Your privacy is a priority for XPR.IMMO (hereinafter "XPR.IMMO" or "we"). We are committed to respecting the personal data of our users (hereinafter "you") and processing it in accordance with Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter "GDPR") and the Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data (hereinafter "Belgian law").
This Privacy Policy informs you about:
- The personal data we collect from you and the reasons for this collection,
- How we use your personal data,
- Your rights regarding your personal data and the means to exercise them.
Date of last modification of this Policy: [XXX] (History of modifications)
Download the latest version in PDF.
I. Who is responsible for the use of your data?
XPR.IMMO may have different roles regarding the processing of your data.
II.1. Data Controller
The controller of your personal data is the company XPR.IMMO, with registered office [XXX], registered at the CBE under number [XXX].
XPR.IMMO processes your data as a controller, for example:
(1) to create and manage your user account on the Platform;
(2) to allow you to access the services offered, use the functionalities provided by the platform (generate reports), manage your credits and track your orders and payments;
(3) to improve the quality of its services and offer you a personalized experience;
(4) to fulfill its legal and regulatory obligations, in particular regarding invoicing and accounting.
All processing carried out by XPR.IMMO as a controller are described in the section "III. Description of processing carried out by XPR.IMMO as a controller".
If you are an individual who wishes to be connected via XPR.IMMO with a real estate expert: Once you have been connected, your data will be processed by the real estate expert as a controller to carry out the missions you entrust to them.
II.2. Data Processor
XPR.IMMO may also act as a processor when it processes your personal data on behalf of and on the instructions of Users who are real estate experts.
Indeed, XPR.IMMO provides a range of tools and services to Users who are real estate experts. If an expert uses XPR.IMMO to benefit from these tools and/or services, XPR.IMMO then processes the data entered in the Platform by the expert solely as a processor.
In this case, the User real estate expert will be the controller of your data and has the obligation to inform you themselves of the processing of your data.
II. Description of processing carried out by XPR.IMMO as a controller:
III.1. Processing of data from visitors to our website and anyone who interacts with us
1) Visit to our website
You can visit our website and learn about our services without having to provide us with any personal information.
However, the use of certain cookies is necessary to navigate our website. Some cookies are essential to the functioning of the site (login, security, technical operation). Other cookies (audience analysis, personalization, targeted advertising) are only used if you have consented.
For more information on this or to configure cookie settings, please refer to our cookie policy.
2) Communicating with you
Purpose of processing: We process this data when you contact us via the contact details indicated on our website in order to communicate with you and respond to your questions.
Lawful basis: The provision of this data is necessary to be able to answer your questions and provide the requested service. This data is therefore essential for the execution of our contract or the taking of pre-contractual measures. Without it, we cannot carry out our mission.
Data processed: This is your name, first name, email address, telephone number as well as any other information you may give us during our exchanges.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
In this case, the data may be processed by our email service provider.
Retention period: Data is retained for 1 year after our last contact.
3) Sending commercial communications by XPR.IMMO:
Purpose of processing: We may use your data to inform you of our news or send you promotional offers relating to our services and user experience.
Lawful basis:
• If you do not have an account on the platform, your data is processed on the basis of your consent (Article 6.1.a GDPR). You can withdraw your consent at any time, by following the procedure indicated in point VI below.
• If you already have an account on the platform, our legitimate interest in informing you of our news, new developments and offering you that may interest you justifies the processing of your data. You can object to this processing of your data at any time, by following the procedure indicated in point VI below.
Data processed: Name, first name, email address, telephone number, communication preferences, data from marketing segmentation (e.g. language, age, address, interests)
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
In this case, your data may be processed by our email service provider.
Retention period: Your data is processed for this purpose until you ask us not to receive commercial communications or until you withdraw your consent.
4) Social media
Data categories – This may include data related to your account, data related to content sharing or communications you have with other people.
Purposes – The data you provide when visiting our pages on social media may be processed jointly by the social network and the administrator of that page for the following purposes:
• collection of certain data through cookies;
• improvement by the social network of its advertising system;
• obtaining audience statistics for the page.
This data will only be processed by the page administrator within the framework of its legitimate interest in obtaining statistics on page visitors in order to properly promote its page. Audience statistics established by the social network are only transmitted to the page administrator in anonymized form.
Recipients of data – Communication to our employees, affiliates, suppliers, external service providers or consultants may be necessary for the execution of this purpose.
Retention period - This data may be processed for as long as the page exists and you visit it.
The personal data use policies of each social network can be found by clicking on the following links:
• Meta (Facebook and Instagram),
• LinkedIn.
5) Exercise of your rights
Purposes – When you exercise the rights conferred on you by the GDPR and described in this data protection policy (right of access, rectification, etc.), we retain the data strictly necessary to prove that we have properly responded to your requests.
Legal basis – The retention of this data stems from the legal obligation imposed by Article 5.2 of the GDPR, namely the duty of accountability.
Data categories – This is your name, first name, request, evidence of measures taken by XPR.IMMO in response to the request.
Recipient of data – Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
This data may also be transmitted to the data protection authority if it requests it.
Duration - We retain your data for this purpose for as long as our liability can be engaged for failure to comply with requests, namely for a maximum period of 10 years.
III.2. Processing of data of Users - Real Estate Experts
6) Creation and management of your user account:
Purpose of processing: Your data is used to create your account on our Platform, allow you to log in, manage your preferences, ensure the security of your profile, and allow you to access the features offered by the Platform.
Your data is also used to provide you with support services, answer your questions, process your support requests and inform you of any changes to services or conditions.
Lawful basis: The processing of this data is necessary for the execution of the contract concluded between you and XPR.IMMO when you create your account on the Platform. Therefore, this data is essential for the execution of our contract. Without it, we cannot carry out our mission (Article 6.1.b GDPR)
Data processed: Name, first name, email address, password, account preferences, login logs.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
In this case, the data may be processed by our platform hosting provider.
Retention period: As long as the account is active and until it is voluntarily deleted by the user or after a period of 3 years of inactivity.
7) Management of your orders and credits:
Purpose of processing: Your data is used to process your credit purchases, track your transactions, correctly deduct the credits used and invoice you for the credits ordered. Your data is also processed in case of legal recovery or when we need to notify you of a change to the Contract or Privacy Policy (in particular in case of new purposes).
Lawful basis: The processing of this data is necessary for the execution of the contract concluded between you and XPR.IMMO when you create your account on the Platform and for billing the credits ordered (Article 6.1.b GDPR)
Data processed: Identification data (name, first name), billing details, payment data, purchase history, credit balance.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
They are transmitted to the tax and social authorities, our social secretariat and our accountant. They could also be transmitted to our counsel or a bailiff in case of legal recovery or dispute.
Retention period: This data is retained for 10 years from the end of the accounting year (legal obligations regarding accounting and taxation).
8) Generation of appraisal reports:
Purpose of processing: We process data you provide us regarding the real property subject to appraisal (identification data of the property owners, contact details, legal, financial or technical information, property photos) as a processor in order to generate the requested report.
Lawful basis: The processing of this data is necessary for the execution of the contract concluded between you and XPR.IMMO when you create your account on the Platform and use this platform to generate reports. Therefore, this data is essential for the execution of our contract. Without it, we cannot carry out our mission. (Article 6.1.b GDPR).
Data processed: name, first name, contact details, legal and financial information related to the property, photos and characteristics of the real property
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
In this case, the data may be processed by our platform hosting provider.
Retention period: The generated reports are immediately downloadable by the user. They are retained on the platform for ... or until deletion of the user's account, whichever occurs first.
9) Management of orders from individuals entrusted to you:
Purpose of processing: Your data is used to pay you for appraisals carried out via the Platform, on behalf of an individual user who ordered the appraisal via the Platform.
Lawful basis: The processing of this data is necessary for the execution of the contract concluded between you and XPR.IMMO when you create your account on the Platform and for billing the credits ordered (Article 6.1.b GDPR)
Data processed: Identification data (name, first name), billing details, payment data, assignment entrusted by the individual.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
They are transmitted to the tax and social authorities, our social secretariat and our accountant. They could also be transmitted to our counsel or a bailiff in case of legal recovery or dispute.
Retention period: This data is retained for 10 years from the end of the accounting year (legal obligations regarding accounting and taxation).
10) Service provision and improvement of services:
Purpose of processing: We use certain data (technical logs, usage preferences, etc.) to analyze platform usage statistics, ensure its proper functioning and continuously improve our services.
Lawful basis: Our legitimate interest in improving our services justifies the processing of this data (Article 6.1.f GDPR)
Data processed: Technical logs, navigation data, usage preferences, IP address, device type, performance data, survey results or user feedback.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
Retention period: This data is processed to anonymize it and present it in statistical form. Once the data is anonymized, we delete the clear data.
III.3. Processing of data of Users - Individuals
1) Creation and management of your user account:
Purpose of processing: Your data is used to create your account on our Platform, allow you to log in, manage your preferences, ensure the security of your profile, and connect you with a real estate expert who is a platform user.
Your data is also used to provide you with support services, answer your questions, process your support requests and inform you of any changes to services or conditions.
Lawful basis: The processing of this data is necessary for the execution of the contract concluded between you and XPR.IMMO when you create your account on the Platform. Therefore, this data is essential for the execution of our contract. Without it, we cannot carry out our mission (Article 6.1.b GDPR)
Data processed: Name, first name, email address, password, account preferences, login logs.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
In this case, the data may be processed by our platform hosting provider.
Once you have been connected with a real estate expert via the platform, your data will be processed by the expert as a controller.
Retention period: As long as the account is active and until it is voluntarily deleted by the user or after a period of 3 years of inactivity.
2) Management of orders and credits:
Purpose of processing: Your data is used to process your credit purchases, track your transactions, correctly deduct the credits used, invoice you for the credits ordered and pay the real estate expert who carried out the appraisal at your request. Your data is also processed in case of legal recovery or when we need to notify you of a change to the Contract or Privacy Policy (in particular in case of new purposes).
Lawful basis: The processing of this data is necessary for the execution of the contract concluded between you and XPR.IMMO when you create your account on the Platform and for billing the credits ordered (Article 6.1.b GDPR)
Data processed: Identification data (name, first name), billing details, payment data, purchase history, credit balance.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
They are transmitted to the tax and social authorities, our social secretariat and our accountant. They could also be transmitted to our counsel or a bailiff in case of dispute.
Retention period: This data is retained for 10 years from the end of the accounting year (legal obligations regarding accounting and taxation).
3) Service provision and improvement of services:
Purpose of processing: We use certain data (technical logs, usage preferences, etc.) to analyze platform usage statistics, ensure its proper functioning and continuously improve our services.
Lawful basis: Our legitimate interest in improving our services justifies the processing of this data (Article 6.1.f GDPR)
Data processed: Technical logs, navigation data, usage preferences, IP address, device type, performance data, survey results or user feedback.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors.
Retention period: This data is processed to anonymize it and present it in statistical form. Once the data is anonymized, we delete the clear data.
III.4. Processing of data of third parties in the context of providing our service
4) Harvesting and processing of public sales prices:
Purpose of processing: Data from public sales (prices, property characteristics) is collected to feed the real estate database, provide reports and analysis.
Lawful basis: The data, which comes from legally publicly accessible sources, is processed on the basis of our legitimate interest in gathering relevant data to analyze the real estate market and its trends (Article 6.1.f GDPR).
Data processed: Public real estate data (price, property address, property characteristics, cadastral information, land use, building permits, municipal building regulations or special development plan, flood zones, subsidence risk, soil pollution, ambient noise, accessibility by public transport, public parking, PMD accessibility, environment-related information (green spaces, Natura 2000 areas, protected areas), listed building, archaeological sites, connection zones, etc.).
This information concerns the real property and not natural persons related to that property (e.g. owner or occupant). XPR.IMMO does not in any way identify the owner or occupant of the properties whose sale price is analyzed.
Recipients: Your data may be communicated to our IT service providers, identified in point IV below, for the purposes strictly necessary to comply with the instructions we give them. In this case, they act solely as processors. In this case, the data may be processed by the supplier of the artificial intelligence tool used to analyze the data.
Retention period: Public data integrated into the database is retained as long as it has economic or historical interest, subject to regular updates or objection from the data subject.
III. With whom do we share your personal data?
As explained in the processing description above, we may share your personal data with IT service providers who help us provide our services from a purely technical perspective. Of course, we always do this in a way that ensures optimal protection of your personal data.
- With our processors:
In order to pursue the data use purposes in its capacity as Data Controller, XPR.IMMO entrusts certain processing tasks to third parties called "processors". These are mainly IT service providers who provide various technical services enabling XPR.IMMO to exercise its activities. Here is the list of services provided:
Processor involved in the sharing of your personal data
Location of the processor
Reason for sharing your personal data
[MFM DIGITAL]
[Belgium]
[IT Service Provider]
- With judicial authorities:
We may share your personal data with public authorities in response to legal requests, including requests related to national security or law enforcement.
- As part of a transaction:
In the context of a transaction, such as a merger, acquisition, consolidation, or sale of assets, we may be required to share your personal data with buyers or sellers.
IV. Is your personal data transferred abroad?
- Data transfer within Europe:
Some data is transferred to our processors established or having servers in the territory of the European Economic Area (the 27 EU member states, Iceland, Norway, Liechtenstein). Be aware that personal data benefits from the same level of protection despite their transfer.
- Data transfers outside Europe
XPR.IMMO does not in principle transfer your data outside the European Economic Area. Exceptionally, XPR.IMMO could use another processor outside the EU. XPR.IMMO ensures in all cases that either:
(1) the processor is established in a country presenting, according to a European Commission decision, an adequate level of personal data protection (as is the case for providers established in the United Kingdom and providers established in the United States signatories to the Privacy Framework);
(2) or at the very least that the transfer is governed by the standard contractual clauses issued by the European Commission and appropriate additional safeguards, which can be communicated upon simple request.
V. What rights do you have regarding your personal data?
We want to inform you as clearly as possible of the rights you have regarding your personal data:
Information – This right is exercised through this document. If among the data processed are the data of your staff, you warrant that they are made aware of this document.
Access and rectification – You have the right to access your data and have it corrected if necessary.
Objection – You can object to the processing of your data that we do on the basis of our legitimate interest.
Withdraw your consent – When data is processed on the basis of your consent, you can reverse this decision at any time, without calling into question past processing.
Deletion and limitation – You can obtain the deletion of your data or the limitation of processing under the conditions provided for in Articles 17 and 18 of the GDPR.
Portability – The data you have provided us can be communicated to you or transmitted to a third party of your choice in electronic format.
For more information about your rights:
https://www.autoriteprotectiondonnees.be/citizen/privacy/what-are-my-rights
VI. How do you exercise your rights?
The controller of your data, XPR.IMMO, whose registered office is located at ……………………, is at your disposal for any questions as well as for any request relating to the rights set out above.
Do not hesitate to contact us by email at [XXX], or by mail to: XPR.IMMO, [XXX], [XXX]. We would be delighted to hear from you and will be pleased to respond to you as soon as possible.
You can also file a complaint with the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 - https://www.autoriteprotectiondonnees.be/citizen/act/file-complaint ).
VII. How will you know that this Privacy Policy has been modified?
This Privacy Policy may be modified at any time, in particular to take into account any legislative or regulatory changes and the evolution of our services. Major changes will be notified via our website or by email, if possible, at least thirty days before they come into effect.
When we publish modifications to this Privacy Policy, we will revise the "last updated" date at the top of the privacy policy and describe the changes on the "Modification History" page. We encourage you to regularly consult this Privacy Policy to find out how XPR.IMMO protects your personal data.
VIII. Third-party websites
Our website may contain hyperlinks leading to third-party websites and information about them. If this is not one of our websites, we have no control over these sites and are not responsible for their privacy policies, which we invite you to consult.