SRL BELGIUM SR, is part of the Sotheby's International Realty group. However, please note that each agency is legally and financially independent.
SRL BELGIUM SR, with registered office at Avenue Louise n°251, 1050 BRUSSELS, registered with the ECB under number 0537.736.425 (hereinafter, “BELGIUM SR”, the “Controller”, collectively, “we”, “us” or “our”) is the Controller within the meaning of the data protection legislation in force.
In this capacity, we undertake to respect the confidentiality of the personal data we process and to process them in accordance with the applicable legislation. Specifically, processing is carried out in accordance with Regulation (EU) 2016/679 (General Data Protection 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, as it is currently in force and as it may be amended from time to time (hereinafter the “GDPR”), as well as the law of July 30, 2018 on the protection of natural persons with regard to the processing of personal data (together the “Applicable Data Protection Laws”).
We also ensure that we are transparent about our personal data processing practices. In this Privacy Statement (the “Statement”), we describe how we may collect, use, disclose and otherwise process personal data about you that we become aware of in the course of providing our services and in connection with the use of our website (collectively, the “Services”).
1. Overview of our collection and use of personal data
In this overview, we outline the personal data we collect and how we use it, with these uses explained in more detail in the following sections of our Privacy Statement below.
Please keep in mind that the actual information we collect and our use of that personal data will vary depending on the nature of our relationship and interactions with you. In addition, in some cases (e.g., where required by law), we ask for your consent or give you certain choices before we collect or use certain personal data.
A. Categories of Personal Data We Collect.
Generally, we collect the following types of personal information:
- Identifying Data: such as name, contact information, IP address and online identifiers.
- Customer Record Data: paper and electronic records containing personal data that you provide to us in order to access or use our Services, such as name, signature, address, telephone number, e-mail and other contact information, property information, search criteria (for a property), financial data, etc.
- Business Data: This includes histories of real estate, products or services purchased, obtained or considered, or other purchase or usage histories or patterns, and your search criteria.
- Usage Data: information about your activity on our website, including, but not limited to, browsing history, search history and information about an individual’s interaction with our services or an advertisement.
- Inferences: Inferences drawn from any of the above used to create a profile that reflects an individual’s preferences, behaviors or other characteristics.
- Special Categories of Data: We do not collect this type of data unless it is necessary to provide you with a particular service (for example, disability and health information to provide you with goods suitable for people with disabilities or to provide you with facilities and/or accommodations suitable for your needs at events we organize) and other profile information you provide to us.
B. Use of Personal Data.
In general, we may use and, where appropriate, disclose your personal information for the following purposes:
- To provide support and Services
- To analyze and improve our business
- Personalize content and experiences
- Advertising, marketing and promotional purposes
- Secure and protect our business
- Defend our rights and interests
- Conduct audits, reports, corporate governance and internal operations
- Compliance with legal obligations
This Statement applies to the processing of personal data by us in connection with the provision and/or use of our Services.
More specifically, it concerns our customers in the broad sense (sellers, buyers, tenants, prospects), whether former, current or potential, independent agents and suppliers working with and/or for us, including their employees, and visitors to our website.;
In general, this Statement relates to anyone who uses or wishes to use our Services, or whose personal data we receive in connection with the Services, or who otherwise interacts or communicates with us regarding our Services.
The processing of personal data about individuals will vary depending on the circumstances.
Personal information. Personal data includes any information that identifies, relates to, describes or is reasonably likely to be associated with or identify a particular person. This concerns in particular the information listed in article 1. A. of this Statement.
Not covered by this Statement. This Privacy Statement does not apply to job seekers and applicants who apply for employment with us, or to our employees and self-employed workers.
3. Our collection of personal data
Generally, we collect your personal data on a voluntary basis. However, please be aware that if you refuse to provide certain personal data considered mandatory or essential, you may not be able to access certain Services or we may not be able to fully respond to your request.
In the majority of cases, we collect personal data concerning you directly from you, in particular when they are related to the use and/or provision of the Services. In some cases, they may be collected from third parties (such as public databases, independent agents and other real estate professionals (eg notaries), banks, social networks, etc.
Information We Collect Directly. We collect information you provide to us, such as:
- Information you provide in order to benefit from our Services, such as real estate searches and preferences, whether you are considering buying or selling real estate, accommodation search criteria, information on financing purchase of real estate and other information related to the purchase or sale of real estate;
- Information you provide when you create an account on our website, when you provide contact information and/or send us other personal data;
- When you complete or submit a form through our Site;
- When you participate in surveys or contests, submit requests or otherwise contact us;
Information We Collect From Third Parties. This may in particular include the following data:
- Real estate professionals. If you interact or list a property with an independent agent or other real estate professional (IMMOWEB, etc.), we may receive personal data about you and your property from them, such as your name and address of your property, your registration and your contact details, among others.
- Property records. We may collect information about individuals and real estate through public databases, such as land ownership and tax records maintained by Heritage Documentation.
- Social networks. If you choose to link, create, or log into your Services account with a social media service (e.g., Twitter, Facebook, Instagram, Linkedin, etc.), or engage with an app or site separate web that communicates with the Services, we may receive personal data about you or your connections from that network. In many cases, you can control the personal data you share with us through the privacy settings available on those third-party social media services.
Please note that in some cases, the third parties concerned will have to be qualified as data controller. We invite you to consult their privacy statements to have a better view of their processing activities.
4. Legal basis for our processing of personal data
In accordance with the GDPR (and other Applicable Data Protection Laws), we collect, use and otherwise process personal data through the following bases of lawfulness:
- Performance of contract: as necessary to enter into or perform our contract with you.
- Fulfillment of legal obligations: for compliance with legal obligations.
- Our legitimate interests: in pursuit of our legitimate business interests, including:
– Performance of contractual obligations with other Sotheby’s International Realty Affiliates LLC group companies, exchange of information between group companies;
– Implementing and operating global support services (e.g. IT) for our business operations;
– Customer relationship management and improvement of our Services, including (direct) marketing and analytics, and generally advertising;
– Prevention of fraud, including misuse of company computer systems or money laundering;
– Physical, IT and network perimeter and employee security;
– Internal investigations, audits (internal and external);
– Mergers, Acquisitions and Reorganizations and Other Business Transactions;
– Defense in court.
- With your consent: In some cases, we rely on your consent to collect and process your personal data.
In addition, we may process your personal data, if necessary, to protect the vital interests of any person.
5. Use of personal data
Please note that the purposes for which we may process personal data vary depending on the circumstances. Generally, we will process your personal data for the purposes set out below.
- Provide assistance and Services: including, for example, sending or facilitating communications between you, independent real estate professionals and our affiliated entities, and other users of the Services (tenants – lessors), providing the products and Services you request (and send related information), operate our Services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide assistance, respond to your requests and provide technical support; and for other customer service and support purposes. (Legal bases: performance of our contract with you; legitimate interests)
- Analyze and improve our business: including to better understand how users access and use our Services, to evaluate and improve our Services and business operations, and to develop new features, offerings and Services; to conduct surveys and other evaluations, such as customer satisfaction surveys; and for other research and analytical purposes. (Legal basis: our legitimate interests)
- Personalize content and experiences: including to provide or recommend content and/or Services, tailor the content we send or display on our Services, personalized instructions, and to otherwise personalize your experiences. (Legal bases: our legitimate interests and/or with your consent)
- For advertising, marketing and promotional purposes: including to reach you with more relevant advertisements and announcements and to evaluate, measure and improve the effectiveness of our advertising campaigns; to send you newsletters, offers or other information that may be of interest to you; to contact you about our Services or information that may be of interest to you; and to administer promotions and contests. (Legal bases: our legitimate interests and/or with your consent)
- Securing and protecting our business: including to protect and secure our business operations, assets, services, network and computing and technology resources, and our people; to investigate, prevent, detect and take action in case of fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third parties, or other unauthorized activities or misconduct. (Legal bases: our legitimate interests and/or compliance with laws)
- Defend our interests: including to manage and respond to actual and potential legal disputes and claims, and to establish, defend or otherwise protect our rights or interests, including in the context of potential or actual disputes with third parties. (Legal basis: our legitimate interests)
- Audit, reporting, corporate governance and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and/or related to any actual or contemplated merger, acquisition, sale or transfer of assets, financing, bankruptcy or restructuring of all or part of our business. (Legal basis: our legitimate interests and/or compliance with our legal obligations)
- Comply with our legal obligations: to comply with legal and regulatory requirements. (Legal basis: compliance with our legal obligations)
- Aggregated and Anonymized Information. We may anonymize personal data and create anonymous and aggregated data sets and reports in order to evaluate, improve and develop our business, products and services, prepare industry benchmarking reports and for other research, marketing and analytical purposes. Aggregated or anonymized data will not identify you personally and will therefore no longer constitute personal data for the purposes of data protection laws.
6. Transfer of personal data
We may disclose the personal data we collect about you as set forth below or as otherwise described at the time of collection or sharing.
- Service Providers: We may pass personal data to third party service providers who use this information to provide services to us, such as hosts, auditors, advisors, consultants, and service and support providers to customers.
- Subsidiaries and Affiliates: We may share your personal data with our affiliates, who may process your personal data as set out in this Statement, including to share relevant news, information and offers with you. Where required by applicable law, we will obtain your consent to such transfer.
- Third Parties: We may disclose personal data to third parties in order to provide our Services, respond to or fulfill your requests, and/or with your consent, including with:
– Independent real estate professionals and owners and operators of real estate brokerage firms to enable them to provide the services you request.
– Third parties to provide you with a service that you have requested as part of a partnership or promotional offer made by a third party or by us.
– The public, if you subscribe to a public part of the Services, such as comments, social media posts or other features visible to the public or generally to registered users of the Services.
– Third parties with whom you choose to let us share information, for example other applications or websites that integrate with the Services, or those with Services that we integrate with.
– Third parties we work with to provide you with more personalized content and advertisements, and to track the effectiveness of campaigns.
- Business transfers: We may disclose or transfer personal data in connection with any current or proposed merger, sale and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event, including related to an audit
- Legally required: We may transfer personal data if we are required to do so by law (e.g. law enforcement, courts, tax authorities, etc.)
- Protect our rights: We may disclose personal data when we believe it is necessary to respond to claims against us or, to comply with legal process (for example, subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and to protect the rights, property, or safety of us, our customers and customers, or others.
Anonymized and aggregated data. We may share aggregated or anonymized information with third parties for analytical and other purposes.
7. Cookies, tracking and analytics
You can also find more information about targeted or “interest-based” advertising and disable many ad networks at www.youronlinechoices.eu.
8. Social Network Features and Third-Party Plug-ins
Please see the privacy policies of these services for more information about how they handle the data you provide or share through them. We do not receive or store passwords to your third party social media accounts in this context.
9. Third Party Websites
The Services may contain links to third-party services. We do not own, operate or control third party websites, including those of independently owned and operated International Realty Affiliates LLC Sotheby franchisees. We are not responsible for the privacy practices of other services and expressly disclaim any liability for their actions, including actions related to the use and disclosure of personal data by such third parties. Where applicable, we encourage you to read the privacy policies of third party services.
10. International Transfers of Personal Data
We may, in certain circumstances, transfer certain information to third parties outside the EU and/or the EEA, including for the transfers listed in Section 6 of this Statement or to the country where a property about which you have requested information is located.
In addition, we inform you that the Data is hosted on servers located in the United States.
Where the third party to whom we transfer your Data is located in a country that does not offer the same level of data protection as the European Union under local data protection laws, we rely on appropriate personal data transfer safeguards.
BELGIUM SR employs a significant number of technical, physical and organizational security measures to ensure the integrity, confidentiality and availability of worker data. BELGIUM SR has implemented security techniques to protect stored employee data from unauthorized access, improper use, alteration, illegal or accidental destruction and accidental loss. BELGIUM SR continues to enhance its security procedures as new technologies become available. BELGIUM SR also warrants (contractually) that third parties and affiliates that process employee data on behalf of BELGIUM SR will adhere to similar security measures, again in compliance with the requirements of legal obligations.
Should an incident, and more specifically a data breach in relation to your personal data, occur, BELGIUM SR will act promptly and diligently in accordance with the applicable legal provisions. In particular, we will take the necessary steps to notify the Data Protection Authority of the breach in question within the legal deadlines, and will inform you if the breach presents a high risk to the rights and freedoms of the Individual, in accordance with the applicable legislation.
12. Data retention
We will retain your Personal Data for the period necessary to fulfill the purposes described in this Privacy Notice, unless a longer retention period is required or permitted by law, including where we believe it is necessary to establish, defend or protect our rights and interests or those of others.
The length of time we retain personal data will therefore vary depending on the information concerned and the purposes determined.
With respect to data and files that we process as a subcontractor, where applicable, we retain such personal data in accordance with the instructions of our data processors.
The Services are not intended for minors under the age of 18, and we do not knowingly collect any personal information, or knowingly track the use of our Services, from minors. If we become aware that Personal Data about minors has been collected, we will take appropriate steps to attempt to delete such Personal Data.
14. Your rights
In accordance with the applicable regulations, you have the following rights which can be exercised at any time and free of charge, except in the case of abuse:
- The right to request access to your data (A)
- The right to rectification (B)
- The right to erasure of data (C)
- The right to object to the processing (D)
- The right to request the restriction of processing (E)
- The right to data portability (F)
- The right to lodge a complaint with the Supervisory Authority (G)
A. Right of access
You have the right to request confirmation from BELGIUM SR whether or not data relating to you is being processed and, where it is, you may request access to such data. In particular, you may request that we provide the following information as well:
- the relevant categories of Data and the purposes of the processing ;
- the recipients or categories of recipients to whom the Data have been or will be communicated, in particular recipients who are established in third countries;
- if possible, the period for which the Data is to be kept or, failing that, the criteria used to determine this period;
- the rights you have with respect to your Data;
- where the Data has not been collected from you, any available information as to its source;
This right can be easily exercised by sending an email to email@example.com.
B. Right of rectification
You have the right at any time to rectify any data concerning you that is inaccurate or incomplete or, at the very least, to provide BELGIUM SR with a statement indicating that the data is incomplete and indicating the additional elements to be taken into account. This right can be easily exercised by sending an email to firstname.lastname@example.org.
C. Right to erasure
You have the right to request BELGIUM SR to delete data concerning you in the following cases:
a) the data is no longer necessary for the purposes for which it was collected or otherwise processed;
b) you have withdrawn the consent on which the processing is based and there is no other legal basis for the processing
c) you have exercised your right to object as explained in point D. below;
d) your data have been processed unlawfully;
e) your data must be erased to comply with a legal obligation;
f) your data has been collected in the context of an offer of information society services to a child.
If your data are necessary to BELGIUM SR for the purposes for which they are processed, they will not be deleted, in particular, when the processing is necessary for BELGIUM SR to comply with a legal obligation, to perform the contract and to contact you or for the establishment, exercise or defense of its legal rights.
This right can easily be exercised by sending an email to email@example.com.
D. Right to object to the processing
You have the right to object, at any time, for reasons related to your particular situation, to the processing of your Data carried out by BELGIUM SR in the pursuit of its legitimate interest. In this case, BELGIUM SR will cease the processing, unless the processing is necessary for the establishment, exercise or defense of legal claims or if BELGIUM SR can demonstrate that there are compelling legitimate reasons which override your interests and rights and freedoms.
This right can be exercised by sending an email to firstname.lastname@example.org.
E. Right to the limitation of processing
Where processing is restricted, with the exception of storage, the data subject to the restriction may only be processed further within the limits determined with your consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another person.
You have the right to request BELGIUM SR to limit the processing when any of the following apply:
(a) you dispute the accuracy of the data;
b) the processing is unlawful, but you do not wish the data to be erased
c) BELGIUM SR no longer needs the data for the purpose of processing, but the data is still necessary for you to establish, exercise or defend legal claims
d) you have objected to the processing and it is verified whether the legitimate reasons pursued by BELGIUM SR prevail over yours.
This right can easily be exercised by sending an email to email@example.com.
F. Right to Data Portability
You have the right to obtain that the data concerning you that you have provided to us to enable the performance of the contract or with your consent and that are processed by means of automated processes, be transmitted to you or be transmitted to another data controller if this is technically possible.
If applicable, this right may be exercised when you request the termination of the Services provided by BELGIUM SR.
G. Questions and right to lodge a complaint with the Supervisory Authority
For any question relating to the processing of your personal data and/or the exercise of your rights, you can contact our Data Protection Officer by sending an e-mail to the attention of the D.P.D. (Data Protection Officer):
o by email: firstname.lastname@example.org
o by post: BELGIUM SR, 1050 BRUSSELS, Avenue Louise n°251
o by phone: +32 2 640 08 01
The Regulation also allows you to lodge a complaint with the Data Protection Authority, if you believe that BELGIUM SR has not acted in accordance with the data protection legislation, using the contact details below:
Data Protection Authority
Rue de la Presse, 35, 1000 Brussels
Phone: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
Or on its website at: https://www.autoriteprotectiondonnees.be/contact
15. Changes to this policy
The present policy is, by nature, evolving and could therefore be modified at any time, in particular to reflect the evolution of our activities and to comply with possible legislative changes.
Any changes will be made in accordance with the various laws and regulations applicable to privacy and data protection.
We encourage you to review this Policy regularly to stay informed of the latest version.
This policy was last updated in April 2023.