GENERAL PRIVACY POLICY ION GROUP
This is the Privacy Policy of the “ION Group” (hereinafter “ION Group” or “we”).
The purpose of this Privacy Policy is to inform you about the processing of personal data in the context of our activities, including, among others, through our central website (https:// https://www.ion.be/nl - hereinafter “Main Website”) and our project websites (hereinafter the Main Website and the project websites are collectively referred to as the “Websites”).
This Privacy Policy may be amended, for example to comply with new legal, contractual or administrative obligations. We therefore encourage you to consult this Privacy Policy on a regular basis. Important changes will be announced through our Main Website. This version of the Privacy Policy was last amended on [XX March 2022].
Other relevant terms for visiting and using the Websites can be found in our Terms of Use[A1] and in our Cookie Policy[A2] , which together with this Privacy Policy form a whole and apply jointly when you visit the Websites.
In case of questions or concerns, you may contact us at any time using the information below (see Title I).
Who is responsible for processing your personal data?
The company within the ION Group that processes your personal data within the scope of its activities (e.g. the company with which you have entered into a contract, to whom you have provided your personal data yourself, from whom you visit the Website, ...) is responsible for processing your personal data.[1]
In addition, ION BV is also a data controller, jointly with the above-mentioned company, in the context of the services provided by ION BV for that company. ION BV is a limited liability company under Belgian law, with its registered office at Vredestraat 53, 8790 Waregem and is registered in the Crossroads Bank for Enterprises under number 0838.897.867.
In certain cases, ION AGENCY NV will also be a data controller, jointly with the above mentioned company (first paragraph), in the context of the brokerage services provided by ION AGENCY NV for that company. ION AGENCY NV is a limited liability company under Belgian law, with its registered office at Vredestraat 53, 8790 Waregem and is registered in the Crossroads Bank for Enterprises under the number 0650.886.430.
The ION Group has a privacy officer who is your contact for all questions regarding the processing of your personal data. The contact details of the privacy officer can be found under Title IX of this Privacy Policy.
What data do we process?
We collect your data in three ways.
The data that you provide to us yourself.
First, we receive your personal data when you share it with us yourself, through the Websites or outside of them.
This may be, for example, through the contact forms on our Websites. You can use these contact forms to ask us a question or to request certain information, for example if you are a tenant or buyer interested in a particular property or if you wish to cooperate with us as a property or land owner. In the contact form you need to provide the mandatory information (i.e. with a red asterisk) and you can send us a personal message.
Also, when you visit our office, we may receive data from you that you provide yourself.
We also collect your personal data when you apply for a vacancy or send us an unsolicited application.
Furthermore, you provide us with your data when you register via the Websites to receive marketing by (electronic) mail as well as invitations to events.
You also provide your personal data yourself when you give a business card to one of the ION Group employees or send us an e-mail or phone call.
Furthermore, you provide your personal data yourself when you are interested in a particular project of the ION Group and contact an employee of the ION Group via real estate websites (e.g. as a tenant, buyer or as a property or land owner).
We also receive your personal data when you conclude an agreement with us (for example: a reservation or compromise agreement, a service agreement, etc.).
In addition, you also provide your personal data yourself when you provide us with an identification form for fraud prevention purposes.
Thus, we may process the following data from you:
identification data e.g. your name, company name, position, authority, address, e-mail address, telephone number, gender, place and date of birth, profession, nationality; identity card or passport number; expiration date of validity of identity card or passport; politically exposed person or in family or close associate and position/connection, copies of identification documents (such as your identity card), description of business relationship, company number;
financial information e.g. your VAT number, account number, description of transaction;
other information you provide us with. An example of other information you provide us with is data about your preferences, e.g. the property you are interested in, the type of marketing you wish to receive, the job vacancy you are applying for, etc.
The data we receive from third parties
In addition, we may also receive your personal data from third parties, such as external brokers, investors, employment and temporary employment agencies or from your employer.
The latter is e.g. the case when we have an agreement with a contracting party (e.g. a supplier or contractor) for whom you work or on whose behalf you provide services to the ION Group.
In addition, we may also obtain data about you from third parties (natural persons or legal entities) for fraud prevention purposes, and more specifically when you have intervened as a natural person in a transaction or when you are acting as an agent of the third party, when you are a director of the third party and, in the case of trusts, fiduciaries or similar legal arrangements, also when you are a founder or protector of the third party.
This includes identification data such as your name, company name, position, address, e-mail address, gender, telephone number, sex, place and date of birth, nationality, identity card or passport number, expiration date of validity of identity card or passport, politically prominent person or in family and position/connection, your authority to commit the third party, your appointment, copy of your identity card your resume and/or the references to your previous work etc.
The data we collect automatically
Furthermore, we process certain data via cookies on our Websites such as the type of browser you use, the operating system you use, your IP address, the number of page visits, whether you are a unique visitor etc.
Certain of this data allows us to identify you as a natural person or can be linked to you, such as your IP address. This data therefore qualifies as personal data, making this Privacy Policy applicable as well. More information about cookies can be found in the Cookie Policy[A3] .
We also process certain non-directly identifying data via cookies when you visit our website, such as, for example, your browser type.
In addition, the ION Group may also process camera images (including sound and e.g. time of arrival in office buildings) to enhance the security in its buildings of its employees and other visitors.
The ION Group may also take photos and videos of you when you visit our events.
Why do we process your data?
To answer your questions.
If you contact us (e.g. via one of the contact forms on the Websites or the application form on the Main Website), we will use the personal data you provide to contact you and answer your question.
For this purpose, we process data such as your name, e-mail address, telephone number, address, your interest, your correspondence with us and any other data you provide us that is relevant to answer your question.
We process this data on the basis of our legitimate interest in order to answer the questions asked of us.
For selection and recruitment
We also process your personal data for the management of vacancies and job applications.
The processing of data is then based on pre-contractual obligations (e.g. if you send us an application), on your consent (e.g. if you provide a reference) or on our legitimate interest to be able to carry out the selection and recruitment procedure properly and to improve it in the future (e.g. maintaining a database of CVs).
To keep you informed of our services and activities and for direct marketing purposes
We process data for prospecting and promotional purposes and (direct) marketing. This allows us to inform you about our projects in which you may be interested. For example, we can invite you to and remind you of our events.
To this end, we mainly process personal data such as your name, e-mail address, telephone number and address. In addition, we also process data about your preferences, such as for example your preferred location based on a property in which you have shown interest in the past etc.
We process this data either based on your consent or on our legitimate interest to keep you informed about our activities and services. For example, we have a legitimate interest (“soft opt-in”) to send you electronic messages about our activities when you are already a client of the ION Group. You have the right to withdraw your consent or object at any time (see Title VIII).
The ION Group may also process your personal data in order to send you personalized information or advertising. To this end, we process personal data such as your name, your e-mail address, your telephone number and your address.
We may develop a profile based on your online behavior. In this profile, we take into account your preferences and interests, for example regarding the pages you have visited, the links you have clicked on, the projects you have viewed and other projects that might interest you. We receive this information through cookies placed on our website. Based on the information collected in the profile, we may send you information and advertisements such as information and advertisements related to projects that fit your profile or that might interest you.
Furthermore, we may use the services of third parties, such as Facebook, to identify target audiences and lookalike audiences in order to advertise our products and services to individuals with similar profiles. For this purpose, we may process personal data such as your name, phone number, address, email address, date of birth, age, gender, your job title, the name of your company, your preferred language, and specific products and services you are interested in.
We can create a profile of you and send you personalized (direct) marketing based on your consent when you accept the cookies that capture this information. You have the right to withdraw your consent to the processing of your personal data for direct marketing purposes at any time (see Title VIII).
More information on the ION Group's use of cookies can be found in our Cookie Policy[A4] .
To conduct (satisfaction) surveys.
We process your data for the purpose of conducting (telephone) (satisfaction) surveys. Within the scope of this survey, we provide your personal data (including your name, your e-mail address, your telephone number, the good you purchased and the construction phase) to specialized service providers, such as Profacts.
We process this data on the basis of our legitimate interest in order, among other things, to gauge customer satisfaction. If you do not wish to participate in this telephone survey, you may object at any time to the processing of your personal data for this purpose via the contact details provided in Title IX.
To organize competitions
We process your data for the purpose of organizing competitions. In the context of these competitions, we may process your personal data such as your name, e-mail address, address and telephone number, as well as the personal data that you provide to us yourself, for example via the competition form upon participation. In the context of these competitions, we may also share the same personal data with service providers, such as Profacts, and with other parties with which the ION Group cooperates for the organization of the competitions.
We process this data either based on your consent or on our legitimate interest to enable you to participate in these competitions. You have the right to withdraw your consent or object at any time (see Title VIII).
To provide our services and conduct our business.
The ION Group processes personal data in order to conduct its business as a project developer and real estate investor, to offer, set up, maintain and support its services, to execute its agreements and for administrative purposes.
For this purpose, we mainly process personal data such as your name, e-mail address, telephone number, date of birth and address, as well as your personal preferences in the context of the service provided to you by the ION Group, correspondence with the ION Group and information about the projects.
We process this data based on your request to take steps prior to the conclusion of a contract, based on the performance of a contract or our legitimate interest to provide our services, perform our contracts and/or conduct our business.
For supplier management
We process personal data in the context of managing our suppliers (e.g. our contractors).
This includes data such as your name, e-mail address and, in certain cases, your resume and/or references to your previous work, which are provided to us by our contracting party.
The processing of the data is then based on the performance of our contract or our legitimate interest to perform our agreements with our suppliers.
For the technical and functional management of our Websites, keeping statistics and storing search preferences
We process personal data obtained through cookies for the technical and functional management of our Websites, to ensure that our Websites are easy to use, to collect statistics (e.g., to measure the number of visitors to the Websites and to measure the most visited pages) and to store your search preferences. Through your data, we can secure our Websites and track how our Websites are used which allows us to improve their content and layout.
To do this, we may process data such as your IP address, the pages you visit, the browser you use, your language preference, your location, and the time and duration of your visit.
The processing of this data is based on your consent (via our cookie banner) or the legitimate interest of the ION Group to provide a well-functioning and secure website and pages with content relevant to you.
For more information on the ION Group's use of cookies, please see our Cookie Policy[A5] .
To comply with legal obligations
We process personal data in order to comply with our legal obligations. In many cases, we are required by law to retain and/or disclose certain personal data to public authorities, for example in light of tax obligations.
For this purpose, we may process data such as your name, address, telephone number, e-mail address, national register number, transaction data and all data necessary to comply with our legal obligations.
We process this personal data because the processing is necessary to fulfill our legal obligations.
For the security of ION's buildings (camera surveillance).
ION has installed surveillance cameras in certain places on and in the buildings of its facilities to increase the security in its buildings of its employees and other visitors.
We collect this data based on our legitimate interest to provide for the security of everyone within our office buildings and to protect our business assets.
Who has access to your personal data?
You can count on us to protect your privacy as much as possible. In this context, we want to minimize the sharing of your personal data with third parties.
Within the ION Group, we share your data only with those who need to access it (e.g., to answer your question, to draft your contract).
We use carefully selected and reliable service providers to carry out certain (processing) activities, e.g. for:
IT services: for example, installing and maintaining PCs and providing a CRM system.
Marketing activities: for example, marketing automation platforms and organizing competitions.
(Satisfaction) surveys: conducting (satisfaction) surveys, for example through specialized service providers such as Profacts.
Customer, supplier administration and communication: for example, maintaining communication with customers and suppliers via a customer administration platform and organizing customer counseling via external customer counselors.
HR activities: for example, through recruitment offices.
Asset and property management: for example, through syndicators, appraisers, etc.
In this context, the ION Group concludes processing agreements with these parties who need access to personal data to perform their services.
In addition, the ION Group may also transfer personal data to an external party that itself also qualifies as a data controller, such as, for example, notaries, external consultants, external property developers, external real estate agents, municipalities, etc. when necessary to provide our services. In addition, the ION Group may also share personal data with parties in connection with competitions.
We may also share personal data with competent authorities authorized to request such data or to whom we are required to disclose information, as well as when required by law or as a result of legal proceedings or lawsuits.
Finally, in the event of a reorganization, demerger, contribution of line of business, merger or sale of the company, we may transfer any personal data we collect to the relevant third party (parties).
Do we transfer your personal data outside the European Economic Area?
The ION Group itself does not process your Personal Data outside the European Economic Area (EEA).
Some Personal Data may be stored or transferred outside the EEA for the purposes described. This transfer may be through service providers located outside the territory of the EEA or storing data on servers located or accessible outside the EEA.
If that is the case, the ION Group will ensure that an adequacy decision (Article 45 General Data Protection Regulation (“AVG”) exists for the country to which data is transferred or that standard contractual clauses (Article 46(2) AVG) are concluded or that other appropriate safeguards are taken in accordance with Chapter V of the AVG.
If you have any questions regarding the transfer of your personal data outside the EEA or if you would like to obtain a copy of the relevant documents, please submit a dated and signed request to the ION Group (cf. contact details under Title IX).
How long do we keep your personal data and how do we secure your personal data?
We will retain your personal data for no longer than necessary for the purposes for which it is processed, taking into account any legal retention obligations.
We will keep the personal data we receive as part of a query or request on file for a limited time to allow further follow-up on your request.
The following is a (non-exhaustive) overview of the main retention periods that the ION Group endeavors to pursue. ION may in any case retain (personal) data longer in the context of an (impending) complaint, a dispute or an investigation.
Personal data in contracts (such as purchase and rental agreements, but also agreements with service providers of the ION Group): retained for a minimum of ten years after the termination of the agreement.
Camera images from security cameras: retained for a maximum period of 1 month (unless the personal data is required for further investigation when an incident has occurred).
Personal data of prospects:
who have completed the contact form on ION's website: retained for a reasonable period of time after the actions (if any) taken in response to the contact form submitted have been completed.
who have subscribed via the website to receive marketing from ION: retained until a) an unsubscribe request is received, b) the email address is no longer correct (if sent emails are not delivered), or c) when the list is updated, it appears that data is no longer relevant or accurate.
Personal data of customers (e.g. tenants or buyers) used for direct marketing for similar products/services: are retained until a) an unsubscribe request is received, or b) the person is no longer a “current customer” of ION. An individual is no longer considered a customer of ION after a period of 10 years following the last transaction or communication with the customer.
Personal data contained in documentation in connection with job applications: retained for at least five years from the application/publication of the job posting, unless the applicant is clearly unsuitable, in which case such information will be deleted within a reasonable period of time.
Furthermore, the ION Group attaches great importance to the security of your personal data. We take appropriate organizational and technical measures, taking into account the state of the art and the nature of the data to be protected and the potential risks, in order to optimally protect personal data against accidental or unauthorized destruction, against accidental loss and against alteration, access and any other unauthorized processing of personal data.
What about links to other websites and social media?
Social media pages of the ION Group.
ION has pages on Twitter[2], Facebook[3], LinkedIn[4], Instagram[5] and Youtube[6]. When you visit these pages, your personal data will be transferred to the social media operator through the use of cookies.
Social media operators may obtain information such as the websites you are currently visiting or have visited in the past and your IP address. When you visit these pages, the ION Group may receive aggregated data from the respective social networks in the form of statistics on how our pages are visited by social media users.
Links on our Websites and social media “share buttons”
The Websites of the ION Group may further contain references to other websites (e.g. via hyperlinks, social plug-ins), provided by other companies or by social media. Please note that clicking on these links will redirect you to websites/platforms to which separate terms of use, privacy policy and cookie policy apply. The ION Group assumes no responsibility or liability for any damages arising from the use of these external websites or platforms in this regard. We recommend that you read these terms of use, privacy policy and cookie policy carefully before using those websites or platforms.
Our website allows you to share content with Facebook[7], LinkedIn[8] and via email. When using these social plug-in functions (e.g. “share” button, ...), information about your usage is sent directly from your browser to the respective social network. If you are already registered with a social network during your visit to our website, the social media operator can assign the visit via the social plug-ins to your personal account. If you are not yet a member of a social network, it is still possible for the social networks to receive and store your IP address and information about the browser and operating system you are using via the social plug-ins.
If you share content from our website directly on the social media page, your personal data will be visible to the visitors of these social media. For the scope and purpose of data collection, as well as the further processing and use of data by social networks and information on rights and settings to protect your privacy, please refer to the privacy policies of these social networks.
How can you exercise your rights?
The privacy legislation gives you several rights and we take information about these rights and their exercise very seriously.
You have the right to request access to, correct, delete or limit the processing of your personal data that we process about you free of charge. In some cases, you may also object to the processing of your personal data and have the right to data portability. In addition, you also have the right to human intervention for decisions based on automated decision-making or profiling.
Where the processing of your personal data is based on your consent, you have the right to withdraw it at any time, but you understand that such withdrawal will not affect the lawful processing we have carried out up to that point based on your consent.
Any questions about your rights, to exercise them or questions about this Privacy Policy can be directed to ION Group at the email address in Title IX of this Privacy Policy. We will respond to your request as soon as possible. However, we may additionally ask you to provide adequate proof of your identity (e.g. copy of your identity card) in accordance with legal requirements and in order to protect the privacy of others.
In certain cases, we may refuse your request if it would be manifestly unfounded or excessive. In doing so, we always act in line with applicable data protection legislation.
Although we naturally prefer to resolve any problems directly with you, we would like to remind you that you always have the right to submit a complaint or question to a competent supervisory authority. In Belgium, you may submit a complaint or question to the Data Protection Authority (see www.gegevensbeschermingsautoriteit.be; address: Printing Press Street 35, 1000 Brussels; phone: +32 (0)2 274 48 00; E: [email protected]).
Questions?
If you have further questions about this website or about this Privacy Policy, please contact the ION Group's Privacy Officer at [email protected].
[1] “Controller” means the legal entity that determines for what purpose and in what manner personal data are processed. It may do this alone or together with other organizations. This means that the Controller exercises overall control over the “why” and the “how” of the Processing of personal data.
[2] Twitter.com/en/privacy
[3] https://nl-nl.facebook.com/privacy/explanation
[4] https://www.linkedin.com/legal/privacy-policy
[5] https://help.instagram.com/519522125107875
[6] https://www.youtube.com/intl/ALL_be/howyoutubeworks/user-settings/priva…