Privacy Policy

Personal data is any information about an identified or identifiable physical person. For example, this can be a person’s name, a photograph, a telephone number, a contract number, an e-mail address, etc.

Processing is any operation regarding personal data. ‘Processing of data’ means any operation involving personal data. Amongst other things, the concept of ‘processing’ covers the collection, recording, management, storage, updating, amendment, retrieval, consulting, use, distribution or diffusion in any other way, joining, combining, filing, erasure, or final destruction of personal data.

The user/expert is the processing manager of your personal data. This means that the user/expert specifies the purpose and the means of processing your personal data. Chapps is merely a processor of your personal data.

If you, as a Chapps client, allow end users (e.g. employees or work placement students) to make use of the Chapps products and services which fall within the scope of this privacy policy, we then have the following additional responsibilities:

• We must inform end users adequately that Chapps will be processing their personal data as a result of their use of Chapps products and services.
• We must obtain all the legally required consent from end users before their personal data is handed over to Chapps for processing within the scope of the Chapps products and services which we allow them to use.
• We are not allowed to use Chapps products and services to collect personal data which is contrary to the prevailing privacy legislation or to provide you yourself with access to the personal data of end users in an unlawful manner.
• We at Chapps must inform you of the level of security of the Chapps products and services and within our limits take what are in our estimation appropriate technical and organisational measures to safeguard personal data adequately from unauthorised or unlawful processing or from unlawful or inadvertent destruction, inadvertent loss, falsification, unauthorised distribution, damage, amendment, unauthorised access, or disclosure.
• We must take all reasonable measures to guarantee the trustworthiness of end users who have access to the personal data.
• We are not allowed to do, cause, or permit anything which could in any way result in any breach of that privacy legislation.

If, via our Chapps products and services, you can make use of other parties’ services such as chat, web sites of third parties, forums, Facebook, Twitter, newsgroups, and/or apps, you must use them here wisely and read the privacy policy of those third parties carefully. Chapps has no control over information which you put there and how it is processed, and we are also not liable.

The user/expert is the processing manager of your personal data. This means that he or she is your contact person and that of the supervisory authorities for all enquiries regarding your data.

We have appointed a data protection officer or DPO as the sole contact person within our company with the following contact details:
Chapps NV,
Picardstraat 7 bus 100,
Data Protection Officer
1000 Brussels
privacy@chapps.com

During your various contact moments with your user/expert, he or she might possibly collect various items of personal data: identification data (e.g. surname, forename, or address), contact data (e.g. address, e-mail address, or telephone number), data about the property which is being let/sold and/or rented/bought, data about the rent agreement, or data regarding the sales agreement.

Chapps will process your data:

• When you become a client with the user/expert.
• When you fill in forms, documents, and contracts which the user/expert presents to you.
• When you call upon the products and services of the user/expert.
• When you contact the user/expert via the various channels made available to you.
• When your data is published or announced by authorised third parties (persons whom you have specially authorised, the Belgian Official Gazette, your estate agent, your manager, your syndic, etc.
• When you share your data when you use the web sites of the user/expert e.g. when you ask for a price quotation or place an order online, or your estate agent or manager does so on your behalf.
• When you visit one of the web sites of the user/expert or use apps via cookies and other forms of technology.

When your user/expert asks for your personal data, you are entitled to refuse. However, such a refusal could impede the start of a business relationship or the implementation of his or her services, could change the type of services, or could affect the management of the services.

We process personal data for various purposes, but in each case we use only that data which is necessary to achieve the purpose in view.

The user/expert uses your personal data:

• When he or she has received your consent.
• In the context of the preparation or implementation of the service provided by the user/expert.
• In order to satisfy the statutory or legislative stipulations to which we and the user/expert are subject, such as preventing money laundering, tackling tax fraud, and tax obligations.
• When the user/expert has a justified interest in doing so, in which case he or she always strives for a balance between that interest and respecting the privacy of the person concerned.

Access to your personal data is granted only to persons who need that data in order to do their job. They must show due regard for a strict observation of secrecy and observe all technical and organisational rules to ensure the confidentiality of the personal data.

Chapps has technical resources and specialist teams in place who concentrate primarily on protecting your personal data. This is how Chapps aims to prevent unauthorised persons from gaining access to the data, processing it, amending it, or destroying it.

This data can also be stored outside the European Union on condition that that the service provider conforms to the European GDPR legislation. Our web sites sometimes mention links to sites of third parties (e.g. social media or organisers of events which we sponsor) with terms and conditions of use which do not fall within the scope of this privacy policy. Read their policy carefully with regard to the protection of your personal data.

We do not sell any personal data to third parties and neither do we give it to third parties unless:

• They are our legal successors and/or other companies within the Chapps group. We pass on your personal data to our potential legal successors and related companies (such as subsidiaries and sister entities) for the same purposes as stated in this privacy policy.
• This is necessary for our service. For some aspects of our products and services we work with third parties or deploy subcontractors. Your personal data is passed on only for the same purposes as with Chapps itself. We make sure that they, like ourselves, treat your data securely, respectfully, and responsibly.
• There is a legal obligation.
• There is a justified interest for Chapps or the third party concerned. This is done only if your interests or your fundamental rights and freedoms are not more important.
• You give us your consent. If Chapps were to hand over personal data in another manner, this would be done with an explicit communication in which clarification is given about the third party, the purposes of the handover, and the processing. We obtain your explicit consent where that is legally required. You can always raise an objection.

We use your data to provide you with an excellent service and general communication about the products which you are interested in or might be interested in. At this level the data stated above is processed in the context of our statutory obligations, our legitimate interest, and the proper execution of your contract (including complaints and client management, as well as informing you about the improvement of the service). If you opt not to receive direct marketing, Chapps will nevertheless continue to inform you about an optimal use of Chapps products and services which you already have. For instance, we can recommend to you a product or service which is better suited to your needs.

Your right to access

You have the right to (free) access to your own personal data. You can ask us:

• Whether or not we process your personal data.
• Why we process it.
• Where the processed data came from originally.
• What logic we use when we automatically process some personal data.

You must apply for your right of access by e-mail. To exercise your right of access and prevent any unlawful disclosure of your personal data, you must provide us with proof of your identity. You are requested preferably to include a copy of the front of your identity card with your application.

Chapps has 45 days to reply to your application. Remember that this period doesn’t start until Chapps has received your written application and is in possession of all the information required to deal with your application.

If you have any reason to believe that Chapps has not dealt with your application correctly, please take this up firstly by sending an e-mail to privacy@chapps.com so that we can consider the options together with you.

For the sake of completeness, we wish to inform you that if Chapps doesn’t reply to your application, rejects it, or if our reply fails to meet your expectations, you are always entitled to lodge a complaint with the Privacy Commission via commission@privacycommission.be, which will act within the scope of its mediation assignment.

Your right to improvement and removal
You are entitled to order the removal or amendment of incomplete, incorrect, inappropriate, or antiquated personal data. You can contact our services for that purpose. If necessary, we will then amend or remove this information within the legally stipulated periods. Remember that, depending on your request, we are sometimes no longer able to offer some services. Furthermore, it is not always possible for us to remove all the requested data.

Your right to object to the processing of your data for direct marketing
You are always entitled to object to the use of your personal data for direct marketing purposes and you do not have to give a reason for your objection. To lodge an objection you can contact Korfine at any time and you then have the option of deactivating our promotions and/or actions via telephone, post, SMS, or e-mail.

Chapps is responsible for taking appropriate organisational and technical measures to safeguard personal data. We are not allowed to keep personal data for longer than is necessary to achieve the objective for which we have collected it. This data is removed as soon as all objectives are achieved.

This means that the processed data is kept for the entire duration of your agreement with the user/expert, the legal storage period, and any other storage period which might be imposed by the applicable legislation and regulations.

Apart from the data which you share with us voluntarily when using our web sites, we also deploy cookies and other technological means to collect data.

Web sites
You can visit our web sites without sharing your personal data. With your consent (in so far as this is necessary) we can inform you as a visitor to our web sites about a personalised range of Chapps products. Some parts or functions are reserved for Chapps clients. To optimise the service, we can supplement your client data with the data which we derive from cookies as a result of your use of our web sites.

Cookies
What are cookies?
We use cookies whenever you open our e-mails and/or whenever you visit our web sites or use apps. Cookies are pieces of information which are stored on your own computer or mobile device and which optimise the user-convenience of our web sites and apps. This means it is possible, for instance, for us to identify you as a visitor to our web sites on your next visit and we can gear our web sites better to your wishes, preferences, and convenience. Cookies can also be used to make the content or publicity of a web site more personal.

Which sorts of cookies do we use?

• • Essential cookies: These are necessary in order to make use of the web site and ensure a secure identity control e.g. web site navigation, content of the shopping trolley, access to personal data, etc.
  • Functional cookies: These make the functioning of the web site easier and ensure a personalised surf experience, for instance, by remembering log-on names, passwords, the content of your shopping trolley, and preferences like language settings.

Mobile apps

• Korfine can offer various apps. If you make use of these services, it might also be necessary to process your personal data. This data is always processed in accordance with the stipulations of this Privacy Policy.

For more information about our privacy policy or for complaints relating to your privacy, including the exercise of your right to access, you can contact us via privacy@chapps.com.

The personal data which collect via these diverse channels is included in the databases of Chapps nv.

Chapps may amend this privacy policy from time to time. And so, please make sure that you always consult the latest version of this policy on www.chapps.com/privacy. Obviously, we will inform you of any intrinsic change via our web sites or other standard communication channels.