Privacy notice
COFINIMMO SA/NV (hereafter: “we”, “us”, ”COFINIMMO”), with company number BE 0426.184.049 and located at Avenue de Tervueren/Tervurenlaan 270 | 1150 Brussels | Belgium, processes your data. COFINIMMO is the Controller of your data within the meaning of the GDPR.
This Notice sets out the basis on which any information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your information and how we will use it.
By visiting https://www.cofinimmo.com (“our Website”), you are accepting and agreeing to the practices described in this Privacy Notice.
COFINIMMO is committed to protecting and respecting your privacy by processing your data in a manner compliant with applicable data protection laws.
Here is how:
- Cookies
Our Website uses cookies. This helps us to provide you with a good experience when you browse on our Website and allows us to improve our Website. Some cookies are necessary for the proper functioning of the Website and cannot be refused if you wish to visit the Website. Other cookies are used to personalize your settings (functionality cookies) and advertising (targeting and advertising cookies) and for analysis and statistics (tracking and performance cookies) .You can refuse them if you want to. For detailed information on the cookies we use and the purposes for which we use them, see our Cookies Notice.
- Processing of your data
Why do we process your data?
- The processing of the data of the visitors of our Website.
- The processing of the data of COFINIMMO's staff.
- The processing of the data of candidates to a job at COFINIMMO.
- The processing of the data of the tenants of COFINIMMO’s buildings.
- The processing of the data of visitors of COFINIMMO’s premises.
- The processing of the data of COFINIMMO’s data processors.
- The processing of the data of other COFINIMMO’s contractants (purchaser of COFINIMMO’s buildings, SubProcessors, other suppliers of goods and services for COFINIMMO).
- The processing of the data of potential future tenants or purchaser of COFINIMMO’s buildings.
- The processing of the data of the visitors of our Website
Categories of Data - We collect and process the following information about you:
- Information you give us:
This is information about you that you give us by filling in forms on our Website or by corresponding with us by phone, email or otherwise. It includes information you provide to us when you complete an online contact form or subscribe to the newsletter. The information you give us may include your last name, first name and email address.
- Information we collect about you.
During each of your visits to our Website, we will automatically collect the following information:
- Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), products/services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
- Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for following purposes:
- To improve our Website to ensure that content is presented in the most effective manner for you and for your computer/device.
- To improve our Website to ensure that content is presented in the most effective manner for you and for your computer/device.
Purpose of the processing
- COFINIMMO processes your data when you visit our Website, learn about our activities and read our latest news.
Therefore, we process your information in order to:
- Administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- Improve our Website to ensure that content is presented in the most effective manner for you and for your computer/device;
- Allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our Website safe and secure and to prevent fraud.
- Ensure that the content from our Website is presented in the most effective manner for you and for your computer/device.
- COFINIMMO processes your data for the management or our professional and/or contractual relationship.
In that sense, we use your information to:
- Carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- Notify you about changes to our services;
- COFINIMMO also contact you based on your information to promote its activities and inform you about it through our Newsletter.
- Finally, COFINIMMO processes your data when you file a contact request on our Website in order to respond to such request and answer to your questions.
Legal basis
- Visit of our Website: the processing of your information is essential for the execution of the contract under which COFINIMMO provides its Website to internet users who wish to access it.
- Management of our professional and/or contractual relationship: the processing of data is necessary for the performance of a contract or necessary to take steps at the request of the data subject prior to entering into a contract.
- Subscription to the newsletter:
- If you subscribed to our newsletter, you gave your consent to the processing of your data for the reception of such newsletter, e.g. you have given your prior express consent to the use of your email address for sending you marketing materials.
- If you did not subscribe to our Newsletter but are already a client, tenant, buyer of COFINIMMO’ services, it is in our legitimate interest to sent you our Newsletter. In other words, the processing of your information for the communication of the newsletter is necessary for pursuing our legitimate interests, considering your fundamental rights and freedoms do not override these interests.
- Contact request: the processing of the data is necessary to respond to the contact request that you initiated. Therefore, you consented to the use of your data.
Recipients of the data
We may share your data to third parties including:
- Our affiliates/other entities within the group;
- Public authorities (including judicial and police authorities);
- Our suppliers of IT related services, e.g. SAP;
- Our suppliers of marketing related services, e.g. MailChimp, Company Webcast;
- Analytics and search engine providers that assist us in the improvement and optimization of our site, e.g. Google.
We will also disclose your information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets;
- If the Company or substantially all of its assets are acquired by a third party, in which case information held by it about its customers may be one of the transferred assets;
- If we are under a duty to disclose or share your information in order to comply with any legal obligation or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with public authorities (including judicial and police authorities) in the event of, for example, a cyber-security incident;
Duration of the processing
The information we hold about you will be retained in a manner consistent with the applicable data protection legislation. In any event, your information shall not be kept longer than is necessary to achieve the purposes stated in this Privacy Notice. In particular, we will only keep:
- Your information relating to your online query for as long as needed to provide you with the requested information.
- The information collected and processed based on your consent, as long as you do not withdraw such consent.
- The information we processed based on our legitimate interest, as long as you do not oppose to such processing
- For the rest, data is retained for maximum 10 years after the end of our contractual relationship or professional relationship for liability reasons.
Unless:
- The processing of your information is necessary in connection with any actual or potential dispute (e.g. we need this information to establish or defend legal claims), in which case we will keep your information until the end of such dispute; and/or
- The retention is necessary for us to comply with any legal or regulatory obligation (e.g. for tax purposes), in which case we will keep your information for as long as required by that obligation.
- Information you give us:
- The processing of the data of COFINIMMO's staff
Categories of Data
This is your identification, contact and financial/banking data. This may include your name, surname, nationality, photo, address, telephone number, job title, email, date and place of birth, bank account, salary information, etc.
Purpose of the processing
COFINIMMO processes the data of its employees in order
- to manage the working relationship which binds them and also in order to control the respect of the application of the IT Corporate policy by the employee (including the rules on the use of the Internet by the employee as well as the use of his professional electronic mailbox).
These data also enable COFINIMMO to proceed with the payment of the salaries of its employees. - to contact them if there is a risk that they may have come into contact with a person infected with the COVID-19 virus during their working day on COFINIMMO’s premises.
Legal basis
The processing is necessary for the performance of the employment contract concluded by COFINIMMO and its employees which includes the IT Corporate policy.
The processing related to the COVID-19 virus is based on your explicit consent (Article 9.2.a of the GDPR) that you can withdraw at any moment.
Recipients of the data
This data will be transmitted to the COFINIMMO’s human resources service and to social administrations if needed as well as to any recipient with whom the disclosure of such data is imposed by a legal obligation to which COFINIMMO is subject.
Duration of the processing
The data concerning COFINIMMO’s employees is retained as long as the employee works for COFINIMMO and maximum 10 years after the end of the employment relationship for liability purposes.
Data relating to the "COVID-19" processing will be retained for 15 days.
- to manage the working relationship which binds them and also in order to control the respect of the application of the IT Corporate policy by the employee (including the rules on the use of the Internet by the employee as well as the use of his professional electronic mailbox).
- The processing of the data of candidates to a job at COFINIMMO
Categories of data
This can include your last name, first name, nationality, picture, address, phone number, email, date and place of birth, resume, references, and cover letter.
Purpose of the processing
Through COFINIMMO’s website or directly by email, or any other channel, you can submit an application to a job at COFINIMMO. When you send us a spontaneous application or when you respond to a job offer, your data will be processed at your request in order to evaluate the possibility of a contractual relationship.
Legal basis
The processing of that information is necessary in order to take steps at the request of the data subject prior to entering into a contract (employment contract).
Recipients of the data
This data will be transmitted to the COFINIMMO employees appointed and responsible for human resources in order to assess your application and give you an answer.
Duration
The data you provide to us as part of an application will be deleted within 6 months of the end of the selection process.
- The processing of the data of the tenant (and its staff) of COFINIMMO’s buildings
Categories of Data
The personal data of the tenant and its staff (in particular surname, first name, ECB/VAT number, image, domicile or residence, telephone numbers (fixed or mobile), e-mail address, date and place of birth, national register number, bank account, proof of bank guarantee, possible rental arrears, correspondence, data relating to access badges, number plate in the event of renting a parking space, etc.) are processed by COFINIMMO.
Purpose of the processing
This data is processed by us to the extent necessary for the following purposes under the contract:
- to proceed, if necessary, to the registration of the lease contract;
- to check the proper performance of the Tenant's contractual obligations;
- to enable COFINIMMO and the Tenant to communicate by telephone or by post, in particular on the subject of the rented property and its community life (possible repairs to be made, availability to read a meter, etc.);
- to notify a modification of the lease contract or of the data protection policy (in particular the addition of a new purpose);
By virtue of COFINIMMO's legitimate interest in the proper conduct of its business:
- in the context of an actual or potential dispute, in which case COFINIMMO will keep your information until the end of the dispute or the end of the limitation period;
- to ensure the proper management of the rented property;
- to promote its services to the Tenant (information operations or promotion of COFINIMMO's services on paper and by electronic means) or to the public, as long as the Tenant does not object;
- for security reasons (security of the Tenant and of the rented property): video-audio-surveillance in the vicinity of the rented premises. These data will be deleted within the applicable legal timeframe, unless they are to be used as evidence;
- in order to manage its real estate assets, and in particular to be able to provide relevant information to potential Purchasers in compliance with the principle of minimization and subject to possible confidentiality guarantees;
Legal basis
The processing of these data is necessary for the performance of the rental contract concluded between the Tenant and COFINIMMO.
Recipients of the data
The strictly necessary data can be communicated to the following third parties:
- tax authorities;
- accountants, auditors;
- real estate expert;
- counsel and/or bailiff in the event of judicial recovery;
- COFINIMMO's subcontractors (in order to allow technical intervention in the rented premises, for example);
- IT service providers (the subcontractors in charge of the IT infrastructure, of the management program could access the Tenant's data to the extent strictly necessary for the execution of their respective missions);
- other occupants of the building, if necessary;
- third parties (co-contractors, notaries, banks) in the context of real estate transactions, including the examination of their feasibility;
- to the seller or potential buyer of the company or assets which COFINIMMO is considering selling or acquiring or in the event of a planned merger or acquisition. Indeed, COFINIMMO may share this personal data with a potential buyer by giving them access to “Data Rooms”. This is necessary for the preparation of the real estate transaction.
Duration of the processing
Data is kept as long as necessary to comply with legal or regulatory obligations (e.g., until the expiration of tax and accounting obligations).
Otherwise, the data is kept until the end of the contractual liability period, i.e. 10 years after the end of the lease contract.
- The processing of the data of visitors of COFINIMMO’s premises
Categories of Data
In order to control access to its premises, COFINIMMO asks its visitors to identify themselves by completing a register at the reception desk.
The collected data are first and last name, the company to which the visitor belongs if applicable, email, the person with whom the visitor has an appointment at COFINIMMO, the postal code of origin, the main means of transport, time of arrival and departure, signature, photos/videos taken by surveillance cameras.
Purpose of the processing
Your personal data is processed by COFINIMMO for and to the extent necessary for the following purposes:
- To ensure the safety of COFINIMMO's staff and persons accessing COFINIMMO's premises (including for the purpose of communicating to the emergency services in the event of an emergency and/or evacuation);
- To ensure the integrity and security of COFINIMMO's property and premises and to prevent unlawful intrusion (or attempted intrusion); and
- To contact you if there is a risk that you may have come into contact with a person infected with the COVID-19 virus during your visit to COFINIMMO’s premises.
Legal basis
The collection and processing of this personal data is based on the legitimate interest of COFINIMMO to be able to ensure the security of its premises and the persons present there (Article 6.1, f) of the GDPR).
The processing related to the COVID-19 virus is based on your explicit consent (Article 9.2.a of the GDPR) that you can withdraw at any moment.
Recipients of the data
Your personal data will not be passed on to third parties other than COFINIMMO staff or the competent authorities, who will process the personal data passed on solely for the purposes mentioned above.
Duration of the processing
Your personal data will be kept for as long as necessary for the above-mentioned purposes and for a maximum of 1 month.
Data relating to the "COVID-19" processing will be retained for 15 days.
Data relating to photos/videos taken by surveillance cameras will be retained for 30 days.
- The processing of the data of COFINIMMO’s data processors
Categories of Data
COFINIMMO processes personal data of data processors (surname, first name, image, occupation, domicile or residence, telephone and fax number, e-mail, date and place of birth, civil status, bank account number, languages and areas of specialization, diplomas and academic or professional qualifications, including, where necessary and to the extent necessary for the management of the insurance policies subscribed for the subcontractor, sensitive and health-related data).
Purpose of the processing
- to enable payment of the services of the Processor and to manage any issue or conflict;
- to enable customers and other Controller’s personnel to contact the Processor by telephone or email;
- to inform customers about the Processors assigned to tasks affecting them;
- for the management of insurance policies which may have been concluded for the benefit of the Processor or its employees, which implies the communication of personal data to third parties, namely the insurance companies concerned;
- for security reasons;
- for intern monitoring and reporting;
- for direct marketing;
- to ask the Processor’s consent on a new purpose.
Legal basis
The provision of those personal data is a requirement necessary to enter into the data processing agreement compliant with the GDPR and allows for the performance of such agreement. Failure to provide such data would prevent the conclusion of the contracts.
Recipients of the data
The data strictly necessary for each of the purposes listed below may be disclosed to the following third parties:
- the group COFINNIMO, which includes the Controller, for monitoring and reporting;
- BPOST to enable improved delivery of our mail;
- one or more insurance companies in case of insurance policies concluded for the benefit of the Processor or its employees;
- tax administration and social security instances, our social secretariat and our accountant.
Duration of the processing
The personal data shall be stored for 10 years after the end of the contract.
- The processing of the data of other COFINIMMO’s contractants or potential contractants (COFINIMMO’s building’s purchaser, SubProcessors, other suppliers of goods and services for COFINIMMO).
Categories of Data
COFINIMMO processes Identification, contact and financial data of its contractant ( surname, first name, ECB/VAT number, image, domicile or residence, telephone numbers (fixed or mobile), e-mail address, date and place of birth, national register number, bank account, proof of bank guarantee, possible rental arrears, correspondence, data relating to access badges, number plate in the event of renting a parking space, etc.).
Purpose of the processing
Those data are used to enable the execution of the contract and to invoice your/our services or to notify you of a change to the Contract or the Data Protection Policy (including new purposes).
Legal basis
This data is therefore essential for the performance of the contract. Without it, we cannot carry out our mission.
Recipients of the data
They are transmitted to the tax and social administrations, as well as to our accountant.
They could be transmitted to our council or to a bailiff in case of judicial recovery.
The data can also be transmitted to a (potential) buyer of COFINIMMO’s buildings in order to manage its real estate assets, and in particular to be able to provide relevant information to the (potential) Purchasers.
Duration of the processing
The data are kept for 10 years after the end of our mission, mainly for tax and accounting reasons, but also for liability reasons.
- The processing of the data of potential future tenants or purchaser of COFINIMMO’s buildings
Categories of data
This can include your identification data, contact data, financial and banking data (in particular surname, first name, ECB/VAT number, image, domicile or residence, telephone numbers (fixed or mobile), e-mail address, date and place of birth, national register number, bank account, proof of bank guarantee, possible rental arrears, correspondence, data relating to access badges, number plate in the event of renting a parking space, etc.).
Purpose of the processing
When you express your interest for a property owned by COFINIMMO, either as a potential tenant or as a potential buyer, it is necessary for COFINIMMO to process your data in order to be able to discuss this opportunity with you, negotiate and answer your questions. Your data is then processed at your request in order to evaluate the possibility of a contractual relationship between you and COFINIMMO.
Legal basis
The processing of that information is necessary in order to take steps at the request of the data subject prior to entering into a contract (a potential lease or sale agreement).
Recipients of the data
This data could be transmitted to COFINIMMO’s legal services if necessary.
The data about potential tenants can also be shared with the seller or potential buyer of the company or assets which COFINIMMO is considering selling or acquiring or in the event of a planned merger or acquisition.
Duration
The data you provide to us as part of an application will be deleted within 6 months of the end of the negotiation process.
- Data localisation
We may transfer your information to a destination outside the European Economic Area (the EEA), if that is appropriate (i) to achieve any of the purposes set out under section 3 and/or (ii) to disclose your information to a third party in accordance with section 5 of this Privacy Notice.
If we transfer your information outside of the EEA, we will make sure that the following safeguards protect your information:
- The laws of the country to which your information is transferred ensure an adequate level of data protection (Article 45 GDPR); or
- The transfer is subject to data protection clauses approved by the European Commission (Article 46.2 GDPR) and necessary supplementary measures;
- The transfer is based on Binding Corporate Rules (Article 47 GDPR); an approved Code of Conduct (Article 40 GDPR); an approved certification mechanism (Article 42 GDPR); an approved data transfer agreement (Article 46.3 GDPR); data protection clauses adopted by the Belgian data protection authority (Article 46.2 GDPR).
If you wish to receive more information relating to the transfers of your information and/or the safeguards that have been implemented (including on how to receive a copy thereof), you can contact us through the contact details set out in section " 8. Complaints" below.
- Your rights
You have certain rights regarding the information we hold about you. These rights can be exercised by contacting us as set out below:
- Information – This right is exercised through this document. If the data processed includes the data of your staff, you are responsible for making them aware of this document.
- Access - You have the right to access the information we keep about you – this is because we want you to be aware of the information we have about you and to enable you to verify whether we process your information in accordance with the applicable data protection laws and regulations;
- Opposition - You have the right, under certain circumstances, to block or suppress further use of your information. When the processing is restricted, we can still store your information, but we can no longer use it;
- Limitation - You have the right to obtain the limitation of the processing of data when you dispute the accuracy of the data; when the processing is unlawful; when Cofinimmo no longer needs the personal data but they are still necessary for the exercise of your legal rights.
- Rectification - If your information is inaccurate or incomplete, you have the right to request the rectification of your information;
- Erasure - You have the right, under certain circumstances, to request the deletion or removal of your information from our systems;
- Complaint - You have the right to lodge a complaint about the way we handle or process your information with your national data protection authority;
- Withdrawing your consent - If our processing of your personal information is based specifically on your consent, you have the right to withdraw that consent at any time. This includes your right to withdraw consent to our use of your information for direct marketing purposes;
- Portability - You have the right to obtain from us, under certain circumstances, your information in a structured, commonly used and machine readable form so you can reuse it for your own purposes across different services. For example: if you want to work with a different service provider, this enables you to move your information easily and in a secure manner to this new service provider.
You also have the right to object to certain types of processing, including processing for direct marketing purposes.
However, note that we may need to retain certain information, for example for legal or administrative purposes (e.g. keeping of accounting records).
For all requests set out above, please send an email to privacy@cofinimmo.be with “data privacy request” in the subject line and include a proof of your identity to help us prevent unauthorized individuals from accessing, changing or deleting your information. 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 keep you informed.
- Security of collected information
We have implemented a number of security features throughout our Website in order to prevent the unauthorised release of or access to collected and/or received information. We have endeavored to create a secure and reliable Website for you, but note that the confidentiality of any communication or material transmitted to or from us or any other party via our Website 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. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- External Websites
Our Website may, from time to time, contain links to and from Websites and/or applications of our partner networks, advertisers and affiliates. To the extent that hyperlinks or banner advertisements incorporating hyperlinks are used to access third party Websites and/or applications, you should be aware that these third party Websites and/or applications are not controlled by us and have their own privacy policies. Therefore, they are not subject to this Privacy Notice and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these Websites and/or applications.
- Agreement with collection and use of your information – changes to our Privacy Notice
By using this Website, you acknowledge that you have read the terms of this Privacy Notice and that you agree with the collection and the use of your information as set out above.
We may amend this Privacy Notice from time to time. Any changes we make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to the Privacy Notice. Your continued use of this Website following the posting of changes to this Privacy Notice will indicate your acceptance of these changes. This Privacy Notice was most recently updated on June 5, 2023.
- Complaints
Questions, comments and requests regarding the Privacy Notice have to be addressed to COFINIMMO – Privacy Team – Avenue de Tervueren/Tervurenlaan 270 | 1150 Brussels | Belgium – privacy@cofinimmo.be.
If you would like more information, or if you wish to lodge a complaint, you can contact the Data Protection Authority (Rue de la Presse, 35 - 1000 Brussels, Tel. + 32 2 274 48 00 - contact@apd-gba.be
https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).