Privacy Policy

This Policy is developed by Latour & Petit, the company that publishes the website https://latouretpetit.be (hereinafter the “website“), whose registered office is at Boulevard de la Woluwe 62/3 – 1200 Woluwe-Saint-Lambert under company number BE0475.331.474 (hereinafter referred to as “Latour & Petit”).

Latour & Petit (in the text, “we“, “our” or possibly “ours“) offers various services in the real estate field: valuation, sale, rental, new property, serviced residences, investment and rental management.

In the course of our activities we may process the personal data of our customers, of individuals, or of any natural person who comes into contact with us, including potential clients (hereinafter referred to as “prospects”).

The purpose of this Policy is to explain how we collect, use and store your personal data.

Data protection and the respect of your privacy are very important values to us and we are committed to processing and protecting your personal data in a fair and transparent manner in accordance with the law.

By “personal data” we mean all personal data about you, i.e. any information that allows you to be identified, directly or indirectly, as a natural person.

This Policy reflects our desire to act transparently, in compliance with the law of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter referred to as the “Privacy Act”), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data repealing Directive 95/46/EC (hereinafter referred to as the “General Data Protection Regulation”)

If you wish to provide feedback on any of the practices described below, please do not hesitate to contact us.

II. What categories of personal data do we process and how do we obtain it?

Categories	Examples	Context & Collection methods
Personal identification data	Surname, first name, date of birth, gender, address, national register numbers, etc.	On our website, this data is collected when filling in the contact form, via the “Contact us” tab, and the registration form, when the user wishes to schedule a visit, via the “Would you like to visit?” tab, and also when the user wishes to get more details on a property, via the “See more details” tab. This data may also be collected when establishing contact via letters, emails, communication to prospective buyers, tenants and sellers, when sending and receiving information that relates to renting, buying or selling of a property. It may also be collected during sales prospecting (promotional emails, newsletters, etc.). This data is also collected through agreements, offer documents between sellers and buyers, as well as through documents for prospective tenants.
Electronic identification data	Telephone number, email, IP addresses, etc.	On our website, some of this information is collected when filling in the contact form, via the “Contact us” tab, and the registration form, when the user wishes to schedule a visit, via the “Would you like to visit?” tab, and also when the user wishes to get more details on a property, via the “See more details” tab. It may also be collected during sales prospecting (promotional emails, newsletters, etc.). Other information is collected via cookies to ensure a better user experience. Some of this data is also collected through agreements, offer documents between sellers and buyers, as well as through documents for prospective tenants.
Search criteria data	Purpose of the search, category of property sought, number of rooms, postal codes, price range, other features (terrace, garden, garage/parking, furnished).	On our website, this data is collected when filling in the registration form. It may also be collected during sales prospecting (promotional emails, newsletters, etc.). This data may also be collected when establishing contact via letters, emails, communication to prospective buyers, tenants and sellers, when sending and receiving information that relates to renting, buying or selling of a property.
Data on the dwelling characteristics	Type of dwelling, own or rented property, length of stay at this address, rent, charges etc.	This data is collected when establishing contact via letters, emails, communication to prospective buyers, tenants and sellers, when sending and receiving information that relates to renting, buying or selling of a property. This data is collected through agreements, offer documents between sellers and buyers, as well as through documents for prospective tenants.
Lifestyle data	Consumption details of goods or services, behaviour of the individual or of his/her family, household composition, etc.	On our website, this data may be collected when filling in the registration form. It may also be collected during sales prospecting (promotional emails, newsletters, etc.).
Financial data	Bank accounts, income, total income, professional income, debts, mortgages, credit, loans, creditworthiness, etc.	This data is collected through agreements, offer documents between sellers and buyers, as well as through documents for prospective tenants.
Financial transaction data	Amounts due and paid by the person concerned, credit granted, overview of payments, rental guarantees and other guarantees, etc.	This data is collected through agreements, offer documents between sellers and buyers, as well as through documents for prospective tenants.

A. Non-personal data

We may also collect non-personal data. This data is termed non-personal because it does not allow you to be identified directly or indirectly.

It may be used for any purpose, for example, to improve our website, our products, to target our advertising or to improve our services.

III. For what purposes do we collect your data?

We collect and process your personal data for the purposes described below.

We have defined these purposes and ensure that only necessary and relevant personal data – in accordance with the data minimisation principle – are processed.

In general, we base the processing of your personal data on the following legal bases:

In order to comply with our legal obligations;
In order to take preliminary measures and to fulfil the contract between us when you use our services;
In order to achieve our legitimate interests (in which case we always take care to balance our interests with your rights and freedoms);
Finally, on the basis of your consent.

In case we have to carry out processing operations that are not yet covered by this Policy, we will contact you before using your personal data. We will contact you for the purpose of informing you about this processing operation and, if necessary, to ask for your explicit consent.

A. Compliance with our legal obligations

In some cases we have to process your personal data in order to comply with legal obligations or when collaborating with the competent authorities. In such cases, we pass on your personal data to fulfil our obligations.

B. With respect to our contractual relationship

When you use our services, a contract exists between you and us. In this context, we process personal data in order to fulfil our contractual obligations and to carry out the task that you have set for us.

In order to fulfil our contract, we process your personal data for the following purposes :

So as to establish contact as directly requested by the user;
To satisfy a direct user request to present to them properties that match their search criteria;
To provide offers and information about properties that may match the user’s search criteria;
Creation and management of client files;
To send and receive information pertaining to the rental, purchase or sale of a property;
Management of contractual documents (offers, leases, agreements, etc.).
Rental management;
Finalising offers between sellers and buyers;
Finalising mandates.

C. With respect to our legitimate interests

In some cases, it is in our legitimate interest to process your personal data.

To this end, we always strive to maintain a fair balance between needing to process your personal data and respecting your rights and freedoms, including the protection of your privacy.

Your personal data is thus processed for the following purposes:

Identification on the website;
Customisation of our services;
Sales prospecting and management of prospects (update of prospection files, organisation of promotional operations, establishing contact for marketing purposes, sending of promotional emails and newsletters, etc.);
Management of people’s opinions on goods, services or content;
Preparation of studies, models (risk, marketing and others) and statistics, using anonymisation and/or pseudonymisation techniques where possible;
Preserving the security of assets and people, fighting against fraud or attempted intrusion, abuse or other offences;
Training of our staff using real-life situations for illustrative purposes (we try as much as possible to anonymise your personal data);
Analysis of your previous searches in order to customise our service offers to suit you;
Keeping a list of customers who no longer wish to be contacted;
Improving existing services and the experience of the website’s users;
Managing your requests related to the application of your rights;
The recognition, exercise, defence and preservation of our

D. Consent

When you register on our website, we request you to become aware and to agree to our processing of your personal data in accordance with this Policy.

When you decide to add (optional) information to your profile, we will consequently process your personal data on the basis of your consent.

In the event that data is disclosed to third parties for direct marketing purposes, users will be informed beforehand so as to be able to give or withhold consent to this processing.

Please note that you have the right to withdraw your consent to the processing of personal data at any time.

IV. How long do we keep your personal data?

In general, we do not keep your personal data any longer than is necessary for the purposes for which it was collected.

With regard to the fulfilment of a contract, we do not keep your personal data for more than 10 years after the end of the contract.

With regard to sales prospecting, if the data subject does not respond to any solicitation 3 years after the last contact, then his/her information has to be deleted.

At the end of the retention period, we make every effort to ensure that the personal data has indeed been made unavailable and inaccessible.

Your rights under the GDPR

V. Access, withdrawal, rectification, erasure, portability, restriction and objection

Your rights under the regulations allow you to retain control over what we do with your personal data.

A. Right of access and copy

This right of access to the data we hold about you applies for all the purposes we have listed above.

This right allows you to ask us whether we are processing your personal data, for what purposes, the categories of data concerned, and the recipients of your data.

You can also ask us for a copy of all the personal data that we process about you.

B. Right to withdraw your consent

As long as we process your personal data on the legal basis of consent, you can always withdraw your consent.

C. Right of rectification

You also have a right of rectification allowing you to ask us, at any time, to amend information that is inaccurate, incomplete or obsolete.

D. Right to be forgotten

You can have your personal data erased when one of the following grounds applies:

The data is no longer necessary for the purposes of the processing operation;
You withdraw your consent to the processing of your data and we base this processing operation only on the legal basis of your consent;
You object to the processing;
We have processed your personal data unlawfully;
If the data we hold is incomplete, inaccurate or obsolete;
We have to erase your personal data in order to comply with a legal obligation (under EU or Member State law) to which we are subject.

E. Right to portability

If we process your personal data on the basis of a contract or of your consent, you can ask us to transfer all your personal data to you or to another data controller.

F. Right to restrict processing

In some cases, you can also ask us to restrict the processing of your personal data.

The situations in which you can ask us to restrict the processing of your personal data are as follows:

Where you have disputed the accuracy of some personal data, while we verify the accuracy of that data;
If we are processing your personal data unlawfully and you would prefer us to restrict such processing rather than delete your personal data.

Obviously, as soon as the restriction of processing no longer applies, we will inform you.

G. Right to object

Where your data is being processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for this purpose.

H. Profiling and automated processing

In order to provide you with a better experience, we use the profiling technique in order to match some of your preferences or interests. Wherever possible, we will only use anonymised or pseudonymised data.

Profiling, within the meaning of the GDPR, is any form of automated processing of personal data in which the data is used to assess certain personal aspects relating to a natural person, including analysing or predicting factors pertaining to that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement.

Where we use your personal data to match some of your preferences, we ensure that no decisions are taken which may have a legal effect or which may significantly affect you in a similar manner.

If you feel that you are being subjected to a decision based solely on an automated process, you can, of course, object to this.

VI. How to exercise your rights ?

A. Identification

In order to help you enforce your rights, we need to verify that your request does indeed pertain to your personal data.

To this end, we will verify your identity by sending you a unique link by email allowing us to confirm your identity.

B. When do we get back to you?

We undertake to get back to you as soon as possible and, at the latest, within one month of your request.

We may have to extend this period to two months if your request is complex and we are dealing with a large number of requests. Should such a situation arise, we will inform you of the reasons for the delay.

General information

VII. Transfer to third parties

In some cases, we transfer your personal data to other third parties.

A. Subcontractor

To enable you to access, improve and use the website, we work with subcontractors who may have access to your personal data.

Where this is the case, we ask them to comply with the legal and regulatory provisions in force, just as we do. In addition, we also ensure that they comply with this Policy.

B. Our partners

If you give us your consent to do so, we will pass on your personal data to our carefully selected partners.

C. Transmission due to a legal obligation or by order of a competent authority

As already explained, we may in some cases need to pass on your personal data in order to comply with a legal obligation, a court order or a request from a competent authority.

VIII. Security

We implement appropriate technical and organisational measures to ensure an adequate level of security during the processing of your personal data. This level of security is determined on the basis of the risks presented by the processing operation and the nature of the data to be protected.

We have put in place appropriate security measures to protect your personal data, including against loss, theft, misuse or alteration of the information received, disclosure or unauthorised use of your personal data.

In the unlikely and unfortunate event that your personal data under our control is compromised as a result of an information security breach, we undertake to act promptly to identify the cause of the breach and take appropriate remedial action.

If necessary and in accordance with the applicable law, we will inform you of this incident.

IX. Claims and complaints

If you wish to provide feedback on any of the practices described in this Policy, please contact us directly so that we may see how we can help you.

You can also lodge a complaint with the Data Protection Authority at the following address:

Data Protection Authority
Rue de la Presse, 35
1000 Brussels
Tél. + 32 2 274 48 00
Fax. + 32 2 274 48 35
contact@apd-gba.be

In addition, you can always lodge a complaint with the Brussels Court of First Instance.

For more information on complaints and possible remedies, please check out the information on the Data Protection Authority’s website: https://www.autoriteprotectiondonnees.be.

X. How to contact us?

If you have any questions and/or complaints about this Policy, please do not hesitate to contact us.

privacy@latouretpetit.be
https://latouretpetit.be
Avenue Paul Hymans 83 / A01, 1200 Woluwe-Saint-Lambert

XI. Amendments

We reserve the right to amend the provisions of this Policy at any time. We will publish the amendments directly on our website.

XII. Applicable law and jurisdiction

This Policy is governed by Belgian law.

Any dispute relating to the interpretation or execution of this Policy will be subject to Belgian law and will fall under the exclusive jurisdiction of the French-speaking courts of the judicial district of Brussels.

This version of the Policy comes into effect and has been updated as of DATE