- PRIVACY protection policy www.immovlan.be -
** see also our Terms & Conditions updated on 25/05/2018. **
The purpose of this Charter is to inform you about how your data are processed by CTR-Media via the www.immovlan.be website.
CTR-Media collects and processes your personal data in a transparent manner and in compliance with: the Act of 08 December 1992 on the protection of privacy in respect of the processing of personal data (hereinafter referred to as the “Protection of Privacy Act"); and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the "General Data Protection Regulation"), from its entry into force on 25 May 2018.
CTR-Media pays particular attention to the protection of your privacy and therefore undertakes to take all reasonable precautions required to protect the personal data collected against loss, theft, disclosure or unauthorised use.
1. Under what circumstances does CTR-Media process your personal data?
The website www.immovlan.be, which is managed and operated by CTR-Media, is an online platform for the publication of real estate offers in the broadest sense of the term and for bringing together operators in this field (owners, potential purchasers, potential tenants, various service providers, notaries, etc.). As part of the operation of the platform www.immovlan.be, CTR-Media collects and processes the personal data of its customers, users and prospects in its capacity as “data controller", within the meaning of the Protection of Privacy Act and the General Data Protection Regulation.
2. What categories of data are processed by CTR-Media?
2.1. As part of the operation of the website www.immovlan.be, CTR-Media – potentially – collects and processes the following personal data:
- Personal identification data (surname, first name, postal address, email address, IP address, telephone/GSM/fax number;
- Business data (company name, registered office, company/VAT number, business telephone number, business email address, position, status, representative's name);
- Data on real estate properties that you are selling or renting or that you are looking for (property category, price range, geographic area, number of rooms, floor area, floor, lift, terrace, garden, address, geo-location, etc. .);
- Financial data (bank account number, banking institution);
- Data on browsing behaviour and habits on the website www.immovlan.be and related CTR-Media applications;
- Any other data that you voluntarily communicate to CTR-Media.
2.2. It is possible that CTR-Media may also collect non-personal data. These data are deemed to be non-personal data given that they cannot be used to identify you, either directly or indirectly. These data can therefore be used for any purpose whatsoever, for example, to improve the website www.immovlan.be, or the products and services offered by CTR-Media or its partners.
2.3. In the event that non-personal data are combined with personal data in such a manner that the identification of the data subject may be possible, these data will be processed as personal data until their identification with an individual person is rendered impossible.
3. For what purposes does CTR-Media process your personal data? What are the legal bases for these?
The legal basis for the processing of your data varies depending on the processing involved and, more specifically, on the purpose of this. In principle, when collecting your data, CTR-Media will inform you of the means and methods of collection and processing of your data. On these occasions, CTR-Media will communicate the legal basis of the processing to you.
For example, your data may be collected and processed as part of the performance of the contract that binds you to CTR-Media, which is concluded through the acceptance of the Terms and Conditions of this Website. When the processing is not necessary to fulfil a contractual relationship, it may be based either on your explicit and informed consent, or on the basis of the legitimate interests of CTR-Media as a business (in particular, the principle of free enterprise and the freedom of information). In this respect, CTR-Media always ensures that there is a balance between your interests and its own, for example, by granting you a right of opposition. Your data may also be processed in accordance with a legal or regulatory requirement.
3.2. Processing undertaken by CTR-Media
3.2.1. Contractual basisIn execution of the contract that binds you to it, CTR-Media performs processing, the purpose of which can be described as follows:
- the use of the Website and the services provided on it, and in particular: (a) the monitoring and management of the evolution of an operation the object of which is a real estate property detailed on our Website (sale, rental, etc.); (b) the establishment of contact/a relationship with a vendor/lessor/potential buyer/potential tenant/service providers/notaries/etc.;
- customer management;
- the issuance, collection and verification of invoices;
- to provide you with an activity report;
- to answer your questions when you contact us voluntarily.
- to ensure the publication and visibility of your real estate offers/advertisements on www.immovlan.be and, where appropriate, on partner media (real estate portals, publications, etc.);
3.2.2. ConsentData that are collected on the basis of your express and informed consent are processed for the following purposes:
- to inform you about real estate offers/advertisements (sale, rental, etc.) in accordance with your search criteria;
- to inform you about potential purchasers/tenants in accordance with the desired action (sale/lease, etc.);
- to establish contact/a relationship with a vendor/lessor/potential purchaser/potential tenant/service providers/notaries/etc.;
- to provide you with promotional information on the products and services of CTR-Media and its partners (direct marketing).
3.2.3. Legitimate interestsData that are collected on the basis of the legitimate interests of CTR-Media are processed for the following purposes:
- to prevent and combat fraud or attempted fraud on the website www.immovlan.be and related CTR-Media applications;
- to ensure the technical management of the website www.immovlan.be and related CTR-Media applications.
- to produce anonymous statistics on browsing behaviour and habits on the websites and applications of CTR-Media and, where appropriate, its partners.
3.3. CTR-Media may be required to perform processing that is not yet provided for in this Charter. In this case, CTR-Media will contact the data subject before reusing his/her personal data, in order to inform him/her of the changes and to give him/her the opportunity to, as applicable, refuse this re-use.
4. Are your personal data shared with third parties?
4.1. In the pursuit of all or part of the purposes detailed in Article 3, CTR-Media may be required to transmit some of your personal data to third parties. These Third Parties may be corporations or natural persons. These may be, for example, business partners, IT service providers that maintain the Website, or consultants; CTR-Media selects these third parties with the utmost care and, in particular, based on the guarantees they provide in terms of the protection of personal data.
A list of these third parties is updated and available on the following page of this Website: (see list of partners )
4.2. No data are transferred to third parties that are located in a country outside the territory of the European Union.
4.3. CTR-Media may also be required to disclose your data when required to do so by law or to comply with a court order or an order from a public authority.
5. CTR-Media employees
CTR-Media ensures that, for persons acting under its authority (employees), access to data and the processing options are limited to what they need for the performance of their duties and the fulfilment of the tasks entrusted to them.
CTR-Media will inform the persons acting under its authority of the provisions of the Protection of Privacy Act and the General Data Protection Regulation, as well as any relevant regulations in relation to privacy and personal data protection.
6. What are your rights and how can you exercise them?
6.1. Right to withdraw your consent. When the processing of your data is solely based upon your consent, you may at any time withdraw it upon written request to CTR-Media. The withdrawal of your consent does not affect the lawfulness of the processing performed prior to such withdrawal. For example, when you sign up for a newsletter or an automated mailing, you can cancel your subscription at any time by clicking on the link at the bottom of each email.
6.2. Right of opposition. When the processing of your data is performed for direct marketing purposes, you may at any time object to the use of your data for this purpose.
6.3. Right of access and copy. In any case, you may obtain a copy (including in electronic format) of your personal data free of charge and, if necessary, rectify, complete or delete data that are inaccurate, incomplete or irrelevant.
6.4. Right to data portability. You may also, at any time, request to receive your personal data free of charge in a structured, commonly used and machine-readable format, in particular for the purpose of transmitting it to another data controller.
6.5. How can you exercise your rights? If you wish to exercise any of the rights described above, you must send your written request (including for electronic formats), dated and signed, to CTR-Media with proof of your identity. You will receive a response as soon as possible, and at the latest within one month. In case of a refusal on our part, you are free to contact the President of the Belgium Court of First Instance who rules over any applications in respect of the right to obtain communication, rectification, deletion or limitation of personal data.
7. What is the retention period for your personal data?
The retention period for your personal data varies depending on the purposes of the intended processing. Your data are never retained beyond the time required to fulfil the processing for which it was collected.
Upon expiry of the retention period, CTR-Media will make every effort to ensure that your personal data have been properly deleted.
8. What security measures are implemented by CTR-Media?
CTR-Media implements appropriate technical and organisational measures in order to guarantee a degree of security for the processing and for the data collected that is commensurate with the risks presented by the processing and the nature of the data to be protected, and suitable for the risks.
CTR-Media always uses encryption technologies that are recognised as industry standards within the IT sector. In any case, CTR-Media implements security measures that are appropriate for protecting your personal data against loss, theft, misuse or alteration of information received, disclosure or unauthorised use.
9.Do you have a question or want to submit a complaint or make a claim?
9.1. If you wish to respond to any of the practices described in this Charter, you may contact CTR-Media at the addresses specified in Article 10 " How to contact CTR-Media? ".
9.2. You can lodge a complaint with the Belgian Privacy Commission (which will become the Data Protection Authority) at the following address:
Commission for the Protection of Privacy
Rue de la Presse, 35
Tel. + 32 2 274 48 00
Fax. + 32 2 274 48 35
9.3. The law also allows you to bring an action to the court of first instance in your place of domicile.
For further information on complaints and possible remedies, CTR-Media recommends that you consult the following address for the Belgian Privacy Commission: https://www.privacycommission.be/en/node/19254.
10. How to contact CTR-MediaFor any question/request/claim, you can contact CTR-Media:
- By email: firstname.lastname@example.org
- By telephone: +32(0)2 730 33 11
- By post: CTR-MEDIA S.A., Rue Royale, 100 à 1000 Brussels – Belgium.
11. What happens if changes are made to this Charter?
The content of this Charter may be amended in accordance with the rules contained in Article 1 of the Terms and Conditions of this Website.
The present version of the Charter is dated on 25/05/2018.
At the same date we updated our Terms & Conditions .