation, genetic data or biometric data.
IV. For what purposes does The Housing Company Ltd. process your personal data ?
8. The Housing Company Ltd. collects and processes your personal data only for the purposes described below. The Housing Company Ltd. ensures that only the necessary and relevant data are processed for a specific purpose.
The Housing Company Ltd. processes your data in the situations permitted by law, more specifically:
- To comply with the legal obligations imposed on The Housing Company Ltd..
- To perform a contract with you or to take certain measures at your request prior to the conclusion of this contract.
- For the protection of the legitimate interests of The Housing Company Ltd., balancing these interests with your fundamental rights and liberties.
- In specific cases, with your consent, as a result of a specific and unambiguous request, preceded by clear and comprehensible information; this consent may be withdrawn by you at any time in accordance with the law.
1. Legal obligations
9. The Housing Company Ltd. must comply with legislation that obliges it in specific circumstances to process your personal data in the context of its activities. These obligations may require The Housing Company Ltd. to cooperate with the competent authorities and/or third parties, and possibly transfer some of your personal data to them.
This includes, among other things:
- The obligation to contribute to the prevention of money laundering and terrorist financing
- The obligation imposed on a steward with regard to the management of co-ownerships.
- The obligation to respond to a formal request from Belgian tax and judicial authorities
The list of legal obligations for which The Housing Company Ltd. must process your data is not exhaustive and is subject to change.
2. Contractual relations between The Housing Company Ltd. and you as a client
10. Before concluding contracts, The Housing Company Ltd. sometimes has to obtain and process certain data, in particular in order to, among other things :
- Respond to your request,
- To assist you in providing information and in concluding the contract
- To follow up on a request, assess its suitability and assess the risks related to a possible contract,
- Fulfil your conciliation mandate
11. In the context of ongoing contracts or the management of contracts, The Housing Company Ltd. has to process a number of data, in particular in order to comply with administrative and accounting obligations.
In this context, your data may be sent internally within The Housing Company Ltd. to various departments, including those that are not directly responsible for the relationship with you or the execution of a particular contract.Ltd.More specifically, The Housing Company Ltd. processes your data during the execution of contracts as follows:
- Manage current contracts / services ordered
- Central management and general picture of the customers
- The management of your real estate
- The management of the co-ownership in which you are co-owner
The Housing Company Ltd. may process your personal data for additional purposes within the framework of the relationship with you and the execution of contracts.
3. Legitimate interests of The Housing Company Ltd.
12. The Housing Company Ltd. also processes your data for the fulfilment of its legitimate interests. In doing so, The Housing Company Ltd. strives to strike a fair balance between the need to process data and respect for your rights and freedoms, including the protection of privacy.
Personal data is processed for, among other things:
- Personalising the services of The Housing Company Ltd.
- The improvement of the quality of the service provided to you by:
Evaluation and improvement of processes, including campaigns, simulations and sales, through various means such as statistical analysis, satisfaction surveys and various other search methods.
Improvement of existing (or under development) products of The Housing Company Ltd. , based on surveys of clients of The Housing Company Ltd. , statistics, tests and feedback from clients via social networks (Twitter, facebook) linked to The Housing Company Ltd.
- Supervision of the activities of The Housing Company Ltd., including the size of the turnover, the number of appointments in our offices, the number of calls and visits to the website of The Housing Company Ltd., the nature of the questions asked by clients etc.</li
- Preparation of studies and statistics using anonymisation and pseudonymisation of those involved
- The training of our staff through the use of practical examples for illustrative purposes, including the recording of certain telephone calls.
- Storage of evidence (archives)
4. Specific justified interest of The Housing Company Ltd. : conventional direct marketing
13. The Housing Company Ltd. carries out a customer segmentation – in particular according to your needs – in order to offer you, for example, suitable premises and/or services that correspond to your professional and personal situation. To this end, The Housing Company Ltd. can, among other things:
- The services you already use and assess your socio-demographic data (age, family composition, income, etc.)
- analyse your behaviour through various channels (visits/meetings, emails, visits to the website, messages via our website), derive your preferences and thereby personalise the information and the internet pages you have visited,
- Adapt the advertisements on the web pages so that they meet the interest you have shown through your behaviour on our website, social networks, in an office or elsewhere (e.g. at events where The Housing Company Ltd. was present),
- To simplify the filling in of forms by filling in certain fields with already known data and asking you to verify the accuracy of these data and to update them if necessary,
- Assessing the key moments for which certain services would suit you best
- Sending you personalised advertisements by post or telephone
5. Your consent to the processing and sending of electronic advertising (electronic direct marketing)
14. The Housing Company Ltd. may process your personal electronic contact details (namely your mobile telephone number and email address) in order to send you personal information, advertisements or proposals via direct marketing or newsletters. In this case The Housing Company Ltd. must first ask for your specific permission.
V. To whom does The Housing Company Ltd. transfer your personal data?
15. The Housing Company Ltd. treats your personal data with the utmost care and shares your data only to offer you the best services in the execution of its assignment.
The Housing Company Ltd. may send your data to other entities within its group at home and abroad, in particular to the other entities of the group that assist The Housing Company Ltd. in the execution, management and control of its activities, including reporting, support and computer security or the provision of specific services and products.
16. In some cases The Housing Company Ltd. is obliged by law to share your data with third parties, including:
- Public or supervisory authorities where there is a legal obligation to communicate information
- Judicial investigative bodies at their express request
The Housing Company Ltd. also transfers your data to specific service providers to help with :
- Design and maintenance of computer equipment and internet applications
- Provision of advertising and communication services, including online and social networking providers
- Preparing reports and statistics, printing documents and designing products or services
- The marketing of its activities, the organisation of events and the management of customer communication
The Housing Company Ltd. must also transfer your data to online and social network providers, which The Housing Company Ltd. uses for the provision of advertising services.
Your personal data may also be disclosed to bailiffs or lawyers in the context of legal proceedings.
In the aforementioned cases, The Housing Company Ltd. ensures that third parties only have limited access to the personal data necessary to carry out the required specific tasks. The Housing Company Ltd. will also ensure that third parties undertake to use and disclose the personal data in a secure and confidential manner in accordance with the instructions of The Housing Company Ltd. and its data protection policy.
17. The Housing Company Ltd. stores your personal data within the EEA. No data will therefore be transferred to countries outside the EEA.
VI. How long will your personal data be kept ?
18. The Housing Company Ltd. will not keep your personal data longer than necessary for the realisation of the purposes for which the data are collected.
This period is linked to the legal and fiscal obligations of The Housing Company Ltd., as well as the legal need to keep your data outside the retention period for evidence or to respond to requests for information from the competent authority, for example:
- 10 years under anti-money laundering legislation
- 10 years within the framework of the contractual liability of The Housing Company Ltd.
- 7 years for the bookkeeping and accounting documents of the associations of co-owners in connection with the performance of the task of trustee
Outside these periods, your personal data will be deleted or made anonymous.
VII. How will your personal data be secured ?
19. The Housing Company Ltd. uses strict standards to protect the personal data under its control against unauthorised or unlawful processing and against accidental loss, destruction or damage.
The Housing Company Ltd. takes measures of a technical and organisational nature such as encryption, antivirus, firewalls, access controls, strict selection of employees and suppliers, to prevent and detect inappropriate access, loss or disclosure of your personal data.
In the unlikely and unfortunate event that your personal data are compromised under the control of The Housing Company Ltd. by a breach of information security, The Housing Company Ltd. will act immediately to identify the cause of such breach and take action through adequate remedial measures. If necessary, The Housing Company Ltd. will notify you of this incident in accordance with applicable law.
VIII. What are your rights when processing your personal data?
1. Right of access, correction, limitation, deletion, transferability of data and objection.
20. For the above purposes you have:
- A right to inspection of your personal data at The Housing Company Ltd.. This means that you can ask The Housing Company Ltd. if it processes your personal data, for what purposes these data are processed, what categories of data are processed, and to whom they are disclosed.
- A right to restriction if you e.g. contest the accuracy of your personal data and this during a period that The Housing Company Ltd. allows to verify this.
- A right of deletion of your personal data. When your contract with The Housing Company Ltd. has come to an end, you can ask The Housing Company Ltd. to delete your personal data if this is no longer necessary for the purposes for which these personal data were collected. You also have the possibility at any time to request the deletion of personal data processed by The Housing Company Ltd. on the basis of your consent (unless The Housing Company Ltd. has a different legal basis for the processing) or on the basis of the legitimate interest of The Housing Company Ltd. (unless there are overriding compelling legitimate grounds for the processing). The Housing Company Ltd. can in any case keep these personal data, if this would be required for probative purposes in the context of legal proceedings.
- A right to transferability of data that you provide to The Housing Company Ltd. if your personal data are processed on the basis of an agreement or on the basis of your consent to send electronic communications and these personal data are processed using automated processes. Under this right you can ask The Housing Company Ltd. to forward your personal data to yourself or directly to another data controller, as far as this is technically possible for The Housing Company Ltd..
You have the right to object to the processing of your data for the purposes mentioned in article IV.3 and IV.4. However, in the case of IV.3 The Housing Company Ltd. may continue to process your personal data if there are compelling legitimate grounds for processing which outweigh your interests, rights and freedoms or which are related to the initiation, exercise or substantiation of a legal claim.
You can exercise your rights by sending a written request by post, dated, signed and accompanied by a copy of your proof of identity to The Housing Company Ltd., Heirbaan 45 in 3110 Rotselaar or by email to firstname.lastname@example.org.
2. Right to object to the sending of electronic advertisements
21. In IV.5 your consent was requested to process and use your electronic contact details to send you commercial information, advertising or personal proposals (via direct marketing campaigns or electronic newsletters). This applies in particular to communications to your mobile phone number and email address.
You have the right to object to the processing of your personal data for the purposes of electronic direct marketing and to oppose the future receipt of such advertising.
You can inform us of this in the following ways:
- By sending an email with a copy of your identity card to email@example.com.
- By sending a letter by post with a copy of your identity card to The Housing Company Ltd., Heirbaan 45, 3110 Rotselaar.
- By clicking on the link “unsubscribe” at the bottom of an email or electronic newsletter sent by The Housing Company Ltd..
However, the exercise of the right of opposition cannot prevent The Housing Company Ltd. from contacting you for any other purpose, including a legal obligation or the execution of the contract, in accordance with this statement.
3. Right to file a complaint
22. If you have any complaints regarding the processing of your personal data, you can contact us as follows:
- By post : The Housing Company Ltd., Heirbaan 45 at 3110 Rotselaar.
- By email : firstname.lastname@example.org
- Telephone : 016 585 233.
23. You can also lodge a complaint with the Commission for the Protection of Privacy by mail at rue de la Pression 15, 1000 Brussels, or by email at email@example.com, or by telephone at +32 2 274 48 00.