Privacy policy
This is an English translation for your convenience. In case of any discrepancy, the Dutch version prevails.
I. Introduction
This privacy policy explains how Immo Jan Stas handles the personal data of its clients who are natural persons, and of all other natural persons who are in contact with Immo Jan Stas (hereinafter referred to as 'you').
Personal data means any information that allows you to be identified, directly or indirectly, as a natural person.
Immo Jan Stas attaches great importance to the protection of your personal data and fully respects your privacy. Immo Jan Stas therefore processes and protects your personal data in a lawful, fair and transparent manner.
When processing your personal data, Immo Jan Stas naturally complies with the law, currently the Belgian Act of 8 December 1992 and, since 25 May 2018, European Regulation (EU) 2016/679 of 27 April 2016 on data protection (better known as the 'GDPR'), or any other legislative act amending it.
More information on the protection of personal data can be obtained from the Belgian Commission for the Protection of Privacy, known since 25 May 2018 as the Data Protection Authority (Gegevensbeschermingsautoriteit).
We invite you to read this statement carefully so that you know and understand the policy of Immo Jan Stas in this area.
This statement is updated regularly. The most recent version is available on our website. We will inform you through our usual communication channels if any significant changes are made.
II. Who is the data controller?
Immo Jan Stas, with its registered office at Jan Stasstraat 3, 3000 Leuven, is the controller of your data.
Immo Jan Stas is therefore your point of contact and is accountable to the Data Protection Authority for the processing of your personal data. Immo Jan Stas determines the purposes for which your personal data are processed, as well as the means used and the characteristics of the processing.
Immo Jan Stas may engage specialised service providers to process your personal data on behalf of Immo Jan Stas and in accordance with its instructions, in line with this privacy policy. Only personal data that are strictly necessary will be passed on to these service providers (hereinafter the 'processors of Immo Jan Stas').
For any questions relating to the protection of your privacy, you may contact the managing director by sending an e-mail to info@immojanstas.be.
III. Which categories of personal data does Immo Jan Stas process?
Below is an overview of the categories of personal data that Immo Jan Stas may process. Other data may also be processed where necessary or useful for the continuation of the contractual relationship with Immo Jan Stas.
The table also indicates the context in which Immo Jan Stas obtains or processes these data. It should be read together with the description of the purposes for which Immo Jan Stas processes the data.
| Category | Examples | Context |
|---|---|---|
| 1/ Identification data of the client/principal (seller or landlord); 2/ Identification data of prospective buyers or tenants | Name, address, place and date of birth, nationality, landline or mobile telephone number and e-mail address. | These data are provided by you and processed when you request information, become a client, conclude a brokerage agreement or register to use the services of Immo Jan Stas (online), for any identification or use. These data may be obtained, among other ways, by reading your identity card. |
| Data relating to the property of the client/principal (seller or landlord) | Title deed, planning information extract, soil certificate, electrical installation inspection certificate, EPC certificate, information on flood risk, post-intervention file, information on heritage value. | These data are provided by you, or requested on your behalf by Immo Jan Stas from the authorities or technical experts. |
| Data of prospective tenants relating to a proposed lease | Information on occupation and employment, creditworthiness, family situation, salary, etc. | These data are collected by means of forms and contracts that you complete at your request. |
| Additional data for concluding a lease or a private sale agreement | National register number | These data are provided by you. The national register number is only used in cases provided for or required by law. |
| Data of co-owners (or their tenants) | Name, address, place and date of birth, nationality, landline or mobile telephone number and e-mail address. | These data are provided by you as a co-owner to Immo Jan Stas when Immo Jan Stas acts as property manager (syndic). |
| Data relating to the performance of property management (syndic) services | Payment transactions, including names and account numbers, communications and references, card numbers, etc. | These data relate to your transactions as a co-owner that are coordinated by the property manager (syndic). |
| Data on the dealings of Immo Jan Stas with you | Information relating to your contacts with Immo Jan Stas by telephone, e-mail, fax, etc. and your interactions on web pages concerning Immo Jan Stas, its services or its partners, on social networks, etc. | These data originate from contacts of any kind between you and Immo Jan Stas (at meetings or events, newsletter subscriptions, social networks, etc.). |
| Data on the behaviour and preferences of the client | Information on your behaviour and preferences regarding the use of communication and relationship channels, information on your personal choices and lifestyle, private or professional projects, hobbies, etc. | These data result from choices you have expressed or analyses carried out by Immo Jan Stas in accordance with this statement and its legal obligations. |
Immo Jan Stas does not process data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sex life or sexual orientation, genetic data or biometric data.
IV. For what purposes does Immo Jan Stas process your personal data?
Immo Jan Stas collects and processes your personal data solely for the purposes described below. Immo Jan Stas ensures that only the data necessary and relevant for a given purpose are processed.
Immo Jan Stas processes your data in the situations permitted by law, in particular:
- To comply with the legal obligations incumbent on Immo Jan Stas (see 'Legal obligations' below).
- To perform a contract with you or to take certain steps at your request prior to entering into that contract (see 'Contractual relationship between Immo Jan Stas and you as a client' below).
- For the purposes of the legitimate interests of Immo Jan Stas, where those interests are balanced against your fundamental rights and freedoms (see 'Legitimate interests of Immo Jan Stas' below).
- In specific cases, with your consent, following a specific and unambiguous request preceded by clear and understandable information; you may withdraw this consent at any time in accordance with the law (see 'Specific legitimate interest of Immo Jan Stas: direct marketing purposes' below).
Legal obligations
Immo Jan Stas must comply with legislation that, in specific circumstances, requires it to process your personal data in the course of its activities. These obligations may require Immo Jan Stas to cooperate with the competent authorities and/or third parties and, where applicable, to pass on certain of your personal data to them.
These include, among others:
- The obligation to contribute to the prevention of money laundering and terrorist financing.
- The obligations imposed on a property manager (syndic) regarding the management of jointly owned buildings.
- The obligation to respond to a formal request from the Belgian tax and judicial authorities.
The list of legal obligations for which Immo Jan Stas must process your data is not exhaustive and is subject to change.
Contractual relationship between Immo Jan Stas and you as a client
Before entering into contracts, Immo Jan Stas sometimes needs to obtain and process certain data, in particular in order to:
- Respond to your request.
- Assist you in providing information and in concluding the contract.
- Follow up a request, assess suitability and evaluate the risks relating to a possible contract.
- Carry out your brokerage assignment.
In the context of ongoing contracts or contract management, Immo Jan Stas needs to process certain data, in particular to comply with administrative and accounting obligations.
In this context, your data may be transferred internally within Immo Jan Stas to various departments, including those not directly responsible for the relationship with you or for the performance of a particular contract.
More specifically, Immo Jan Stas processes your data in performing contracts as follows:
- Management of ongoing contracts/services ordered.
- Central management and overall view of clients.
- Management of your property.
- Management of the jointly owned building in which you are a co-owner.
Immo Jan Stas may process your personal data for additional purposes in the context of its relationship with you and the performance of contracts.
Legitimate interests of Immo Jan Stas
Immo Jan Stas also processes your data in pursuit of its legitimate interests. In doing so, Immo Jan Stas seeks to strike a fair balance between the need to process data and respect for your rights and freedoms, including the protection of your privacy.
Personal data are processed, among other things, for:
- Personalising the services of Immo Jan Stas.
- Improving the quality of the service provided to you through: (a) evaluating and improving processes, including campaigns, simulations and sales, by various means such as statistical analysis, satisfaction surveys and various other research methods; (b) improving existing products of Immo Jan Stas (or products under development), based on surveys among clients of Immo Jan Stas, statistics, tests and client feedback via social networks (Twitter, Facebook) linked to Immo Jan Stas.
- Monitoring the activities of Immo Jan Stas, including turnover, the number of appointments in our offices, the number of calls and visits to the Immo Jan Stas website, the nature of questions asked by clients, etc.
- Preparing studies and statistics, using anonymisation and pseudonymisation of the persons concerned.
- Training our staff through the use of practical examples by way of illustration, including the recording of certain telephone conversations.
- Using cookies to ensure the operation of its website. More information on how cookies work and on the options to restrict and delete them can be found under IX. Cookie policy.
- Retaining evidence (archives).
- Establishing, exercising, defending and preserving the rights of Immo Jan Stas or of any persons it represents, for example in debt collection proceedings or disputes.
Specific legitimate interest of Immo Jan Stas: direct marketing purposes
Immo Jan Stas carries out client segmentation (in particular according to your needs) in order, for example, to offer you suitable properties and/or services that match your professional and personal situation. To this end, Immo Jan Stas may, among other things:
- Assess the services you already use and your socio-demographic data (age, household composition, income, etc.).
- Analyse your behaviour across various channels (visits/meetings, e-mails, visits to the website, messages via our website), infer your preferences and thereby personalise the information and web pages you have visited.
- Adapt the advertisements on web pages to match the interest you have shown through your behaviour on our website, on social networks, in an office or elsewhere (e.g. at events attended by Immo Jan Stas).
- Simplify the completion of forms by pre-filling certain fields with data already known and asking you to verify the accuracy of these data and update them where necessary.
- Assess the key moments at which certain services would suit you best.
- Send you personalised advertising by post or telephone.
Immo Jan Stas may process your personal electronic contact details (namely your mobile telephone number and e-mail address) in order to send you personal information, advertisements or proposals by direct marketing or newsletters. In this case, Immo Jan Stas must first ask for your specific consent.
By accepting this privacy policy, you consent to the processing of your personal data for direct marketing purposes.
V. With whom does Immo Jan Stas share your personal data?
Immo Jan Stas treats your personal data with the utmost care and only shares your data in order to offer you the best possible services in carrying out its assignment.
Immo Jan Stas may transfer your data to other entities within its group in Belgium and abroad, in particular to the other group entities that assist Immo Jan Stas in performing, managing and monitoring its activities, including reporting, support and IT security, or in offering specific services and products.
In some cases, Immo Jan Stas is required by law to share your data with third parties, including:
- Public authorities or supervisory authorities, where there is a legal obligation to disclose information.
- Judicial investigating authorities, at their express request.
Immo Jan Stas also transfers your data to specific service providers to assist with:
- Designing and maintaining IT equipment and internet applications.
- Providing advertising and communication services, including online and social network providers.
- Preparing reports and statistics, printing documents and designing products or services.
- Marketing its activities, organising events and managing client communications.
Immo Jan Stas must also pass on your data to online and social network providers that Immo Jan Stas uses to provide advertising services.
Your personal data may also be disclosed to bailiffs or lawyers in the context of legal proceedings.
In the cases mentioned above, Immo Jan Stas ensures that third parties only have limited access to the personal data needed to carry out the specific tasks required. Immo Jan Stas will also ensure that third parties undertake to use the personal data securely and confidentially, and in accordance with the instructions of Immo Jan Stas and its data protection policy.
Immo Jan Stas stores your personal data within the EEA. Consequently, no data are transferred to countries outside the EEA.
VI. How long are your personal data kept?
Immo Jan Stas will not keep your personal data for longer than is necessary to achieve the purposes for which they were collected.
This period is linked to the legal and tax obligations of Immo Jan Stas, as well as the legal need to retain your data beyond the retention period as evidence or to respond to requests for information from the competent authority, for example:
- 10 years under anti-money laundering legislation.
- 10 years in connection with the contractual liability of Immo Jan Stas.
- 7 years for the accounts and supporting documents of associations of co-owners in connection with the performance of the role of property manager (syndic).
After these periods, your personal data are deleted or anonymised.
VII. How are your personal data protected?
Immo Jan Stas applies strict standards to protect the personal data under its control against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Immo Jan Stas therefore takes technical and organisational measures such as encryption, antivirus software, firewalls, access controls and strict selection of staff and suppliers, in order to prevent and detect inappropriate access to, loss or disclosure of your personal data.
In the unlikely and unfortunate event that your personal data under the control of Immo Jan Stas are compromised by an information security breach, Immo Jan Stas will act immediately to identify the cause of the breach and take appropriate remedial action. Where necessary, Immo Jan Stas will notify you of the incident in accordance with the applicable legislation.
VIII. What are your rights regarding the processing of your personal data?
Right of access, rectification, restriction, erasure, data portability and objection
For the purposes mentioned above, you have:
- A right of access to your personal data held by Immo Jan Stas. This means that you may ask Immo Jan Stas whether it processes your personal data, for what purposes, which categories of data are processed and to whom they are disclosed.
- A right to rectification if you find that your personal data are inaccurate or incomplete.
- A right to restriction, for example if you contest the accuracy of your personal data, for a period enabling Immo Jan Stas to verify this.
- A right to erasure of your personal data. When your contract with Immo Jan Stas has ended, you may ask Immo Jan Stas to erase your personal data if they are no longer necessary for the purposes for which they were collected. You may also at any time request the erasure of personal data processed by Immo Jan Stas on the basis of your consent (unless Immo Jan Stas has another legal ground for the processing) or on the basis of the legitimate interest of Immo Jan Stas (unless there are overriding compelling legitimate grounds for the processing). In any event, Immo Jan Stas may retain these personal data where this is required as evidence in the context of legal claims.
- A right to portability of the data you have provided to Immo Jan Stas, where your personal data are processed on the basis of a contract or of your consent to receive electronic communications, and these personal data are processed by automated means. Under this right, you may ask Immo Jan Stas to send your personal data to you or directly to another controller, insofar as this is technically feasible for Immo Jan Stas.
- A right to object to the processing of your data for the purposes listed under 'Legitimate interests of Immo Jan Stas'. In that case, Immo Jan Stas will stop processing your personal data, unless Immo Jan Stas demonstrates compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.
- A right to object to direct marketing. Under 'Specific legitimate interest of Immo Jan Stas: direct marketing purposes', your consent was requested to process and use your electronic contact details to send you commercial information, advertising or personal proposals (through direct marketing campaigns or electronic newsletters). This applies in particular to communications to your mobile telephone number and e-mail address. You have the right to object to the processing of your personal data for electronic direct marketing and to refuse to receive such advertising in the future. However, exercising this right to object does not prevent Immo Jan Stas from contacting you for any other purpose, including a legal obligation or the performance of the contract, in accordance with this statement.
Right to lodge a complaint
You may exercise your rights by sending a dated and signed written request by post, enclosing a copy of your identity document, to Immo Jan Stas, Jan Stasstraat 3, 3000 Leuven, or by e-mail to info@immojanstas.be.
You may also lodge a complaint with the Commission for the Protection of Privacy, by post at Drukpersstraat 15, 1000 Brussels, by e-mail at commission@privacycommission.be, or by telephone on +32 2 274 48 00.
IX. Cookie policy
When you visit a website or use an application or app of Immo Jan Stas, files and technologies may be used that store information on your terminal equipment (PC, laptop, smartphone, tablet, etc.) or that access information already stored on your terminal equipment. These files and technologies may include cookies, web beacons, log files, settings and information on your terminal equipment, and the like.
The Immo Jan Stas website only uses the following cookie:
- Strictly necessary session cookie: when you log in to the management area or the owner portal, the website sets a session cookie that is needed to keep you logged in and to secure your session. This cookie is strictly necessary for those protected areas to work and is not used for any other purpose. It is not set when you simply browse the website without logging in.
Immo Jan Stas does not use analytics cookies (such as Google Analytics), the Facebook pixel or any other tracking, advertising or third-party cookies.
To know how often a property is viewed, the website keeps an anonymous count of the number of times a property page is viewed. No cookies are used for this and no information whatsoever about the visitor is stored.
You can manage, block or delete cookies in your browser settings (for example Chrome, Firefox, Safari or Edge). If you block or delete the session cookie, you will not be able to log in to the management area or the owner portal; the rest of the website remains fully usable.