Privacy Policy

We understand that your trust in us is the most important asset of Immowi International BV (hereinafter referred to as "Immowi International", "we" or "us"). Your privacy is therefore essential to us.

This privacy policy (hereinafter referred to as "Privacy Statement", "Privacy Disclaimer" or "Privacy Policy") applies, among other things, to:

• our websites https://www.immowi.com/;
• the landing pages prepared by Immowi International for the benefit of its project partners (hereinafter referred to as the "Landing Page"); and,
• all (commercial) relationships between Immowi International, its prospects, project partners (or other customers), business partners and suppliers.

This Privacy Statement contains, among other things, information about the personal data that Immowi International collects, as well as how Immowi International uses and processes these personal data.

Immowi International wishes to emphasise that it endeavours at all times to act in accordance with the "Privacy Laws", namely:

• the Belgian Privacy Act of 30 July 2018 on the protection of individuals with regard to the processing of personal data;
• EU Regulation 2016/679 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 and repealing Directive 95/46/EC; and/or,
• other privacy laws and regulations applicable to Immowi International.

Please read this Privacy Policy in conjunction with Immowi International's legal disclaimer and cookie policy.

The main activity of Immowi International, under the name Immowi.com, consists of lead generation for project partners. For this purpose she prepares Landing Pages, about the real estate projects of her project partners. The Landing Page contains more information about the property project (e.g. quantity of units, price range, type of units, etc.).

After building a Landing Page, parts (e.g. photos and/or articles) are converted into advertisements. These advertisements are placed on their website by Immowi International's marketing partners (e.g. Facebook, Google, etc.). Immowi International only sees the number of advertisements displayed on the marketing partners' websites and has no insight into the choices made by the marketing partner regarding the placement of the advertisement (e.g. where on the page).

After an advertisement is clicked on on the website of the marketing partner, the visitor will end up on the Landing Page. If, after viewing the Landing Page, the visitor is still interested in the real estate project, he/she can fill in his/her personal information in the contact form.

Sometimes certain contact details of the project partner can be found immediately on the Landing Page (e.g. the logo, the name of the project partner or the name of a contact person). In this case, the visitor may also contact the project partner directly with any questions or comments regarding privacy, as Immowi International and the project partner are jointly responsible for the visitor's collected personal data.

Immowi International will forward all fully and correctly completed contact forms to the project partner so that they can contact interested visitors to provide more information about the project, schedule a visit, etc.

In order to optimise its services in the future, Immowi will divide the personal data of interested parties into different categories (e.g. residential, industrial, luxury, etc.) depending on the type of property. This information will then be used to help (the algorithm of) the marketing partners advertise in a more targeted way in subsequent (similar) projects.

Immowi guarantees to pay special attention to the GDPR in all its forms of advertising (and/or when calling on marketing partners to advertise):

• Transparency: The fact that certain visitors to the marketing partners' websites see the advertisement (and others do not) may be a result of Immowi International's categorisation in the past. However, at no time will those involved be favoured or disadvantaged by seeing or not seeing the ad (e.g. no discounts or other benefits relating to the property).
• Data minimization: Immowi collects only a limited amount of personal data of the interested visitor.
• Restriction on further processing: Only part of the personal data of interested visitors will be used at a later date to improve Immowi's services.
• Limitation of impact: Immowi does not use the personal data of 'non-interested visitors' (visitors who do not click on the advertisement, or, who click on the advertisement but do not leave any personal data on the Landing Page).
• Purpose and limitation in time: Immowi will only use the personal data of interested visitors to optimize the service, as long as they can add value to it.

Immowi International may collect and process the following personal data in the course of its business:

• Name
• First name
• Email
• Phone (fixed and/or mobile)
• Postal code
• Available budget in euro or other currency
• Preference of the location of a real estate project or service
• Preferred property characteristics (with/without garden, number of bedrooms, etc.)
• Preferred time period before making a purchase
• Communication preference (physical appointment, telephone contact, brochure)
• IP-address
• Contact details of the contact person of a project partner/business partner
• All personal data contained in the free field of the contact form
• All other personal data voluntarily transferred to Immowi International (in the course of correspondence).

These personal data are collected at or within the framework of:

• Visiting the Websites
• Visit of the Landing Pages
• Filling in the contact form on the Websites
• A partnership with Immowi International (e.g. request a quote from a project partner, use of a service provider by Immowi International, etc.).
• Correspondence with and on behalf of Immowi International
• Subscribe to the newsletter
• Organisation of seminars on lead generation

The provision of certain personal data is a condition of benefiting from the services. This will indicate which details are mandatory and which are optional.

Immowi International may use your personal data for the following purposes:

• The execution of an agreement with the project partners (incl. invoicing and follow-up)
• Bringing parties into contact (e.g. potential buyers with real estate offices and estate agents, potential sellers with real estate offices and estate agents, etc.)
• Optimising the quality, management and content of the Websites and the Landing Pages
• Optimizing its services
• Sending direct marketing of interested visitors for another (but similar) project (retargeting purposes)
• Sending a newsletter
• Follow-up after a meeting/conference
• Confirmation of registration for a webinar or seminar
• Carrying out customer satisfaction surveys, surveys and other market surveys
• Statistical purposes

Processing shall take place on the following legal grounds, as appropriate:

• You have consented to the processing of your personal data for one or more specific purposes
• The processing is necessary for the execution of the agreement with Immowi International or to take measures at your request prior to the conclusion of an agreement
• The processing is necessary in order to comply with a legal obligation incumbent on Immowi International.
• The processing is necessary to protect your vital interests or those of another natural person.
• The processing is necessary for the performance of a task in the public interest
• The processing is necessary to protect the legitimate interests of Immowi International.

(i) The optimisation of the service towards project partners by dividing the personal data of interested visitors into categories and then using them to train the algorithms of the marketing partners in order to be able to advertise better in the future.

Immowi International maintains the balance between this legitimate interest and your interests and fundamental freedoms by limiting the impact in the following ways:

• The categories into which the interested visitors are divided are general, vague and do not contain far-reaching information about the visitor (type of real estate residential, industrial, luxury, etc.);
• The subdivision has no/little impact on the visitor, as the subdivision is not used to contact the visitor in any other way (but only to advertise better in the future);
• Immowi International will not take decisions with a legal (or similar) impact on the basis of the subdivision; and,
• Immowi International respects the principles described above; and,
• The visitor always has the option of opposing this by contacting Immowi International or filling in the exercise rights form.

(ii) To engage in retarget direct marketing. Persons who have completed the Landing Page may receive direct marketing on other but similar real estate projects.

• Direct marketing from another project partner will only be sent to interested visitors ('customers' of Immowi International);
• Direct marketing will always relate to similar projects; and,
• The visitor always has the option of opposing this by contacting Immowi International or filling in the exercise rights form.

Immowi International will disclose your personal data to third parties as necessary for the purposes set out in point IV. Your personal data may then be transferred to and/or processed by:

• Project partners (e.g. to provide them with the completed contact forms);
• Marketing partners (e.g. to improve the algorithm);
• Software/cloud providers (e.g. to support the use of Immowi International databases); and,
• Other service providers (e.g. to develop the Websites and/or the Landing Pages).

If Immowi International discloses your personal data to third parties in this context, the third party in question is obliged to use your personal data in accordance with the Privacy Laws.

Without prejudice to the foregoing, Immowi International may disclose your personal data:

• To the competent authorities (i) where Immowi International is obliged to do so by law or in the context of judicial or future legal proceedings and (ii) to safeguard and defend the rights of Immowi International.
• If Immowi International or substantially all of its assets are acquired by a third party, in which case your personal data collected by Immowi International will be one of the transferred assets.

In all other cases, Immowi International will not sell, rent or transfer your personal data to third parties, unless (i) it has obtained your consent and (ii) it has entered into a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and treatment of your personal data in accordance with privacy.

Any transfer of personal data outside the European Economic Area (EEA) to an addressee residing or domiciled in a country not covered by an adequacy decision issued by the European Commission will be governed by one or more appropriate safeguards (as approved by the EU):

• The conclusion of a data transfer agreement with the addressee, which will contain the standard contractual clauses as stipulated in the 'Decision of the European Commission of 5 February 2010 (Decision 2010/87/EC)'; and/or
• Binding operating regulations; and/or
• Certification mechanism (such as but not limited to the EU-US Privacy Shield).

Unless a longer retention period is required or justified (i) by law or (ii) by compliance with other regulations, Immowi International will only retain your personal data for the period necessary to achieve and fulfil the purposes set out in this Privacy Statement under 'IV. Use of Personal Data'.

Within the framework of the processing of your personal data, you have the following privacy rights:

• Right of access to your personal data;
• Right of rectification, completion or update of your personal data;
• Right of deletion of your personal data ('right to be forgotten');
• Right to restrict the processing of your personal data;
• Right to transfer your personal data; and,
• Right of objection/ opposition to the processing of your personal data.

In this context, Immowi International would like to point out that certain of its services can no longer be provided, in particular if you delete certain necessary personal data or wish to limit the processing of your personal data, or if you object to the processing of your personal data.

If you wish to exercise your privacy rights, please contact privacy@immowi.com or complete and email the form to exercise your privacy rights to Immowi International.

In principle you can exercise these rights free of charge using the form above.

If you no longer wish to receive newsletters about Immowi International's services, you can unsubscribe at any time by clicking on the 'unsubscribe' button as provided at the bottom of every e-mail from Immowi International.

Immowi International is committed to taking appropriate and reasonable physical, technological and organisational security measures to prevent (i) unauthorised or unlawful access to your personal data, as well as (ii) loss, misuse or alteration of your personal data.

Immowi International will keep all personal data it has collected in the cloud.

Notwithstanding (i) Immowi International's security policy, (ii) the controls it carries out and (iii) the actions it takes in this context, an infallible level of security cannot be guaranteed. No method of transmission or transmission over the Internet or any method of electronic storage is 100% secure and therefore Immowi International cannot guarantee absolute security in this context.

Immowi International may update this Privacy Statement by posting a new version on the Websites, whereby Immowi International will indicate the date of update in the footer of this Privacy Statement. It is strongly recommended that you periodically check the Websites and the relevant page on which the Privacy Statement is displayed to ensure that you are aware of any changes.

The Websites may contain hyperlinks to other websites. When you click on one of these links, you may be directed to another website or Internet resource that may knowingly or through the use of cookies or other technologies collect information about you. Immowi International has no responsibility, liability or control over these other websites or internet sources, nor their collection, use and dissemination of your personal data. You should check the privacy policies of these other websites and internet sources yourself in order to determine whether they comply with the Privacy Laws.

If you have any questions about the Privacy Statement or how Immowi International collects, uses or processes your personal data, please contact us:

By e-mail: privacy@immowi.com,

or

By post: Immowi International BV, Gaston Crommenlaan 8, 9050 Ghent, Belgium

If you are dissatisfied with the way in which Immowi International has dealt with these questions or comments or if you have any complaints about the way in which Immowi International collects, uses or processes your data, you may lodge a complaint with the Data Protection Authority.

Latest Version: May 2020