SREIM BRUXELLES located at Avenue Louise 331 at 1000 Brussels, Belgium, a company incorporated under Belgian law registered with the ECB under the number BE 0713.430.842 and / or its affiliated companies and subsidiaries (hereinafter referred to as " Groupe Serris "," we "," us "," us ") are committed to protecting and respecting your privacy. To identify the affiliated companies and subsidiaries of the SERRIS Group.



This Privacy Policy ("Policy") aims to specify how we process personal data ("personal data", "data", "information") of our Customers, job applicants, prospects, partners and suppliers (hereinafter "you", "your", "your") that we collect or that you provide to us (see Section 2 below).

Please read the following carefully to understand how we will use your personal data.


Our Policy informs you about:
1. The identity of the controller
2. Who is this Policy for?
3. How do we collect your Data?
4. The Data We Collect
5. Cookies and other tracers
6. The use of your Data
7. Legal basis for processing your Data
8. Disclosure of your Data
9. Transfer of your Data
10. Your rights
11. The security of the Data collected
12. The conservation of your Data
13. External websites
14. How do I know if this Policy has changed?
15. How to contact us?

1. The identity of the controller


The controller of your personal data is the SREIM Group. If you have any questions or requests regarding our Policy or how we process your personal data in general, please contact us via section 15 below.

2. Who is this Policy for?



This Policy is intended for our:
- Customers (namely on the one hand our promoters, operators, institutional or non-institutional investors, sellers of real estate (banks, insurance, funds, real estate, other natural or legal persons), project managers, main brands national and international, and on the other hand our tenants of commercial premises, business premises, offices, residences and student residences) ("Customers");
- Prospects (a promoter, operator, institutional investor or not, seller of real estate (banks, insurance, funds, real estate, other natural or legal persons), project managers, a sign or a tenant who could be interested in concluding a contract with us);
- Partners (any person or company that can intervene in order to facilitate the activity of our customers; [for example to insert]);
- Job applicants (ie potential candidates for a job with us);
- Suppliers (any company that provides services to us in the course of our activities; [for example to insert]).

3. How do we collect your data?


The information we collect will be saved, used and protected by us in accordance with:
- The Regulation of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC ( general data protection regulation) (“GDPR”), including its corrigenda;
- French Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms;
- The Belgian Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data; And in all cases, as far as in force and applicable, including any amendment (eg by decree, ordinance, decree), modification or replacement occurring from time to time (hereinafter collectively referred to as the " data protection legislation ”).
Depending on the nature of the relationship that you have with the SREIM Group, we are likely to collect your personal data (i.e. any data relating to a person directly or indirectly identifiable) in several ways:
- During your exchanges with our services (sales, acquisitions, management, accounting, general services, HR), our real estate brokers (brokers), service providers;
- When you fill out a contact form (paper or electronic);
- When you visit one of our websites;
- When you contact us directly by e-mail, telephone, post, email, message (instant messaging applications, such as Messenger), via our Website, or others;
- Via the websites of our service providers and partners (e.g. IT broker, student accommodation websites);
- When putting together your application as part of a property rental request;
- During events and trade fairs (e.g. real estate fairs), according to our exchanges and meetings.

4. The data we collect


We collect and process the following data:

- Your personal identification data (names, first names, email, telephone, national identifier / social security number / passport number / Registration number in the national directory for the identification of natural persons (NIR), date of birth, household composition, postal address, etc.);
- During each visit to our Websites we will automatically collect technical information, including the IP address used to connect your computer to the Internet, the type of browser and your browser version, the setting time zone, type and plug-in versions of browser, operating system and platform; your device ID, etc. ;
- Your data relating to your professional career (professional qualifications);
- Your financial data (published balance sheets, KBis, etc.);
- Image recordings: profile photo;
- Your financial characteristics (account number, payment methods, other payment data);
- Information about you from messages you post on third party websites, or through a comment / notice, or when you contact us by email, mail, telephone or any other communication channel .

5. Cookies and other tracers


Our websites use cookies. They help us provide you with a good experience when you browse them and also allow us to improve it.

6. The use of your data


In accordance with the legal foundations (legal bases) developed in section 7 below, the use and processing of your data must be for a specific purpose (i.e. a purpose). Your data is collected and used for the following purposes:

A. The execution of a contract or pre-contractual measures


- Analysis of your request for your application file (paper / online), rental financing;
- Management of disputes and litigation with our Customers, suppliers and partners;
- The management and execution of a service, in particular the management of your rental financing, the management of the acquisition of existing or new buildings;
- Managing the acquisition of company shares;
- Managing your complaints;
- The management of our real estate;
- Management of guarantees and sureties;
- Managing our contracts with our suppliers and partners;


B. Compliance with our legal and regulatory obligations


- Knowledge of our Customers;
- The fight against money laundering and the financing of terrorism;
- Management of fire, accident and other risk insurance;
- The prevention of fraud;
- Performing internal and external audits;
- To verify and execute financial transactions related to your payments;

C. The legitimate interests of the SERRIS Group


- Management and monitoring of our prospects;
- Improving the knowledge of our Customers, the selection and targeting of them (in particular to carry out market studies / data analysis);
- Commercial prospecting and marketing communication;
- Management and monitoring of our suppliers;
- Management and monitoring of our partners;
- To provide you with information on the other services we offer and which may be of interest to you;
- Fraud prevention and risk management;
- To examine and assess your application when you apply via our Internet Sites or a third-party site (eg via LinkedIn);
- To respond to all your requests / questions when you intentionally communicate with our services;
- To administer our Websites and for internal operations, including troubleshooting, data analysis, tests, research, and for statistical and survey purposes;
- To improve our Websites and our social networks in order to ensure that the content is presented in the most effective way for you and for your computer / device;
- As part of our efforts to keep our website secure and prevent fraud;
- To measure or understand the effectiveness of the advertising and marketing campaigns we offer, and to provide you with relevant advertising;

D. Your consent


- For (direct) marketing purposes: to contact you in order to invite you to events (eg trade fair, real estate fair), to offer you appropriate, personalized marketing content likely to interest you.

7. Legal basis for processing your data


Your information is collected and processed under the following legal bases:
- Your information is collected and processed if it is necessary for the pursuit of our legitimate interests, provided that your fundamental rights and freedoms are not affected (eg we use your information for the improvement of knowledge of our Customers);
- Your information is collected and processed in the context of the execution of the contract concluded with you, e.g. in the case of a rental contract, or in the case of a contract with a supplier or partner;
- If they are necessary for compliance with a legal obligation to which we are subject; or
- When you have given your consent for the collection and processing of your data, e.g. if you have given your express consent to this end, we may use your contact data (e.g. your email address) to send you commercial communication.

8. Disclosure of your data


For the aforementioned purposes (see Section 6), we may share your information with:
- other entities (branches or subsidiaries) that are part of the SERRIS Group in order to allow them to offer you their specific services and inform you about their activities.
- our business partners [for example to insert without mentioning a name but rather categories];
- public authorities (including judicial and police authorities);
- banks and insurers;
- our professional advisers (e.g. from regulated professions);
- our IT service providers;
- our service providers or subcontractors to whom we entrust specific operational functions or services [for example to be inserted without mentioning a name but rather categories];
- our marketing service providers;
- online payment service providers;
- analytics and search engine providers who help us improve and optimize our site, such as Google Analytics;
We will also disclose information to third parties:
- in the event of the purchase or sale of a business or assets, we reserve the right to disclose your data to the seller or buyer of that business or assets;
- during such transactions, if the SERRIS Group or all of its assets were to be purchased by a third party, information concerning its Customers will be one of the transferred assets;
- if we are under an obligation to disclose or share your data in order to comply with a legal obligation or to protect the rights, property or safety of the SERRIS Group, our Customers or others. This includes sharing information with public authorities (including judicial and police authorities) in particular in the event of judicial, administrative or extrajudicial proceedings, including during proceedings before regulatory bodies, or in the event of 'cyber incident;
- if this is necessary to achieve one of the purposes described in section 6 of this Policy.

9. The transfer of your data


We may transfer your information outside the European Economic Area (EEA), including to the United States if necessary (i) to achieve one of the objectives set out in section 6 and / or ( ii) to disclose your information to a third party in accordance with section 8 of this Privacy Policy.
If your information is transferred outside the EEA, we will ensure that it is protected by the following guarantees:
- the laws of the country to which your information is transferred ensure an appropriate level of data protection (article 45 of the GDPR); or
- the transfer is governed by the data protection provisions approved by the European Commission (Article 46.2 of the GDPR) or is subject to the EU-US Privacy Shield.
If you would like to learn more about the transfer of your data and / or the guarantees implemented (including how to obtain a copy), do not hesitate to contact us via section 15 below. below.

10. Your rights


You have certain rights regarding the data that we process about you. You can exercise these rights by contacting us (see contact details below):
- You have the right to be informed in a clear, transparent and easily understandable manner about how we use your information. This is why we provide you with all of this information in this Policy;
- You have the right to access the data we hold about you - indeed we want you to be aware of the data we have about you and we want to allow you to check whether we are processing your data in accordance with applicable data protection legislation (see Section 3);
- You have the right, in certain circumstances, to request the limitation of the processing of your information. In the event of restricted processing, we will continue to store your data, but we will no longer use it;
- You have the right to request the rectification of your information if it is inaccurate or incomplete;
- You have the right, in certain circumstances, to request the erasure of your information from our systems;
- You have the right to lodge a complaint about the way in which we handle or process your information with the national data protection authority:

o In Belgium: at the Data Protection Authority (APD) https://www.autoriteprotectiondonnees.be/introduire-une-requete-une-plainte (FR) / https: //www.gegevensbeschermingsautoriteit. be / verzoek-klacht-Indienen (NL);
o In France: at the National Commission for Data Protection (CNIL) https://www.cnil.fr/fr/plaintes;
o For other countries, please see the list here;

- You have the right to object at any time, for a reason which is specific to you, to the processing of your personal data. Indeed, if you consider that one of the treatments infringes your privacy and / or causes you excessive damage, you can use this right. In particular, you have the right to withdraw your consent for the use of your data for direct marketing purposes. However, you cannot in any case prevent us from processing your data if the processing is necessary for the conclusion or execution of your contract with the SERRIS Group; - You have the right to receive, in certain circumstances, your data in a structured, commonly used, machine-readable and interoperable format so that you can reuse it for your own purposes within the framework of various services (right to portability ). Please note, however, that we may retain certain information for legal or administrative purposes (e.g. keeping accounting books).
In accordance with the Data Protection Act, and insofar as you fall within the scope of this law, you have the possibility of communicating to us (general or specific) directives relating to the conservation, erasure and communication of your data after your death. These directives can also be registered with a trusted digital third party certified by the CNIL. You can designate a person who will be responsible for carrying them out. Otherwise, your heirs will be responsible for their implementation.
For all the aforementioned requests, please send us an e-mail with "data protection request" as the subject and include a copy of your identity card or other proof of your identity ( e.g. driver's license) to help us prevent unauthorized access, modification or deletion of your information. We will respond as soon as possible. If we need more than a month (from the receipt of your request) to respond to your request, we will keep you informed.

11. The security of the data collected


We have implemented a number of security measures on our Website to prevent disclosure or unauthorized access to the information collected and / or received. We have strived to create secure and reliable websites. Please note, however, that the confidentiality of any communication or other material transmitted to us or that we transmit to third parties via our websites or by e-mail cannot be guaranteed. We accept no responsibility for the security of information transmitted through these methods.
All the information you provide to us is kept on secure servers. When you have received (or chosen) a password that allows you to access certain parts of our Websites, you are responsible for maintaining the confidentiality of this password. We ask you not to share your passwords.

12. The conservation of your data


The information we collect is kept in accordance with applicable data protection law. In any case, your information will not be kept longer than necessary to achieve the objectives set out in this Policy.
The retention period of your data is variable and is based on the following criteria:
- Our contractual rights and obligations with you;
- The sensitivity of your data;
- Security reasons;
- Limitation periods under applicable law (s);
- The guidelines issued by the competent data protection authorities (e.g. The European Data Protection Supervisor (EDPS), the CNIL, the APD); and
- The jurisprudence of the courts and tribunals in the matter;
Unless:
- the processing of your data is necessary in the context of an actual or potential litigation (e.g. we need this information to establish or defend our rights), in which case we will keep your Data until the end of a such litigation; and or
- retention is necessary to enable us to comply with any legal or regulatory obligation (eg for tax purposes), in which case we will keep your information for as long as necessary for that obligation.
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13. External websites


Our Websites may, from time to time, contain links to or from the websites of our partner networks, our advertisers or our affiliates. If you follow a link to one of these websites and / or applications, please be aware that these websites and / or applications have their own data protection policies which we do not control. They are therefore not the subject of this Policy and we accept no responsibility for these policies. Please check these policies before sending information to these websites and / or applications.

14. How do I know if this Policy has changed?


By using our Websites, you acknowledge that you have read the terms of this Policy and agree to the collection and use of your information as indicated above.
We may modify this Policy at any time, in particular to take account of any legislative or regulatory changes. Any changes we make to our Policy will be posted on our Websites and, if applicable, will be brought to your attention by email. We will describe the changes in the "Change History" tab [To be created on the Site].
Please check this page frequently for updates or changes to our Policy. Your continued use of our Websites following the publication of these modifications implies your acceptance of them.
This Policy was last updated on [insert date of last update].

15. How to contact us?


If you have any questions or comments regarding this Policy, you can send them in writing to the following address: SREIM BRUXELLES SPRL, For the attention of the legal department, Avenue Louise 331 1000 Brussels, Belgium; or by email to:…