Privacy & GDPR
The purpose of this privacy statement (hereinafter the “Statement”) is to inform all persons (with the exception of employees) whose personal data (hereinafter “Personal Data”) is processed by S.P.R.L. EXPONENTIAL INVEST, whose registered office is at Chaussée de Marche 496/21, 5101 ERPENT (Belgium) and which is registered with the Crossroads Bank for Enterprises under no. BE 0664.610.841 (hereinafter “we” and “Secundo”).
1. Purpose of the Statement
Through this Statement, we wish to make sure that you:
– are informed of the processing of your Personal Data and of your rights;
– retain control over the Personal Data of yours that we process;
– are able to exercise your rights in respect of your Personal Data.
This Statement has been drawn up in accordance with the provisions of:
– the Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data and,
– Regulation 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 (hereinafter the “GDPR”).
2. Who this Statement is addressed to
This Statement applies to the processing of Personal Data concerning:
– our suppliers and/or commercial partners,
– our users and prospects, and
– the visitors to our website.
In so far as we may collect and process Personal Data of third parties communicated to us by you, we ask you to inform those third parties of the existence of this Statement so that they may take note of the processing that we carry out on their Personal Data as well as of their rights.
3. Definitions
For the purposes of this Statement, we have defined the terms below as follows:
Consent: a freely given, specific, informed and unambiguous indication of wishes by which the data subject (you) accepts, by a statement or by a clear affirmative action, that (your) Personal Data concerning them be subject to a particular processing operation (e.g. sending you advertising by email).
Personal data (hereinafter “Personal Data”): information relating, directly or indirectly, to a data subject (you). Below you will find the Personal Data that we collect and use about you.
Purpose of the processing: the reason for which the Personal Data is processed.
Data subject: a natural person (you) who can be identified, directly or indirectly, by Personal Data, in particular by reference to an identifier such as a name, an identification number, an online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.
Data controller: a natural or legal person who processes Personal Data on their own behalf and, as such, determines the means and the purposes of the processing operation(s).
Processor: a natural or legal person who processes Personal Data on behalf of a data controller.
Processing: an operation or set of operations applied to Personal Data or to a set of Personal Data, such as collection, recording, organisation, structuring, consultation, use, communication, storage, adaptation, retrieval, etc.
4. Who are we?
4. 1. Secundo as data controller
In the course of our activities, Secundo processes your Personal Data (by collecting it, storing it, etc.), in particular with a view to putting you in touch with our partners. In this respect, we are considered the controller of the processing of your Personal Data. It is we who determine the purposes (the why) and the means (the how) of the processing of your Personal Data.
Our partners, for their part, will be considered data controllers when they process your Personal Data in the course of their activities.
As data controller, we pay particular attention to the protection of your privacy and we therefore undertake to take the reasonable precautions required to protect your Personal Data against loss, theft, disclosure or unauthorised use.
However, we reserve the right to disclose your Personal Data in accordance with what is provided for above in the Statement.
You may contact us by the following means:
– email: rgpd@secundo.com
– telephone: +32.80.30.64.46
– post at the following address: chaussée de Marche 496/21 – 5101 Erpent
4. 2. GDPR contact person
We have also designated a GDPR contact person.
The task of this contact person is to inform you about the processing of your Personal Data by Secundo as well as about the exercise of your rights. They provide advice and ensure that the regulations in force, in particular the GDPR, are properly complied with.
You may address the contact person for any question relating to the processing of your Personal Data and if you wish to exercise one of the rights described in point 13 of the Statement.
The GDPR contact person may be contacted by the following means:
– Email: rgpd@secundo.com
– Telephone: +32 81.30.64.46
– Postal address: chaussée de Marche 496/21 5101 Erpent
5. What Personal Data do we collect about you?
5.1. Personal Data of our users, prospects, partners or third parties contacting Secundo directly
We collect your Personal Data (see below) from you. However, you may also pass on to us Personal Data relating to the representatives of your company, to your staff, your colleagues and/or independent consultants (hereinafter commonly referred to as “you” or “your”).
If you communicate to us the Personal Data of your representatives, your staff, your colleagues and/or your independent consultants, you must inform them of the existence and the content of this Statement.
The Personal Data concerns the following data:
– identification data such as surname, first name, gender, etc.,
– contact data such as telephone number, email address, postal address, etc.,
– any other personal data that you communicate to us voluntarily during our contacts (bank account number, national register number, identity card number, date of birth).
As regards our users, your Personal Data may be collected directly from you when making a request through our site or during any event organised by Secundo.
We may also process data concerning you coming from third parties such as the media (immoweb, vlan, logicimmo, etc.). This is communicated to us only following a request made through the forms available on their respective sites.
5.2. Personal Data of the visitors to our website
When you visit our website https://fr-be.secundo.com/ , we also collect Personal Data concerning you. This is:
– the IP address, and
– “cookies”.
“Cookies” are small files saved on your computer by your browser which allow us to obtain certain information about your use of our website (e.g. language choice, duration of your visit to the page, preferences, etc.). They make it possible in particular to facilitate navigation on our site (through the use of so-called necessary cookies) but also to better adapt the website to your wishes and preferences. You will find more information on this subject in our “cookie policy”.
6. For what purposes do we need your Personal Data?
6.1. Providing our services to our users
In order to provide you with our services, we process your Personal Data (see point 5.1.).
If you refuse to communicate certain essential data, our agency may not be able to process your request.
6.2. Proper performance of the service contract concluded with our partners
In connection with the performance of the service contract that we have concluded with our suppliers/partners, we process their Personal Data (see point 5.1.) in order to be able to perform the concluded contract correctly, in particular by collecting the contact details of the contact persons at our suppliers/partners, etc.
Some of the information we ask of you is mandatory and conditions the conclusion of the contract concluded with you. If you do not provide this information, we will unfortunately not be able to conclude a contract with you.
6.3. Marketing operations
We may also send you advertising and/or a newsletter if:
– you have already used our services,
– you have previously consented to receiving this type of communication.
We may also publish your written comments and opinions relating to our services on our marketing and advertising materials (e.g. website, brochures, etc.) together with your name and your town if you have given us your explicit consent in this respect.
6.4. Securing the website
On the basis of our legitimate interest, which is to secure our website https://fr-be.secundo.com/, we collect and process your IP address.
6.5. Use of cookies
When you browse our website https://fr-be.secundo.com/, we install “cookies” (as explained in point 5.2.):
– which are necessary for the proper functioning of our website, on the basis of our legitimate interest, which is to offer you a functional website, and
– for the purpose of analysing your browsing on our website, only if you have previously consented.
If you would like to obtain more detailed information on the use of our cookies, their retention periods, etc., please consult our “[cookie policy]” accessible from our website https://fr-be.secundo.com/.
6.6. Use of social media
In order to increase our presence on the internet and to be closer to our users and future users, we are also present on social media such as Facebook, LinkedIn, YouTube, Instagram, Snapchat, TikTok, etc.
By visiting these sites, you may, on the basis of your free consent, share some of your Personal Data directly with us by contacting us, commenting on and/or sharing our publications.
Furthermore, we encourage you to read the “privacy” statement that these third parties have published on their site in order to be informed of the processing carried out by these third parties on your Personal Data in their capacity as data controller of your Personal Data.
6.7. The proper functioning of our agency
In order to function properly as a company, we process your Personal Data in order to:
– use it as evidence in a potential dispute (in particular Personal Data relating to a transaction/contractual relationship),
– enable us to defend ourselves in court, exercise and safeguard our rights as well as the rights of the persons we represent in court,
– manage our agency (for administrative purposes), prevent the risks associated with our activities (e.g. in order to comply with certain legal obligations, in order to prevent risks in terms of money laundering, fraud, etc.),
– handle the complaints and/or questions received,
We process your Personal Data on the basis of our legitimate interests set out below and, in the alternative, on the basis of our legal obligations (in terms of tax and accounting evidence, etc.).
7. What are the grounds justifying the processing?
We are only authorised to use and process your Personal Data if one of the following conditions is met:
– we have your free and explicit consent to use your Personal Data for a certain purpose. Thus, we ask for your consent when:
- you are not yet a user with us and you wish to receive commercial information or advertising (through direct marketing actions or electronic newsletters),
– the use of your Personal Data is necessary for the performance of a contract with the various partners of Secundo or, at your request, to take steps with a view to concluding a contract with the partners of Secundo.
– we are legally required to process certain Personal Data, and more particularly to communicate it to the competent authorities. This will be the case in particular, but not exclusively, in tax and accounting matters, for example.
– we have a legitimate interest in processing your Personal Data. This will be the case in particular as regards:
- sending commercial information or advertising to our users,
- the collection and recording of your IP address with a view to securing our website,
- and the purposes mentioned in point 6.8. of this Statement.
8. With which other persons do we share your Personal Data?
Only those of our colleagues who need access to your Personal Data in order to carry out their professional tasks may access it. These persons act under our supervision and our responsibility.
Furthermore, we also call upon external suppliers/partners, who take charge of certain processing operations so that we can offer you our services, namely IT, legal, financial, accounting and other services. Given that these third parties have access to your Personal Data in connection with the performance of the services requested, we have taken technical, organisational and contractual measures in order to ensure that your Personal Data is processed and used solely for the purposes mentioned in point 6 of this Statement.
Lastly, if we are subject to a legal obligation, your Personal Data may be communicated to public institutions, tax authorities or any other competent authority.
9. Where do we store and process your Personal Data?
Your Personal Data will be transferred outside the European Union (hereinafter the “EU”) and/or the European Economic Area (hereinafter the “EEA”), in particular to Switzerland, since the system we use to store your personal data is located in the Canton of Geneva, Satigny, in Switzerland.
Switzerland is considered by the European Commission to be a country offering an adequate level of protection in accordance with the GDPR.
Apart from Switzerland, we do not transfer your personal data outside the EU/EEA.
If we subsequently plan to have your Personal Data recorded and processed outside the EU and/or the EEA, we will notify you explicitly.
If you use the social media referred to in point 6.7. of this Statement to contact us, comment on and/or share our publications, these third parties may transfer your Personal Data outside the EU and/or the EEA. In this respect, we encourage you to read the “privacy” statement that these third parties have published on their site.
10. How long do we keep your Personal Data?
We will not keep your Personal Data for longer than is necessary to achieve the objectives mentioned in point 6 of this Statement.
Given that the need to keep Personal Data depends on the type of Personal Data concerned, on the subject of the processing and on the purpose of the processing, retention periods may vary considerably.
Personal Data relating to prospects processed for commercial prospecting purposes is kept for a minimum of 5 years.
Indeed, buying a second home abroad requires reflection; it is clear that such a purchase is not decided upon within a few weeks.
We have many clients who decided on a purchase after 6 years of reflection, during which we had regular contacts with a view to carrying out the purchase project.
The Personal Data of Users will be kept for as long as is necessary to provide the service requested by the User.
As regards other Personal Data, you will find below the criteria on which we base ourselves to define the retention periods:
– for how long do we need your Personal Data in order to be able to provide the service or to benefit from the services requested?
– have we defined and announced a certain retention period?
– have we obtained authorisation to extend the retention period?
– are we subject to a legal retention/archiving obligation, to a contractual or equivalent obligation?
As soon as we no longer need your Personal Data and we are no longer legally required to keep it, we will delete it permanently or, if this proves impossible, we will anonymise it in our system.
11. How do we secure your Personal Data?
Your Personal Data is considered strictly personal and confidential. We take the appropriate technical and organisational measures to protect it against any destruction, loss, accidental alteration and any damage, accidental or unlawful access or other unjustified processing.
12. What are your rights?
Under the applicable regulations, as a data subject, you have certain rights (see below). These rights are not absolute and may be subject to certain restrictions expressly provided for in the applicable legislation.
12.1. Right to be informed
You have the right to be informed, at the latest when your Personal Data is collected, about the processing that we carry out, your related rights and the exercise of those rights. It is for this purpose that we have drawn up this Statement.
12.2. Right of access
You have the right to access the Personal Data that we process and have a right of oversight over it. If you wish, we will provide you with a copy of your Personal Data. You may also obtain an answer to any question concerning the processing of your Personal Data (reasons for the processing, recipients, retention period, etc.).
12.3. Right to rectification
You have the right to request the deletion, rectification and/or addition of your Personal Data that is erroneous, incomplete, inadequate or out of date.
12.4. Right to be forgotten
You have the right, subject to the conditions laid down by the regulations and free of charge, to obtain the erasure of your Personal Data.
12.5. Right to restriction of processing
You have the right to obtain the restriction of the processing of your Personal Data, making it possible to stop the processing that we carry out on a transitional and temporary basis. You may stop a specific processing operation, or all the processing operations that we carry out on your Personal Data, permanently by invoking the right to object.
12.6. Right to data portability
You have the right to receive your Personal Data that we process in a digital, readable and structured format in order to be able to save it for personal (re)use, or to ask us to transfer it to another data controller, in so far as this is technically possible.
12.7. Right to object to certain processing operations
You have the right to object to the processing of your Personal Data carried out on the basis of a legitimate interest (see point 6 of the Statement) on grounds relating to your particular situation; thus making it possible to stop permanently the processing that we carry out.
For example, you may object at any time to Secundo sending commercial and/or advertising information.
However, we draw your attention to the fact that the exercise of your right to object does not prevent us from contacting you for any other purpose, including the performance of the contract, in accordance with this Statement.
12.8. Right to withdraw consent at any time
You have the right to withdraw your consent at any time. When you use this right, we will stop the processing operation(s) that we carry out on your Personal Data.
13. How to exercise your rights?
To exercise the aforementioned rights, you may send us a written request by:
– Email: rgpd@secundo.com
– Post: chaussée de Marche 496/21 5101 Erpent
We ask you to indicate clearly the right you wish to invoke and which processing operation(s) you wish to object to or which consent you wish to withdraw. Your written request must be dated and signed and must contain proof of identity.
Each request will be handled free of charge. However, where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may:
a) require the payment of a reasonable fee taking into account the administrative costs incurred in providing the information, making the communications or taking the measures requested; or
b) refuse to act on these requests.
Your request will be handled within one month. This period may be extended by two months, taking into account factors such as the complexity and the number of requests. In the event of an extension of the period, you will be informed of it and of the reasons for the extension.
Where applicable, we will inform the third parties to whom your Personal Data has been communicated of any rectification, erasure or restriction carried out, unless this proves impossible or requires disproportionate effort.
14. How to ask questions or lodge a complaint?
If you have questions or if you wish to lodge a complaint concerning the processing of your Personal Data, you may contact us by:
– Email: rgpd@secundo.com
– Post: chaussée de Marche 496/21 5101 Erpent
If you are not satisfied with our answer, if you have remarks concerning the exercise of your rights or if you consider that our processing of your Personal Data does not comply with the legislation, you have the right to lodge a complaint with the Data Protection Authority.
In this respect, we encourage you to visit their website: https://www.autoritedeprotectiondonnees.be or to contact them by:
– post:
Data Protection Authority
Rue de la Presse, 35
1000 Brussels
– telephone: 02/274.48.00,
– email: contact@apd-gba.be
15. Amendment of this Statement
We reserve the right to amend or supplement this Statement if necessary.
In the event of significant amendments, the date of amendment will be updated, a copy of the new Statement will, as far as possible, be communicated to you and will be posted on our website https://fr-be.secundo.com/.
We encourage you to consult this Statement periodically in order to take note of the way in which we process and protect your Personal Data.