Declaration of confidentiality
1. Introduction
Preliminary remarks: We respect the privacy of our customers and visitors to our website. We therefore treat your personal data with care. Through this privacy policy, we would like to inform you of how we treat your personal data when you use this site, as well as when you use our services.
Introduction to personal data protection : Since May 25, 2018, a new European regulation determines your rights with regard to your personal data. The most important concepts of this new legislation (known as GDPR) are data subjects, personal data and processing. The data subject is you, the natural person who visits this site or uses our services. Your personal data is all the data that concerns you: it may be your name, your e-mail address, but also the fact that you contacted us via a contact form, or the contract you concluded with us. What we do with your personal data is called processing. This ranges from request, storage to use, and other various purposes.
2. Which personal data ?
Why do we process your personal data? We process your personal data in order to sell or rent your property, to find a property corresponding to your wishes and needs among the properties that we rent and sell, as well as to allow you to stay informed of properties that may be of interest to you.
On what legal basis do we process your personal data? Any use of your personal data must have a legal, “lawful” basis. We process your data on the basis of our legitimate interest, your consent, the pre-contractual phase, the execution of an agreement, and the legal obligation. We sometimes have a “legal obligation” to request personal data. For example, establishing a sales agreement requires your national register number. For certain matters, such as sending newsletters by e-mail, we ask for your consent. You can withdraw your consent at any time. This can be done easily, usually by clicking on the “unsubscribe” button that you will find in each of these emails. We also retain data based on our “legitimate interest”. This legitimate interest includes what you can expect as a client, that we deal with as estate agents in order to carry out our work properly. This concerns, for example, the establishment of lists of candidate buyers or important specific information in the context of certain properties or certain customers. Finally, we obviously need personal data to be able to perform the contract that binds us to you, such as your contact details.
What personal data do we keep about you? The personal data we keep about you depends on your relationship with us. We call this the categories of data subjects.
VISITOR: The natural person who visits the site without making themselves known and without providing personal data.
FREE SERVICES: The natural person who uses our free services (such as personalized searches, free property valuation, contact form) without signing a contract.
POTENTIAL TENANT: The potential tenant who, in the context of a specific property or as part of the search for a rental property in general, provides us with detailed information, and possibly visits one or more properties.
POTENTIAL-BUYER: The potential buyer who provides us with information in the context of a specific property or in the context of the search for a property in general, and possibly visits one or more properties.
OWNER: The owner, with whom a rental mandate is concluded.
SELLER: The seller, with whom a sales mandate is concluded.
RESIDENT: The person who resides in a property, when that person is not the owner or seller in the transaction.
PROSPECT: The natural person who contacts us or whom we contact with a view to the sale or rental of property relating to this person.
CO-OWNER: The natural or legal person, owner or having been of at least one lot in a co-ownership of which The Keys Management is or has been trustee.
We discuss below: the different categories of customers, how we process your personal data, whether you can object to this processing, and what the consequences are. Next, we look at the rights you have regarding us as a data subject.
What personal data do we process from the visitor? If you, as a visitor to our website, do not share any personal data, we will not retain any personal data. Depending on the browser settings, cookies may be placed on the user’s device. See Cookies Policy.
What personal data do we process for free services? Some of our services are completely free. In this case, we only process the data required for this service. These services include: creating a profile, saving searches, requesting a free estimation of your property, filling out a contact form, subscribing to a newsletter. When creating a profile, the following data may be requested: identification data and contact details. When saving a search, in addition to an e-mail address, the information necessary or useful for compiling the requested query is saved. A free valuation of your property requires a certain investment and it is normal that we may keep various personal data, such as property data, identification data, contact details, reason for requesting the estimate. The realisation of a free valuation implies the authorisation to collect this data. Once a valuation has been made, we retain that valuation, based on both your consent and a legitimate interest, and possible liability for, that valuation. When you complete a contact form, we save your contact details and your question or comment as well as any other communication. When you sign up for a newsletter, your email address will be saved. Except as set out above, all processing takes place within the scope of your consent. We retain this personal data for as long as the processing is ongoing and for up to 6 months or more after your last activity.
What personal data of the prospective tenant do we process? You are a potential tenant as soon as you identify yourself with us for this purpose. The following processing is possible for a potential tenant: a pre-screening allows us to complete your tenant profile. This is by no means an automated decision. We collect this information to allow you to visit properties that may meet your needs and not to visit properties that do not meet your needs. This personal data may include: your pay slip or other information on your income, your family situation, from when you want to rent, your budget, as well as all the information on the desired property. When a property is visited, we also note it. When concluding a lease, all the data necessary for the conclusion of the rental contract are collected and stored. We keep this personal data with a view to possibly concluding a lease. The legal basis for processing is therefore the pre-contractual phase. The retention period for personal data is at least 6 months, but depends on your level of activity as a prospective tenant, and can be reasonably renewed to establish a long-term profile of the tenant. If, on the basis of your reduced activity as a prospective tenant, we decide to no longer process your data, you can be informed in advance. If you sign a lease, we must keep the personal data for at least 10 years, according to our contractual liability. You have a right of access and an effective right to rectify objectively incorrect data. No particular personal data is stored (such as race, religion, sexual orientation, state of health, etc.) unless you explicitly request it.
What personal data of the potential buyer do we process? You are a potential buyer as soon as you identify yourself with us for this purpose. We process the following personal data for a potential buyer: we store your name, email address and mobile phone number. We record your wishes and needs regarding the property you are looking for, as well as any other information you provide to us regarding your situation or which we believe may be useful in finding a suitable property. If you visit a property, we record this as activity related to that property. The seller, who has access to the activity report via an online profile, sees that a visit has taken place. If you make an offer, we will keep your offer and the seller’s response. If an offer or a counter-offer is accepted, all legal data required to establish a compromise can be collected and stored (such as a copy of your identity card). The sales contract is also saved. If you have shown a serious interest in a property or if you have visited a property, and if we complete our mission without selling the property, the seller will receive a list of all potential (serious) buyers by registered mail. This list contains your name, email address, and a partially hidden phone number. We will pass your details to the seller for a compelling legitimate interest, in particular because of the contractual conditions in the mandate. This means that you cannot object to being listed. The following precautions are taken in this context: it is forbidden for the seller to contact you on the basis of this list, it is also forbidden for him to inform anyone that you are on this list, as well as to transmit this list. After 6 months, the seller is obliged to delete the list as well as any copy or scan in his possession. In addition, it is possible that we send this list to a real estate agent who takes over the mandate, or with whom we work. Apart from what has been indicated above, the processing is carried out on the basis of your consent and our legitimate interest in order to be able to offer you a better service. Your data is kept for a minimum of 2 years. If you make a firm offer, sign a promise to purchase or a sales contract, we must keep the personal data for at least 10 years for our contractual liability. By default, we keep your data for a period of 30 years, but after 10 years, you can request the erasure of your data. You have a right of access and an effective right to rectify objectively incorrect data. For this purpose, you must provide us with proof of your identity, the correct information and, where applicable, sufficient proof of this correct value. No particular personal data is stored (such as race, religion, sexual orientation, state of health, etc.) unless you explicitly request it.
What personal data of the owner do we process? As part of a rental mandate, we keep all the data necessary for the execution of the rental mandate, such as the data of the property, your identity and your contact details. We also store additional information we obtain about the property or other information useful to a tenant for your property. Please note that the GDPR prohibits the processing of any personal data relating to race, religion, sexual orientation or health status, so the other useful information that we record cannot in any way relate to such data. Personal data is kept in order to be able to execute the rental mandate. Personal data is kept for at least 10 years, taking into account the legal obligations in this area and our contractual responsibility. By default, we keep your data for a period of 30 years, but after 10 years, you can request the erasure of your data. If you entrust us with the establishment of a CPE or an electrical compliance certificate, the necessary personal data will be transmitted to our partner. If a rental contract is concluded, the data necessary for the establishment of the lease will be kept. If you decide to publish your property on one or more real estate portal sites, we will only send the details of the property to this portal site, and no other contact details or details relating to you.
What personal data of the seller do we process? As part of a sales mandate, we keep all the data necessary for the execution of this mandate, such as the data of the property, your identity and your contact details. We also keep additional information that we obtain concerning the property or other useful information for a prospective buyer of your property. Personal data is kept for at least 10 years, taking into account the legal obligations in this area and our contractual responsibility. By default, we keep your data for a period of 30 years, but after 10 years, you can request the erasure of your data. If you entrust us with obtaining an EPC or electrical compliance certificate, the necessary personal data will be transmitted to our partner. If a sales contract is reached, the data necessary to prepare the sales contract will be kept. If you decide to publish your property on one or more real estate portal sites, we will only send the details of the property to this portal site, and no other contact details or details relating to you. See below for important information on your possible responsibilities as a seller. What resident personal data do we process? As part of a sale or rental mandate, we keep all the data necessary for the execution of the mandate, including the contact details of the resident. We keep them until the end of the mandate. This data is then deleted if you have no other relationship with our agency.
What personal data of the prospect do we process? We distinguish between the prospect who contacts us and the prospect we contact. If you contact us for a possible mandate, we will keep your identity, your contact details, the information we obtain on your property and any other information allowing us to assess your property and the context or reason for your contact. We do this on the basis of a legitimate interest, in particular the efficient processing of this non-binding contact. We keep the data you give us by default for 2 years. We may also contact you if we learn that you intend to put your property up for sale or for rent. The contact details provided may be stored in accordance with the GDPR. If you wish to have further contact with us, we will process your personal data as we do for people who contact us spontaneously. If you no longer wish to be contacted by us, or only after a certain period of time (eg three months), we will consider your request.
What personal data of the co-owner do we process?
As part of a syndic mission, we keep all the data necessary for the execution of this, such as the data of the property, your identity and your contact details. We also keep additional information that we obtain concerning the property or other useful information in the context of the management of the co-ownership. Personal data is kept for at least 10 years, taking into account the legal obligations in this area and our contractual responsibility. By default, we keep your data for a period of 30 years, but after 10 years, you can request the erasure of your data. What resident personal data do we process? As part of a trustee contract, we keep all the data necessary for the execution of the mission, including the contact details of the residents. We keep them until the end of the mandate. This data is then deleted if you have no other relationship with our agency.
What if you belong to two categories of people simultaneously? It may be that over time you belong to more than one category of people involved. For example, a prospective buyer may later become a seller. In this case, your personal data will be processed according to both categories, possibly with several legal bases. The longest retention period will be retained.
What about data from third parties, such as portal sites? Properties for sale and for rent can be published on portal sites. Real estate portal sites contain criteria for searching, collecting and saving your details. With your permission, a portal site gives us your contact details and information about the property you are interested in. You will immediately receive an email from us confirming that we have received your contact details and information about the property you are interested in. This email may contain an invitation to consent to automatically receive messages from similar properties. We can also automatically send you a series of properties similar to the property for which you have requested information (many customers appreciate this service). You can always unsubscribe with one click.
Historical data. Historical data is personal data contained in our database before May 25, 2018, the date of entry into force of the GDPR. For people with whom we have a mandate or for whom we have a legal obligation to keep personal data, we will of course keep this data. For other personal data, which is stored in our database either on the basis of consent or on the basis of our legitimate interest, it is generally difficult, if not impossible, to know on what basis we store this data. A company has two ways to handle this. A first solution consists in sending to any person included in this file an e-mail asking to renew or confirm the consent to use personal data. In this case, only the personal data of those who have actually accepted will be kept. A second way is to consider the processing of personal data as a legitimate interest. In this case, the person concerned has the possibility of opposing the processing at each contact; this opposition will terminate the processing. Each of these ways of working can be combined with an operation to clean up old customer data. We opted for the second way of processing historical data. It goes without saying that you always have the right to request the deletion of this historical personal data (in the absence of legal obligations and contracts in progress).
Your responsibilities as a seller. It is possible for several reasons that the sales contract you have entrusted to us ends without the sale of your property. In this case, you will receive at the end of our mission the list of candidate buyers who have visited your property or who have expressed a serious interest. This list contains the personal data of these potential buyers, in particular the surname and first name, the e-mail address and the mobile telephone number (possibly partially masked). Even as an individual, you have obligations under the GDPR in relation to this list and are responsible for it. You are authorized to save and consult the personal data of this list for 6 months after receipt. You are not authorized to communicate this personal data to anyone or in any way, or to share it with anyone, unless you contact a real estate agent with whom you wish to work. You are also prohibited from actively seeking contact with such persons. After 6 months, you are obligated to destroy this list, along with every copy, scan and photo in your possession.
Contact. For any question or request concerning the processing of your personal data, you can contact us at the following address: The Keys srl & The Keys Management srl / Chaussée de la Hulpe, 166 in 1170 Watermael-Boitsfort / info@thekeys.be
Your rights as a data subject. As a data subject, you have a number of rights in relation to your personal data. You have a right of access to your personal data. This means that you have the right to access the personal data that we hold about you. Note that we have one month to respond to your request and that we may ask you for proof of your identity before responding to your request. You also have the right to rectification. This means that you have the right to correct incorrect personal data. In this case, we may ask you for proof of the accuracy of the data you provide. You also have a right to erasure of data. This means that you can request the deletion of your personal data. Please note that this is not always possible, especially if we have a legal obligation to retain personal data, if you have entered into a contractual relationship with us, or in other exceptional situations. The right to erasure of data cannot be used to terminate an existing contract. You can also object to certain processing, in particular processing that we carry out on the basis of our justified (non-compelling) interest. You can also withdraw your consent at any time for the processing for which you have given your consent. With regard to both objecting and withdrawing consent, we will cease processing if there are no other legal bases requiring processing. Finally, you always have the right to file a complaint with the Data Protection Authority (www.privacycommission.be).
Security. Your personal data will be treated confidentially. They are also appropriately protected according to the risk involved in their processing and, where necessary, stored and secured in accordance with specific legal requirements.
Transfer to third parties. We will only transmit your personal data to third parties once your consent has been obtained, on the basis of a legal obligation or a judicial or administrative decision or as indicated above in the context of the execution of the contract.
Social Media and Other Third Parties. We have no influence on the social media and other third-party services that are used on our website, and therefore assume no liability. When you use your social media profile, the relevant social media provider processes your personal data in accordance with its policy. We have no influence on this policy. We encourage you to carefully read their personal data policy.
Direct Marketing. “Direct Marketing” means any direct communication between us and you, which aims to inform you about our products and services or to update your customer profile and which are not e-mails sent in the context of personalised searches that you have saved. You can always oppose the use of your personal data for direct marketing by contacting us for this purpose.
Changes to this Privacy Policy. We strive to maintain this privacy policy. However, for various reasons, it may exceptionally be necessary to modify the content. Therefore, we invite you to consult this page regularly.
Disclaimer of this privacy policy. It is possible that some features have not yet been fully implemented or have been implemented differently from what is described here. We accept no responsibility for this. In any case, this does not affect the rights conferred on you by the GDPR and which you can exercise from May 25, 2018.
3. Cookies policy
What is a cookie ? A cookie is a small file placed on your device by a website. Cookies are designed to be read and used later.
How is a cookie placed on your device? Cookies are placed on your device by the website itself or by third parties present on the site through source code provided by them.
Don’t want cookies on your device? It is possible to disable cookies on your device by changing your browser settings. The site http://www.aboutcookies.org/ explains how to refuse cookies on the most common browsers. For more information on your browser, you can visit the following pages: Internet Explorer, Mozilla Firefox, Google Chrome, Safari. Cookies can nevertheless be useful for you and for us. Also, before refusing cookies, it may be useful to read the following.
How are cookies classified? Cookies can be classified in different ways. We have opted for the following classification:
– Essential cookies (also called technical cookies): these cookies are necessary for the proper functioning of the site. Without these cookies, a website may not function properly, and certain features may not be accessible.
– Functional cookies: these cookies save your preferences when visiting the site.
– Analytical cookies: through these cookies, third parties (such as WebTrends or Google Analytics) analyze how a website is visited, which layout is generally preferred, etc. The website then uses this data to optimize its functionality .
– Marketing cookies: these cookies are used by third parties (such as DoubleClick or Google Ads) in the context of marketing campaigns, in order to promote certain websites or products consulted when visiting other sites.
– Other third-party cookies (including social networks): a website may display content from third parties (such as videos or “likes”). These third parties manage their cookies on your device according to their own privacy policies and cookies policies. We do not interfere with this policy and cannot assume responsibility for it.
What cookies does this site use? This site may use each of the types of cookies described above.
4. Disclaimer
General remark. By visiting this website and using the information provided there, you accept this Disclaimer as well as the possible conditions of use and you have read the privacy policy and the Cookie policy. Read these two documents carefully.
Responsible editor. The editor responsible for this website is The Keys srl & The Keys Management srl – info@thekeys.be
Responsibility. This site contains properties which are offered for rental or sale. The description of the property and the display of the sale price or the rent has been made with the greatest care. However, both the technical description and the sale price or rent may contain factual errors or approximations. The sale price or the rent announced as well as the technical description of the property are therefore purely indicative and are not contractual. The posting of a property for rent or for sale cannot therefore be considered as a binding offer from us or from the owner or seller. The seller or the owner is only bound by a written agreement following the firm offer you have made. We strongly recommend viewing a property before making a firm offer. Contact us by email or phone to arrange a visit. In order to allow you to then make a binding offer, we have standard forms that we make available to you. Finally, it is possible that the property is no longer available at the time of the consultation. We reject any responsibility in this regard. This site may also contain information and advice concerning the acquisition or rental of a property. This information expresses the opinion of its author. The greatest care has been devoted to this information; nevertheless, factual errors or inaccuracies cannot be excluded. This information therefore does not give you any rights against us or against the owners. Furthermore, we accept no responsibility for any decisions you make based (in part) on this information. This website may contain links to other websites. The content of these pages may be commercial or informative and in no way engages our responsibility. We also have no influence on the social media platforms and other third-party services that are used on our website and are therefore not responsible for them.
Intellectual property. Intellectual property rights as governed by applicable law apply to the content of this website. The content of this site is notably protected by copyright. It is therefore prohibited to copy or use texts, images, photographic material, video material and others without the written authorization of the responsible publisher, except for the exceptions provided for by law, which will be interpreted in a restrictive manner.
Applicable law. Belgian law applies to disputes relating to the use of this site.
5. Subcontractors
SOGIS (property management accounting software) / Rue de l’Industrie, 20 in B-1400 Nivelles
OMNICASA SOFTWARE SOLUTIONS (lettings and sales management software) / Avenue Louise, 523 in B-1050 Ixelles
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