1. Who are we?

AG REAL ESTATE NV/SA, is a Belgian company, whose registered office is at Kunstlaan/Avenue des Arts 58 1000 Brussels (hereafter “AG REAL ESTATE”).

Our company websites www.agrealestate.eu  and www.agresidential.be, the websites regarding our shopping centers www.westlandshopping.be, www.city2.be, www.niniashoppingcenter.be, www.gentzuid.be, www.anspach-brussels.be, www.galeries-st-lambert.be, www.thewshopping.be, www.themint.be, www.click2shopbrussels.be and our many project-based websites (www.scholenvanmorgen.be, www.canalwharf.be, www.cavell-court.be, www.vivid-leuven.be,…), and our Apps are run by AG REAL ESTATE, and as the case may be by third party subcontractors, under the responsibility of AG REAL ESTATE.

When we refer to ‘’we’’ or ‘’our’’ in this Privacy Policy we are referring to AG REAL ESTATE and any of its affiliates. When we refer to “you” or “your”, we are referring to any user of any of AG REAL ESTATE’s websites, Apps or services.

Our Data Protection Officer (“DPO”) can be reached by postal mail at DPO AG REAL ESTATE, Kunstlaan/Avenue des Arts 58, 1000 Brussels, Belgium, or by email at dpo@agrealestate.eu.

2. Introduction & General Terms

At AG REAL ESTATE, we’re committed to protecting and respecting your privacy.

This Privacy Policy relates to our use of any personal information we collect from you:

• via following online services:
  • any AG REAL ESTATE website that links to this Privacy Policy;
  • social media or official AG REAL ESTATE content on other websites;
  • our mobile device applications (“Apps”),
• via any Bluetooth, Wi-Fi or any similar technology that may communicate with your (mobile) device including identifying its location, in our shopping centers. This includes collecting unique online identifiers such as IP addresses, MAC addresses, which are numbers that can uniquely identify terminal equipment such as a specific computer, handset, tablet or other network device on the internet.
• when you are filmed by our surveillance cameras in and around our buildings. The images are recorded solely for the purpose of guaranteeing the security of the goods and the persons as well as to prevent the abuses, frauds and other offences of which our visitors and ourselves could be victims (their presence is indicated by pictograms provided with our contact details );
• when the license plate of your car is filmed by our automatic license plate recognition cameras in a very limited number of office buildings in order to manage the access to the car park of these office buildings (their presence is indicated by pictograms with our contact details).

This Privacy Policy also relates to our use of any personal information you provide to us by phone, SMS, email, in letters or other correspondence, in person and through copies of your personal information obtained from your identity card or your residence permit (but excluding your national number) for the purpose of preparing lease or real estate purchase documents and when you are ordering on our marketplace click2shopbrussels.be.

In order to provide you with the full range of services, we sometimes need to collect information about you.

This Privacy Policy explains the following:

• what information AG REAL ESTATE may collect about you;
• how AG REAL ESTATE will use information that we collect about you;
• when AG REAL ESTATE may use your details to contact you;
• whether AG REAL ESTATE will disclose your details to anyone else;
• your choices regarding the personal information you provide to us;
• the use of cookies on AG REAL ESTATE websites and how you can reject cookies.

AG REAL ESTATE is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereafter the “GDPR“). Please note that, no website can be completely secure. If you have any concerns that one of your AG REAL ESTATE accounts could have been compromised, e.g. someone could have discovered your password, please get in touch immediately.

AG REAL ESTATE websites contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, and are also likely to use cookies, and we therefore urge you to review them. Their policies will govern the use of personal information you submit, or which may be collected by cookies, when visiting such websites. We do not accept any responsibility or liability for the privacy practices of third party websites and your use of such websites is at your own risk.

3. What information does AG REAL ESTATE collect?

When you access or sign up to any of AG REAL ESTATE’s services, for example Apps, newsletters, marketplace, chats with our social media accounts, message boards, web and mobile notifications, telephone or text AG REAL ESTATE, we may receive personal information about you.

This can consist of personal information you have provided to us such as, for example, your name, email address, postal address, telephone or mobile number, gender or date of birth, the licence plate of your car, personal interests (e.g. what newsletters you have read), images as well as general (aggregate, non-personal) information collected about the way in which visitors make use of AG REAL ESTATE on-line services and the shop where you have done a purchase, the date of the purchase, the products bought, the amount per product, the total purchase amount and the delivery address (when you order on the marketplace click2shopbrussels.be).

If you are the parent or guardian of a child under (16), we may process limited personal data about you so that you can give consent for the child to access some AG REAL ESTATE services. We may use your contact details to communicate with you about the child’s account or use of services.

Please note that sometimes we will require you to provide additional personal information, for example when preparing lease or real estate purchase agreements. When we do this we will provide further information about why we are collecting your information and how we will use it.

Some of our services enable you to sign-in via a third-party service, such as Facebook. If you choose to sign-in via a third-party app, you will be presented with a dialog box which will ask your permission to allow AG REAL ESTATE to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible to the third-party service, such as Facebook). Please note that any information that is not required by the particular service you have opted to use will not be retained by AG REAL ESTATE.

For more information, please see article 15 of this policy, on AG REAL ESTATE’s use of cookies and similar technologies, and article 17, on information collected by AG REAL ESTATE when you use AG REAL ESTATE Apps.

4. For what purposes does AG REAL ESTATE use the information it collects about you?

AG REAL ESTATE will use your personal information for a number of purposes including the following:

• to provide you with our services, including the preparation of real estate lease or purchase agreements;
• to provide you with information about our services;
• to deal with your requests and enquiries;
• to provide you with the most user-friendly online navigation experience;
• for “service administration purposes”, which means that AG REAL ESTATE may contact you for reasons related to the service or online content you have signed up for;
• we may also show you relevant advertising, as set out in article 7;
• to contact you about a submission you have made;
• to process job applications;
• to use IP addresses and device identifiers to identify the location of users, to block disruptive use, to establish the number of visits of our websites and shopping malls,
• for analysis and research purposes so that we may improve the services offered by AG REAL ESTATE;
• we also use and disclose information in aggregate (so that no individuals are identified or identifiable) for marketing and strategic development purposes (for example the number of visitors in a shopping center and the heatmap of the direction taken by the crowd of visitors in a shopping center) ;
• for the purpose of guaranteeing the security of the goods and the persons as well as to prevent the abuses, frauds and other offences of which our visitors and ourselves could be victims.

We will only collect, use or share your personal data for the purposes set out above where we are satisfied that:

• our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you (e.g. rental contracts, apartment sales contracts)
• our use of your personal data is necessary to support legitimate interests that we have as a business to provide products and services to our customers, to protect our property and to ensure safety at our premises, provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights (e.g. surveillance cameras, heatmap of the direction taken by the crowd of visitors in a shopping center, orders on the marketplace www.click2shopbrussels.be)
• our use of your personal data is necessary to comply with a relevant legal obligation that we have (e.g. maintain business records, comply with requests by public authorities, comply with anti-money laundering legislation)
• you have provided your consent to us using your personal data for that purpose (e.g. you provide us with direct marketing consent or opt in to our apps)

Where AG REAL ESTATE proposes using your personal information for purposes not mentioned above we will notify you first. Please see article 18 below for details.

5. Your AG REAL ESTATE Account

If you have registered for an AG REAL ESTATE account on one of our websites or through an App or the marketplace, this will not automatically allow you to login to other AG REAL ESTATE website and apps, as these services might be run by AG REAL ESTATE or separate subcontractor chosen by AG REAL ESTATE.

Your AG REAL ESTATE accounts will always be covered by the policies of this website. But, please be aware that additional policies may apply if your AG REAL ESTATE account is linked to another account.

6. When will AG REAL ESTATE contact you?

AG REAL ESTATE may contact you:

• in relation to any contractual relation you have engaged with AG REAL ESTATE;
• in relation to any service, activity or online content you have signed up for, for yourself or for your under 16-year old child in order to ensure that AG REAL ESTATE can deliver the services, e.g. to verify your email when you sign up for a AG REAL ESTATE newsletter, or to help you reset your password for your accounts on our websites or Apps;
• in relation to any correspondence we receive from you or any comment or complaint you make about AG REAL ESTATE products or services;
• in relation to any job application;
• in relation to our legal rights and obligations;
• in relation to any personalized services you are using;
• in relation to any contribution you have submitted to AG REAL ESTATE, e.g. on AG REAL ESTATE message boards or via text or voicemail message;
• to invite you to participate in surveys about AG REAL ESTATE services (participation is always voluntary);
• to update you on any material changes to AG REAL ESTATE’s policies and practices; and
• for marketing purposes, as set out in article 7.

We will never contact you to ask for your AG REAL ESTATE account password, or other login information. If you receive any emails or calls from people asking for this information and claiming to be from AG REAL ESTATE please inform our DPO straightaway.

7. Will You be contacted for marketing purposes?

AG REAL ESTATE will only send you marketing emails or contact you on AG REAL ESTATE platforms when you have agreed to this. You will always be able to unsubscribe by following the procedure set out in article 12.  From time to time we may also contact you to ask your opinion on certain issues affecting AG REAL ESTATE. AG REAL ESTATE may personalize the message content based upon any information you have provided to us and your use of AG REAL ESTATE platforms.

8. Will AG REAL ESTATE share my personal information?

AG REAL ESTATE will not sell or rent your information to third parties and will not share your information with third parties for marketing purposes.

Generally, we will use your information within AG REAL ESTATE and will only share it outside AG REAL ESTATE where you have requested it or given your consent, except:

• where disclosure is required or permitted by law (for example to government bodies or law enforcement agencies, including for child protection reasons) by a court order or for the purposes of prevention of fraud or other crime, or
• if AG REAL Estate files a claim with its insurer in case of an accident, or
• If AG REAL ESTATE or its affiliate ceases to be the data controller in respect of your personal information through the operation of a merger, acquisition or any change of control;
• in the limited circumstances described below and in article 9.

We may pass your information to our third-party service providers, agents subcontractors and other associated organizations for the purposes of completing tasks and providing services to you on our behalf (for example to send you mailings). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service. In addition, our contracts with such third party service providers require them to keep your information secure and not to use it for their own direct marketing purposes. We will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so.

9. Offensive or inappropriate content on AG REAL ESTATE websites

If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on or to AG REAL ESTATE websites, social media pages, or otherwise engage in any disruptive behaviour on any AG REAL ESTATE service, AG REAL ESTATE may remove such content.

Where AG REAL ESTATE reasonably believes that you are or may be in breach of any applicable laws, for example on hate speech, AG REAL ESTATE may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. AG REAL ESTATE would only do so in circumstances where such disclosure is permitted under applicable laws, including data protection law.

10. What if I am a user aged under 16?

If you are aged 16 or under, please get your parent/guardian’s permission before you provide any personal information to AG REAL ESTATE.

11. How long will AG REAL ESTATE keep my personal information?

We will hold your personal information on our systems only for as long as is necessary for the relevant activity, or as long as is legally or contractually set out for any relevant contract you hold with AG REAL ESTATE. If you delete your AG REAL ESTATE account, then your personal information is deleted immediately. For further information about deleting your AG REAL ESTATE account, please see article 12 below.

12. What can you do with the personal data you submitted to us?

You have the right to restrict and the right to object to the use of your personal data; the right to withdraw your consent to the use of your personal data and the right to request deletion of your personal data.

In the context of the shopping centers you can opt-out from the collection of the MAC address of your mobile device by turning off your device Bluetooth and Wi-Fi capabilities of your mobile device or by opting-out via the website of our third party service provider:

• https://pfm-footfall.com/opt-out/

In the context of some of our websites and apps of AG REAL ESTATE, these rights are all exercised and obtained by deleting your AG REAL ESTATE accounts. You can find out how to delete your accounts on the respective websites or Apps or marketplace. As explained in article 11 above, deleting your AG REAL ESTATE account will erase any personal information in your account that we have about you.

In any case, you can exercise your rights by contacting our DPO You may also adjust your communication preferences or opt out of communications at any time by clicking ‘unsubscribe’ at the bottom of any e-mail, following instructions provided in the communication or changing your preferences within your account or by sending us an e-mail.

You have the right to portability of your personal data. All personal data you directly submitted to AG REAL ESTATE, can be sent to you or any third party, at your request made directly to our DPO.

13. Can I find out what personal information AG REAL ESTATE holds about me?

Under the GDPR you have the right to access to and the right to correct the personal information AG REAL ESTATE holds. These rights can be exercised by:

• logging into your AG REAL ESTATE account regarding the information we hold about you in the context of that account;
• contacting our DPO directly, who will then use reasonable efforts consistent with our legal duty, to supply, correct or delete personal information about you that may be held on our files.

We will endeavour to provide you with access to your personal information wherever possible.

14. What if I am unhappy with the way AG REAL ESTATE is managing my personal data?

You have the right to complain to the Belgian Data Protection Authority:

• By postal mail: Belgian Data Protection Authority Rue de la Presse, 35, 1000 Bruxelles.
• By telephone:  +32 (0)2 274 48 00
• By fax: +32 (0)2 274 48 35
• By email:   contact@apd-gba.be

15. Web browser cookies

a. What is a cookie?

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (all referred to here as a “device”) web browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your web browser if your browser’s preferences allow it.

Many websites do this whenever a user visits their website in order to track online traffic flows. Similar technologies are also often used within emails to understand whether the email has been read or if any links have been clicked. In order to inform you fully, AG REAL ESTATE will ask your consent for the receipt of  cookies. However, you can change your cookie settings at any times in your web-browser (see our full Cookies Policy for more information).

On AG REAL ESTATE websites, cookies record information about your online preferences and allow us to tailor our websites to your interests.

b.  AG REAL ESTATE cookies and how to reject cookies

AG REAL ESTATE’s Cookies Policy, which contains full information about how AG REAL ESTATE uses cookies, and which explains how to control what cookies are set on your device through AG REAL ESTATE website, can be found on our website.

It is important to note that if you change your settings and block certain cookies, you will not be able to take full advantage of some features of AG REAL ESTATE services, and we might not be able to provide some features you have previously chosen to receive.

c. Other information collected from web browsers

Your web browser may also provide AG REAL ESTATE with information about your device, such as an IP address and details about the browser that you are using.

If you have any concerns about the way that we use cookies or respect your settings, please contact our DPO.

16. Do Not Track (DNT) browser setting

DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. Our websites do not currently respond to DNT requests.

17. Apps

When you download or use an AG REAL ESTATE app on your mobile device, information may be accessed from or stored to your device. Most often this is used in a similar way to a web browser cookie, such as by enabling the app to ‘remember’ you or provide you with the content you have requested.

Your web browser or device may also provide AG REAL ESTATE with information about your device, such as a device identifier or IP address. Device identifiers may be collected automatically, such as the device ID, IP address, MAC address, IMEI number and app ID (a unique identifier relating to the particular copy of the app you are running).

When you sign in to a AG REAL ESTATE app, your sign-in details may be stored securely on the device you are using, so you may in the future, if you wish to do so, access other AG REAL ESTATE ‘apps’ on the same device without needing to enter your sign-in details again.

If you have any concerns about the information which might be accessed from or stored on your device by AG REAL ESTATE, you may wish to only access AG REAL ESTATE content through a web browser and review your web browser settings.

18. Changes to AG REAL ESTATE’s Privacy Policy

This Privacy Policy may be updated from time to time so you may wish to check it each time you submit personal information to AG REAL ESTATE. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use AG REAL ESTATE websites or Apps to submit personal information to AG REAL ESTATE. You can also delete your AG REAL ESTATE account at any time – please see article 12 for details. If material changes are made to the Privacy Policy, for instance affecting how we would like to use your personal information, we will provide a more prominent notice.

19. Transferring your information outside of Europe

As part of the services offered to you through the AG REAL ESTATE websites and Apps, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to Belgium. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights as set out in this Policy continue to be protected.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

20. Contacting AG REAL ESTATE about this Privacy Policy

If you have any questions or comments about this Privacy Policy please contact our DPO, whose full details are listed in article 1.