Introduction

This privacy policy sets out how WP Real Estate BV handles the personal data of its customers and all other natural persons interacting with WP Real Estate.

This privacy policy covers how WP Real Estate BV, with registered office at Descampstraat 9, 8370 Blankenberge, deals with the personal data of its clients, natural persons, and all other natural persons who interact with WP Real Estate BV (hereinafter referred to as ‘you’).

WP Real Estate BV is committed to the protection of your personal data and privacy and therefore handles and protects your personal data in a transparent, appropriate and lawful manner. By 'personal data', we are referring to 'any form of information that allows you to identify yourself directly or indirectly as a natural person'.

When processing your personal data, WP Real Estate BV complies with all competent legislation, including, since 25 May 2018, the European General Data Protection Regulation 2016/679 of 27 April 2016 ('GDPR'), along with any other legislative act amending it. More information on personal data protection can be obtained from the Belgische Commissie voor de bescherming van de persoonlijke levenssfeer (Belgian Commission for the Protection of Personal Data), also known as the Gegevensbeschermingsautoriteit (Data Protection Authority). Please read this policy carefully to ensure you know and understand WP Real Estate BV's privacy policy. In addition, this policy is updated regularly.

The most recent version of this policy can be found on our website. Should any significant amendments be made, we will inform you through our usual communication channels.

PROCESSING OF PERSONAL DATA

WP Real Estate BV is responsible for processing your personal data:

WP Real Estate BV - Descampstraat 9, 8370 Blankenberge – BE0802.670.644 – privacy@wprealestate.be – 050 43 55 03. WP Real Estate BV is accountable to the Gegevensbeschermingsautoriteit (Data Protection Authority) when it comes to the processing of your personal data. WP Real Estate BV shall determine the purposes for which your personal data will be processed, as well as the means used and the processing properties.

WP Real Estate may call upon specialised third-party service providers to process your personal data on behalf of WP Real Estate, in accordance with both WP Real Estate's instructions and this privacy policy. Only such personal data as is strictly necessary will be transmitted to third-party service providers.

PERSONAL DATA THAT WE PROCESS

WP Real Estate processes your personal data due to you using our services and/or by you actively providing it to us, via our website or through correspondence, email, social media or during conversations. Here is an overview of the personal data we may process:

• identification data (surname, first name, date, place and country of birth, nationality, etc.);
• contact details (postal and email address, home and mobile telephone number);
• marital and family status;
• banking and financial information;
• information regarding occupation, identity of employer, position, income and other personal wealth information;
• information regarding and digital footprints of your mobile or non-mobile devices.
• Information regarding your activity on our website
• Internet browser and type of device

SPECIFIC AND/OR SENSITIVE PERSONAL DATA WE PROCESS

Our website and/or service does not seek to collect data on website users under the age of 16, unless they have parental or guardian authorisation. However, we are unable to check whether users are over the age of 16. We therefore advise parents to become engaged in their children's online activities to avoid collecting data about children without parental consent. If you believe that we have collected personal information about a minor without such consent, please contact us via privacy@wprealestate.be and we will delete this information.

FOR WHAT PURPOSE AND ON WHAT BASIS WE PROCESS PERSONAL DATA

WP Real Estate processes personal data for the following purposes, as permitted by law:

• Sending our newsletter and/or other direct marketing
• Calling or emailing you if necessary to carry out our services and marketing policy
• Enabling you to create an account
• WP Real Estate analyses your website behaviour to improve the website and tailor the products and services offered to your preferences
• To fulfil WP Real Estate BV's legal obligations (e.g. answers to queries from the tax authorities, statutory obligations of the directors and shareholders, obligations to prevent money laundering and the financing of terrorism, etc.)
• To enter into or perform a contract with you, or to undertake certain initiatives at your request prior to the conclusion of said contract
• To safeguard the legitimate interests of WP Real Estate BV, balancing these interests with your fundamental rights and freedoms
• To represent our interests in any legal disputes
• In specific cases, with your consent, as a result of a specific and explicit request, preceded by clear information. This consent may be withdrawn by you at any time in accordance with the law.

HOW LONG WE STORE PERSONAL DATA

Personal data shall be stored for a time-limited period, no longer than necessary, taking into account the reasons for processing, as determined on a case-by-case basis.

WP Real Estate applies a maximum retention period that is in principle equal to the presiding statutory limitation or expiry periods. As a rule, WP Real Estate will keep personal data in the context of e.g. a property purchase in application of the Woningbouwwet (Housing Act) for a period of 10 years from final delivery.

his period is linked to WP Real Estate's tax and legal obligations, as well as the legal need to keep your data beyond the retention period for evidence purposes or to respond to requests for information from the competent authority:

• 10 years under anti-money laundering legislation;
• 10 years in the context of contractual liability;
• 7 years for the accounts and accounting documents of the co-owners' organisations following the performance of the trustee's duties.
• Outside of these periods, your personal data will be deleted or anonymised.

SHARING OF PERSONAL DATA WITH THIRD PARTIES

WP Real Estate may employ external third-party service providers as part of its operations. WP Real Estate may transfer personal data to these external service providers to the extent necessary to perform their assignment.

WP Real Estate cannot be held liable for the operations of external third-party service providers, nor when WP Real Estate or these external service providers (have to) transfer personal data on the basis of (i) a statutory provision, (ii) a legitimate interest, (iii) an explicit order from a supervisory or administrative authority, (iv) a police, investigative or judicial investigation, or (v) a judicial decision.

COOKIES, OR SIMILAR TECHNIQUES, THAT WE USE

WP Real Estate uses functional, analytical and tracking cookies. A cookie is a small text file that is stored in the browser of your computer, tablet or smartphone the first time you visit this website. WP Real Estate uses cookies for a purely technical purpose. These ensure that the website works properly and that, for example, your preferences settings are remembered. These cookies are also used to make the website work properly, as well as optimise it. We also use cookies that track your browsing behaviour, allowing us to offer more tailored content and advertisements.

You can opt out of cookies by setting your internet browser to stop saving cookies. In addition, you can also delete any information previously stored via your browser settings.

Cookies explanation

Cookies are also placed on our website by third parties. These include advertisers and/or the social media organisations. Here’s an overview:

Necessary cookies

These cookies are essential for navigating the website and using the features provided. Without these cookies, requested services such as remembering your login details or the items in your shopping basket cannot be provided.

Performance cookies

These cookies collect anonymous data on how people use our website. We use Google Analytics cookies to find out how customers arrive at our website, how they browse or use our website and what can be improved, such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not contain any personal information based on which your identity can be determined.

Functional cookies

These cookies remember any choices you make, such as the country you are visiting the website from, language choice and search parameters such as size, colour or product line. This information can then be used to provide you with an experience that better reflects your choices, making a visit more targeted and enjoyable. The data collected by these cookies may be anonymised. These cookies cannot track your browsing activity on other websites.

Social media cookies

These cookies allow you to share what you have been doing on the website across social media such as Facebook and Twitter. We have no control over these cookies. Please refer to the respective privacy policy for information on how these cookies work.

Block cookies

You can block cookies by activating the browser setting that allows you to refuse the storage of cookies. However, if you use your browser settings to block these cookies, you may not be able to access (certain parts of) our website.

If you wish to withdraw your consent (you can do so at any time), you can delete your cookies using your browser settings. Please note that web browsers allow you to change your cookie settings.

These settings can usually be found under the 'Options' or 'Preferences' menu of your web browser. To better understand these settings, the following links may be useful. If not, you should consult the 'Help' section in your web browser for more details.

RIGHTS IN THE PROCESSING OF PERSONAL DATA

• Right of access, rectification, restriction, deletion, transferability of data and objection for the purposes mentioned above, you have:
• Right to access your personal data at WP Real Estate BV. This means that you can ask WP Real Estate BV whether it processes your personal data, for what purposes it is being processed, what categories of data are being processed, and to whom they are disclosed;
• Right of rectification if you establish that your personal data is incorrect or incomplete;
• Right to restriction if, for example, you dispute the accuracy of your personal data and for a period of time that allows WP Real Estate BV to check this;
• Right to have your personal data deleted. When your contract with WP Real Estate BV comes to an end, you may ask WP Real Estate BV to delete your personal data if it is no longer required for the purposes for which it was collected. You also have the option to request the deletion at any time of personal data processed by WP Real Estate BV based on your consent (unless WP Real Estate BV has another legal ground for such processing) or based on WP Real Estate BV's legitimate interest (unless there are overriding compelling legitimate grounds for processing). WP Real Estate BV may in any event keep this personal data if this would be required for evidence purposes in the context of legal claims;
• Right to transferability of data which you yourself have provided to WP Real Estate BV if your personal data is processed based on an agreement or based on your permission to send electronic communications and such personal data is processed using automated processes. Under this right, you may ask WP Real Estate BV to forward your personal data to yourself or directly to another data processor, to the extent technically possible for WP Real Estate BV.

You have the right to object to the processing of your data for the purposes set out in Articles IV.3 and IV.4. However, in the case of IV.3, WP Real Estate BV may continue to process personal data if there are compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms or grounds relating to the establishment, exercise or support of legal claims.

You can exercise your rights by sending a written request by post, dated, signed and with a copy of your ID enclosed to WP Real Estate BV, Descampstraat 9, 8370 Blankenberge, Belgium, by email to privacy@wprealestate.be or by using the website contact form. Right to oppose the sending of electronic advertising In IV.5, your consent was requested to process and use your electronic contact details to send commercial information, advertising or personalised offers to you (via direct marketing campaigns or electronic newsletters). This especially applies to communications to your mobile phone number and email address. You have the right to object to the processing of your personal data for electronic direct marketing, as well as to oppose the future receipt of such advertising. You can notify us in the following ways:

• By sending an email with a copy of your ID to privacy@wprealestate.be;
• By sending a letter by post with a copy of your ID to WP Real Estate BV - Descampstraat 9, 8370 Blankenberge, Belgium;
• By clicking on the 'unsubscribe' link at the bottom of an email or electronic newsletter sent by WP Real Estate BV;
• By sending a request via the contact page on our website.

However, exercising the right to object cannot prevent WP Real Estate BV from contacting you for any other purpose, including for any legal obligation or performance of the contract, in accordance with this policy. Right to lodge a complaint If you have complaints regarding the processing of your personal data, you can contact us via the details below:

• By post: WP Real Estate BV – Descampstraat 9, 8370 Blankenberge, Belgium
• By email: privacy@wprealestate.be
• By phone: 050 43 55 03
• Via the contact form on our website

You can also complain to the Commissie voor de Bescherming van de Persoonlijke Levenssfeer (Commission for the Protection of Privacy) by post at Rue du Printing Press 15, 1000 Brussels, Belgium, by email at commission@privacycommission.be, or by phone on +32 2 274 48 00.

HOW WE SAFEGUARD PERSONAL DATA

WP Real Estate maintains strict standards when it comes to protecting the personal data under its control against unauthorised or unlawful processing, as well as against accidental loss, deletion or damage.

WP Real Estate therefore takes technical and organisational measures such as encryption, antivirus, firewalls, entry controls, strict selection of employees and suppliers, to prevent and detect inappropriate access, loss or disclosure of your personal data.

In the unlikely and unfortunate event that, under WP Real Estate's watch, your personal data is compromised by a data security breach, WP Real Estate will act immediately to identify the cause of such a breach and take action through appropriate remediation measures. If necessary, WP Real Estate will notify you of such incidents in accordance with the applicable law.

If you feel that your data is not secure or there are indications of misuse, please contact our customer service team or email privacy@wprealestate.be.

JURISDICTION - APPLICABLE LAW - ACCEPTANCE

This Privacy Policy is governed, interpreted and implemented in accordance with Belgian law, which is exclusively applicable in the event of any dispute.

The courts of the Bruges judicial district have exclusive jurisdiction in adjudicating over any dispute that might arise from the interpretation or implementation of this policy.

By visiting the website, the data subject accepts all the provisions set out in this Privacy Policy.