Table of contents
- Who is responsible for processing of your personal data?
- Which personal data do we process about you?
- Why and how do we process your personal data?
- Who has access to your personal data?
- Do we transfer your personal data outside the European Economic Area?
- How do we protect your personal data?
- How long do we keep your personal data?
- How can you exercise your rights?
- How can you contact us?
2. Who is responsible for processing of your personal data?
Eaglestone SA, a limited liability company whose registered office is established at Avenue Louise 489, 1000 Brussels (Belgium), is the controller of the processing of your personal data. This means that Eaglestone determines for what purposes and with what means your personal data will be processed.
3. Which personal data do we process about you?
• Directly identifiable information that you provide to us
- We do not process directly identifiable information about you, such as your name, address, phone number, etc., unless you yourself provide us with your personal data, for example:
- through the contact form on our websites,
- when you subscribe to our newsletter, press list or investors mailing list via our company website (www.Eaglestone.be),
- when you request a brochure on one of our websites,
- when you conclude a purchase contract with us,
- when you contact us directly by e-mail, phone or otherwise,
- when you give us your business card,
- when you apply for a job with Eaglestone,
Exceptionally, we may process directly identifiable information about you provided to us from other sources, for example when we engage a recruitment office for the search of an employee for a vacant position and certain personal data (e.g. your name, your contact information, your resume, etc.) are to that purpose made available to us. In such cases, unless we have reason to doubt this, we assume that the original source from which we receive your information has collected such information in accordance with the data protection rules.
• Automatically generated non-directly identifiable information
4. Why and how do we process your personal data?
All data we collect from you, will be processed by us in accordance with the Regulation 2016/679 of 27 April 2016 of the European Parliament and of the Council 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 (General Data Protection Regulation) (GDPR), and any applicable corresponding or equivalent national laws or regulations, as in force and applicable, and as may be amended, supplemented or replaced from time to time.
4.1. For the technical and functional management of our websites
We process personal data for the technical and functional management of our websites and to make our websites easy to use. By using your data, we can check how our websites are used and we can improve their content and layout. This data also allows us to adequately secure our websites.
4.2. In the context of our operational functioning, day-to-day business management and administration
We process your personal data when carrying out our ordinary business activities. To this end, we can process data such as your contact details, your function, your company, your powers to represent a company, your address, your e-mail address, your bank account number and date of birth.
We process this information, depending of the activity, based on our obligation to comply with legal obligations, on the basis of the performance of a contract to which you are a party, or based on our legitimate interest in pursuing an efficient and smooth operation of our business (e.g. keeping a list of our professional contacts).
4.3. In the context of our commercial residential activities
When you make an offer to purchase an apartment on our website or when you visit us or one of our agents and provide us with certain personal information with regard to your search for an apartment, we process your personal data in order to check availabilities for your preferred apartment and conclude a purchase agreement with you. Once a purchase contract is entered into, we process your data to provide you with the requested apartment and to manage the contractual relationship (including as the case may be in the framework of legal claims).
For this purpose, we process the data you provide to us (in person or via our website), such as your name, your e-mail address, your telephone number, your country and any additional information or special requests. When we enter into a purchase agreement with you, we process data such as your contact details, financial data e.g. your bank account number, …
The processing of your personal data for this purpose is based on your request to take certain steps prior to (possibly) entering into a purchase agreement and on Eaglestone’s legitimate interest in assessing whether a counterparty will be able to meet its contractual obligations. Once the purchase agreement is entered into, the processing is based on the performance of a contract to which you are a party.
4.4. To keep you informed about our activities
We process your personal data when you wish to be kept informed about the latest Eaglestone information, e.g. by signing up to the mailing list on the website, or by submitting a request via the contact form on the website to receive our press releases or other investor related information (www.eaglestone.be).
To this end, we can process data such as your name, your job, your company name, your address, your e-mail address, your rental preference, your telephone number and your preferred language.
Depending on the case, we process this information based on your consent or based on our legitimate interest to keep our stakeholders informed about our activities. If the processing of your personal data is based on your consent, you may withdraw your consent at any time (see below under section 9).
4.5. To answer your questions
If you ask us a question by telephone, via the contact form on our websites or by e-mail, we will process your personal data in order to answer that question. For this purpose, we can process data e.g. your name, your contact information, your correspondence with Eaglestone, and any other personal data you provide us with that may be relevant to answering your question.
We process this information based on your consent. You are free to provide us with your personal data for this purpose, and you may withdraw your consent at any time (see below under section 9).
4.6. To contact you in the context of a selection and recruitment process
When you apply for a job at Eaglestone or one of its subsidiaries (e.g. by mail, at a job fair etc.), we process your personal data in order to contact you and to follow up on your application.
For this purpose, we process data such as your name, your contact information, your correspondence with Eaglestone, your resume, and other documents you provide us with. The processing of your personal data for this purpose is based on your request to take steps prior to (possibly) entering into a contract or on Eaglestone’s human resources related legitimate interests, including identifying, screening and evaluating your profile for potential employment.
5. Who has access to your personal data?
- our subsidiaries.
- certain selected service providers which render services for Eaglestone in accordance with the instructions provided by Eaglestone (e.g. professional advisors and attorneys, IT related service providers (including for services consisting of hosting the websites or the distribution of press releases), providers of recruitment related services, etc.).
- prospective acquirers in the event that Eaglestone would sell all or a part of its business or assets.
We do not provide any personal data to other parties except when required by law, regulation or by court order, or required to protect the rights, property or safety of Eaglestone group or its stakeholders (e.g. to conduct investigations into possible breaches of law, or to detect, prevent and protect against fraud and any technical or security vulnerabilities).
6. Do we transfer your personal data outside the European Economic Area?
7. How do we protect your personal data?
Eaglestone has implemented a number of security features throughout our websites and software systems in order to protect your personal data from destruction, loss, modification or any other unauthorised processing. Note however that the confidentiality of any communication or material transmitted to or from us or any other party via websites or email cannot be guaranteed. We accept no responsibility or liability for the security of information transmitted via these methods.
All information you provide to us is stored on our secure servers, that may only be accessed by a limited number of persons holding special access rights and who undertake to respect and maintain its confidential nature.
8. How long do we keep your personal data?
The information we hold about you will be retained in a manner consistent with the applicable data protection legislation. Eaglestone does not store your personal data for longer than necessary for the purposes for which it is stored, unless:
- the retention is necessary to protect the interest of Eaglestone (e.g. in connection with any actual or potential dispute, in which case Eaglestone retains the information until the end of the applicable prescription period); and/or
- the retention is necessary to comply with any legal or regulatory obligation (e.g. for tax or accounting purposes), in which case we will keep your information for as long as required by that obligation.
9. How can you exercise your rights?
You have the right to request free access to the personal data processed by Eaglestone, to request the correction or removal of your data or to request a restriction of the processing. You may also request the portability of your data and you may object to the processing of your personal data, without substantiation in the case of direct marketing, or substantiated in other cases. Please note that the applicable legislation may impose conditions on exercising the above rights.
When the processing of your personal data is based on your consent, you may withdraw this at any time. Withdrawal of your consent does not affect the lawfulness of the processing based on consent before withdrawal.
You can direct your request based on the above rights by mail to the address mentioned below. Please include a copy of your identity card to help us prevent unauthorised individuals from accessing, changing or deleting your information. Eaglestone cannot handle your request without proof of your identity. We will respond to your request as soon as practically possible. If we need more than one month (from receipt of your request) to respond to your request, we will let you know.
You also have the right to file a complaint with the supervisory authority, which is the Belgian Data Protection Authority. It can be reached by mail at Rue de la Presse 35, 1000 Brussels, and by e-mail at the following address: firstname.lastname@example.org.
10.How can you contact us?
- by e-mail at email@example.com or firstname.lastname@example.org;
- by mail at Eaglestone SA, Avenue Louise 489, 1050 Brussels (Belgium); or at Eaglestone S.à r.l., Avenue J.F. Kennedy 44, L-1855 Luxembourg;
- by phone at +32 2 627 87 14.