I. INTRODUCTION

1. This privacy policy outlines how Joni Invest s.p.r.l. handles the personal data of its customers, natural persons and all other natural persons who are in contact with Joni Invest s.p.r.l. (hereafter referred to as 'you').

2. Personal data are understood to mean any form of information directly or indirectly allowing the identification of yourself as a natural person.

3. Joni Invest s.p.r.l. attaches great importance to the protection of your personal data and fully respects your privacy. Joni Invest s.p.r.l. processes and protects your personal data in a legitimate, appropriate and transparent manner.

   In processing your personal data Joni Invest s.p.r.l. obviously respects all relevant legal provisions, viz. the Act of 8 December 1992 on the Protection of Privacy and, since 25 May 2018, European regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (more commonly known as 'GDPR') as well as any other future legal provision that modifies the former.

   For more details on privacy protection please contact the Belgian Privacy Commission, as of 25 May 2018 renamed the Belgian Data Protection Authority.

4. We invite you to read the present declaration carefully in order to familiarise yourself with the policy of Joni Invest s.p.r.l..

   This declaration is updated on a regular basis. The most recent version of the declaration is available on our website. You will be informed of important changes to the declaration via the usual communication channels.

II. WHO IS THE CONTROLLER ?

5. Joni Invest s.p.r.l., with registered office at Avenue Charles Quint 305, 1083 Ganshoren is the controller of your personal data.

6. Joni Invest s.p.r.l. is also your point of contact and will answer to the Belgian Data Protection Authority as to the processing of your personal data. Joni Invest s.p.r.l. determines the purposes for which your personal data are processed as well as the means used and the processing characteristics.

7. Joni Invest s.p.r.l. can call on specialised service providers to process your personal data on behalf of Joni Invest s.p.r.l. and according to the instructions of Joni Invest s.p.r.l. in accordance with this privacy policy. Only those personal data that are strictly necessary will be passed on to these service providers (hereafter referred to as the 'processors of Joni Invest s.p.r.l.').

8. Please address all questions regarding the protection of your privacy to the manager. You can contact the manager by sending an email to [email protected].

III. WHICH CATEGORIES OF PERSONAL DATA DOES JONI INVEST S.P.R.L. PROCESS ?

9. Below you will find a list of the categories of personal data that Joni Invest s.p.r.l. can process. It is possible that other data will also be processed if they are necessary or useful for the continuation of the contractual relationship with Joni Invest s.p.r.l..

   In such cases the context in which Joni Invest s.p.r.l. obtains or processes this data is indicated. This table should be read in conjunction with the description of the purposes for which Joni Invest s.p.r.l. processes the data.

   Category	Examples	Context
   1/ Identity information of the customer / principal (seller or lessor) 2/ Identity information of prospective buyer or lessee Name, address, date and place of birth, nationality, home or mobile phone number and email address.	Name, address, date and place of birth, nationality, home or mobile phone number and email address.	This data is provided by you and processed when you make inquiries, become a customer, conclude a brokerage agreement or when you register online to use the services of Joni Invest s.p.r.l. (online), for any type of identification or use. Amongst others, this data can be acquired by reading in your identity card.
   Data on the property of the customer / principal (seller or lessor)	Title of property, urban development statement, soil certificate, inspection certificate of the electrical installation, EPC certificate, information on overcurrent sensitivity, post-intervention file, information on the heritage value.	This data is supplied by you or obtained by Joni Invest s.p.r.l. from the government or technical experts on your behalf.
   Data of the prospective lessee relating to a proposed lease	Information on occupation and employment situation, solvability, family situation, salary, etc.	This data is collected using forms and contracts filled out by you on your request.
   Additional data for the conclusion of a lease or preliminary sales agreement	National registry number	This data is supplied by you The national registry number is only used in cases where such is stipulated or required by law.
   Personal data of co-owners (or their lessees)	Name, address, date and place of birth, nationality, home or mobile phone number and email address.	This data is supplied by you as co-owner to Joni Invest s.p.r.l. when Joni Invest s.p.r.l. acts as the trustee
   Data related to the performance of trustee services.	Payments including names and account numbers, communication and references, card numbers, etc.	This data pertains to your transactions as co-owner that are coordinated by the trustee.
   Data on the transactions of Joni Invest s.p.r.l. with you	The information relating to your contacts with Joni Invest s.p.r.l. by telephone, email, fax, etc. and your interactions on the web pages regarding Joni Invest s.p.r.l., its services or its partners, on social networks, etc.	This data originates from contacts of any nature between you and Joni Invest s.p.r.l. (in case of meetings or events, subscription to a newsletter, social networks, etc.)
   Data on the customer's behaviour and preferences	Information on your behaviour and preferences regarding the use of communication and relationship channels, information on your personal choices and lifestyle, private or professional projects, hobbies, etc.	This data is the consequence of choices you have expressed or analyses performed by Joni Invest s.p.r.l. in accordance with this declaration and its legal obligations.

10. Joni Invest s.p.r.l. processes no data that reveal your race or ethnicity, your political beliefs, religious or philosophical beliefs, union membership, health or life-related data or sexual orientation, genetic or biometric data.

IV. FOR WHAT PURPOSES DOES JONI INVEST S.P.R.L. PROCESS YOUR PERSONAL DATA?

11. Joni Invest s.p.r.l. collects and processes your personal data solely for the purposes described below. Joni Invest s.p.r.l. takes care to only process data that is necessary and relevant to a specific purpose.

    Joni Invest s.p.r.l. processes your data in situations permitted by law, to wit:

    • To meet the legal obligations that Joni Invest s.p.r.l. must fulfil (12.).
    • To execute a contract concluded with you or to take certain measures on your request before the conclusion of said contract (13.).
    • To protect the legitimate interests of Joni Invest s.p.r.l., in which these interests are weighed against your fundamental rights and freedoms (14.).
    • In specific cases, with your consent, as the result of a specific and unambiguous request, preceded by clear and comprehensible information; in accordance with the law you can revoke this consent at any time (15.).

12. Legal Obligations

    Joni Invest s.p.r.l. must comply with the legislation compelling it in specific circumstances to process your personal data as part of its activities. These obligations may entail that Joni Invest s.p.r.l. must cooperate with the competent authorities and/or third parties and, possibly, supply them with certain of your personal data.

    Amongst others, this includes:

    • The obligation to contribute to the prevention of money laundering and the financing of terrorism.
    • The obligations imposed upon a trustee with respect to the management of co-ownership.
    • The obligation to respond to a formal request from the Belgian tax and judicial authorities.

    The list of legal obligations for which Joni Invest s.p.r.l. must process your data is non-exhaustive and subject to change.

13. Contractual relationships between Joni Invest s.p.r.l. and you as a customer

    In order to conclude a contract Joni Invest s.p.r.l. must sometimes acquire and process certain data in order to, amongst others:

    • Respond to your request.
    • Assist you in supplying information and when concluding the contract.
    • Follow-up on a request, evaluate suitability and assess the risks arising from a possible contract.
    • Fulfil the brokerage agreement.

    As part of current contracts or the management of contracts Joni Invest s.p.r.l. must process certain data, more specifically to meet its administrative and accounting obligations.

    Within this context your data may be forwarded within Joni Invest s.p.r.l. to several departments, including those not directly responsible for the relationship with you or the execution of a certain contract.

    More specifically Joni Invest s.p.r.l. processes your data as follows with the execution of contracts:

    • Management of current contracts / services ordered.
    • Central management and a general picture of the customers.
    • The management of your property.
    • Management of the co-ownership of which you are a co-owner.

    Joni Invest s.p.r.l. can process your personal data for additional reasons within the scope of its relationship with you and the execution of contracts.

14. Legitimate interests of Joni Invest s.p.r.l.

    Joni Invest s.p.r.l. also processes your data to protect its legitimate interests. In so doing Joni Invest s.p.r.l. strives to strike a fair balance between the necessity to process data and the respect for rights and freedoms, including the protection of your privacy.

    Amongst others personal data are processed with a view to:

    • Personalising the services of Joni Invest s.p.r.l..
    • Improving the quality of the service provided to you through:
      • The evaluation and improvement of processes including campaigns, simulations and sales through the use of different means such as statistical analysis, satisfaction surveys and various other search methods.
      • The improvement of existing products or products under development by Joni Invest s.p.r.l. based on customer surveys by Joni Invest s.p.r.l., statistics, tests and customer feedback on social networks (Twitter, Facebook) coupled with Joni Invest s.p.r.l..

    • The supervision of activities by Joni Invest s.p.r.l. including the size of the turnover, the number of meetings at our branches, the number of calls and visits to the website of Joni Invest s.p.r.l., the nature of the questions asked by customers, etc.
    • The preparation of studies and statistics that use anonymisation and pseudonymisation of those involved.
    • The training of our staff through the use of practical examples by way of illustration, including the recording of certain telephone conversations.
    • The use of cookies to improve the user experience of the website visitors. More information on the use of cookies and the possibilities to limit the use of cookies and remove them can be found under article IX. Cookie Policy
    • The storage of evidence (archives).
    • The determination, exercise, defence and retention of the rights of Joni Invest s.p.r.l. or all the individuals it represents, for instance in case of recovery procedures or disputes.

15. Specific legitimate interest of Joni Invest s.p.r.l.: direct marketing purposes

    Joni Invest s.p.r.l. performs a customer segmentation - specifically in accordance with your needs - to offer you, for instance, suitable properties and/or services that correspond with your professional and personal situation. To this end, Joni Invest s.p.r.l. can, amongst others:

    • Assess the services you are already using as well as your sociodemographic data (age, composition of your household, revenue, etc.).
    • Analyse your behaviour via multiple channels (visits/meetings, emails, website visits, messages via our website), derive your preferences and, as a result, personalise the information and the web pages you have visited.
    • Adjust the ads on the web pages so they cater to the interests you have shown through your behaviour on our website, social networks, in a branch or elsewhere (e.g. at events where Joni Invest s.p.r.l. was present).
    • Simplify the completion of forms by filling out certain fields in advance with known data and ask you to verify their accuracy and make adjustments if necessary.
    • Assess the key moments at which certain services would best suit you.
    • Send you personalised ads by phone or regular mail.

    Joni Invest s.p.r.l. can process all your personal electronic contact information (viz. your mobile number and email address) to send you personal information, advertisements or proposals via direct marketing or newsletters. In this case Joni Invest s.p.r.l. must obtain your express consent beforehand.

    By accepting this privacy policy you are giving permission for the processing of your personal data for direct marketing purposes.

V. WITH WHOM DOES JONI INVEST S.P.R.L. SHARE YOUR PERSONAL DATA?

16. Joni Invest s.p.r.l. treats your personal data with the utmost care and only shares your data to offer you the best possible service in the execution of its assignment.

    Joni Invest s.p.r.l. can forward your data to other entities within its group, both at home and abroad, viz. the other entities of the group that assist Joni Invest s.p.r.l. in the execution, management and control of the activities including reporting, support and computer security or the offering of specific products and services.

17. In some cases Joni Invest s.p.r.l. is obligated by law to share your data with third parties, including:

    • Public or supervisory authorities when there is a legal obligation to supply information
    • Judicial authorities: at their explicit request

    Joni Invest s.p.r.l. also transfers your data to specific service providers to help with:

    • The design and maintenance of computer equipment and internet applications.
    • The offering of publicity and communication services, including online and social network providers.
    • The preparation of reports and statistics, the printing of documents and the design of products or services.
    • The commercialisation of its activities, the organisation of events and customer communications management.

    Joni Invest s.p.r.l. must also share your data with the online and social network providers it uses to offer publicity services.

    Also, your personal data may be shared with bailiffs or lawyers within the scope of legal proceedings.

    In the above-mentioned cases Joni Invest s.p.r.l. will take care to restrict the access of third parties to those personal data that is necessary to perform the required specific tasks. Joni Invest s.p.r.l. will also make sure that third parties commit themselves to using the personal data in a safe and confidential manner and in accordance with the instructions of Joni Invest s.p.r.l. and its data protection policy.

18. Joni Invest s.p.r.l. stores your data within the EEA. As a result, no data is transferred to countries outside the EEA.

VI. HOW LONG IS YOUR PERSONAL DATA STORED?

19. Joni Invest s.p.r.l. will not store your personal data any longer than strictly necessary to fulfil the purposes for which the data were gathered.

    This period is linked to the legal and tax obligations of Joni Invest s.p.r.l., as well as the legal necessity to store your data beyond the storage period as evidence or to react to information requests from competent authorities e.g.:

    • 10 years within the scope of the anti-money laundering legislation
    • 10 years within the scope of the contractual liability of Joni Invest s.p.r.l.
    • 7 years for the accounting and supporting documents of the co-owners' associations in light of the exercise of Joni Invest s.p.r.l.'s duties as a trustee.

    Outside these periods your personal data is either removed or anonymised.

VII. HOW IS YOUR PERSONAL DATA PROTECTED?

20. Joni Invest s.p.r.l. implements strict standards to protect the personal data under its control against unauthorised or illegitimate processing and against inadvertent loss, destruction or damage.

    Joni Invest s.p.r.l. implements measures of a technical and organisational nature such as encryption, antivirus software, firewalls, access control and a strict selection of staff and suppliers to prevent and detect unauthorised access, loss or disclosure of your personal data.

    In the unlikely and unfortunate event that your personal data under the control of Joni Invest s.p.r.l. is compromised by a breach of our information security, Joni Invest s.p.r.l. will immediately undertake the necessary actions to determine the source of the breach and take adequate measures to keep this from happening again in the future. If necessary, Joni Invest s.p.r.l. will inform you of the incident in compliance with the applicable legislation.

VIII. WHAT ARE YOUR RIGHTS WITH THE PROCESSING OF YOUR PERSONAL DATA?

21. The right of access, the right to rectification, restriction, erasure, the right to data portability and the right to object

    For the above-mentioned purposes you have:

    • The right of access to your personal data at Joni Invest s.p.r.l.. This means that you can ask Joni Invest s.p.r.l. whether it processes your personal data, for which purposes it is processed, which categories of data are processed and with whom the data is shared.
    • The right of rectification if you find that your personal data is incorrect or incomplete.
    • The right to restriction if e.g. you contest the accuracy of your personal data and this for a period enabling Joni Invest s.p.r.l. to verify this.
    • The right to erasure of your personal data. When your contract with Joni Invest s.p.r.l. comes to an end you can ask Joni Invest s.p.r.l. to delete your personal data if it is no longer needed for the purposes for which it was originally collected. You can also at all times request erasure of the personal data processed by Joni Invest s.p.r.l. on the basis of your consent (unless Joni Invest s.p.r.l. has a different legal ground for the processing) or on the basis of the legitimate interest of Joni Invest s.p.r.l. (unless there are compelling predominant legitimate grounds for the processing). Joni Invest s.p.r.l. can at any rate maintain your personal data if such is required for the purposes of proof within the scope of a legal claim.
    • The right to portability of the data you yourself have supplied to Joni Invest s.p.r.l. if your personal data is processed on the basis of an agreement or on the basis of your consent to send electronic communications and if this personal data is processed by automated means. In exercising this right you can request that Joni Invest s.p.r.l. forward your personal data to yourself or directly to another controller where technically feasible for Joni Invest s.p.r.l..
    • The right to object to the processing of your data for the purposes listed under article 14. In this case, Joni Invest s.p.r.l. will no longer process your personal data unless Joni Invest s.p.r.l. demonstrates compelling legitimate grounds for the processing that override your interests, rights and freedoms or unless there are grounds related to the establishment, exercise or defence of a legal claim.
    • The right to object to direct marketing. Article 15 asked for your consent to process your electronic contact details and use them to send you commercial information, publicity or personal proposals (via direct marketing actions or electronic newsletters). This applies specifically to communications to your mobile number and email address. You have the right to object against the processing of your personal data for electronic direct marketing purposes and to oppose the future reception of such publicity. However, the exercise of this right cannot withhold Joni Invest s.p.r.l. from contacting you for a different purpose, including a legal obligation or the execution of the contract, in accordance with this declaration.

22. The right to lodge a complaint

    You can exercise your rights by sending a dated request in writing by regular mail, duly signed and with a copy of your identity card, to Joni Invest s.p.r.l., Avenue Charles Quint 305, 1083 Ganshoren, or via email to [email protected].

    You can also lodge a complaint with the privacy commission via regular mail to Drukpersstraat 15, 1000 Brussels, or via email at [email protected], or by phone at +32 2 274 48 00.

IX. COOKIE POLICY

23. When visiting a website or using an application or app of Joni Invest s.p.r.l. files and technologies may be used that store information on your end device (PC, laptop, smartphone, tablet, etc.) or that access information already stored on your end device. These files and technologies may consist of cookies, web beacons, log files, settings and information on your end device and such.

24. The website of Joni Invest s.p.r.l. uses the following categories of cookies:

    • Functional cookies: These cookies enable the basic functions of the website. They guarantee the proper technical operation of the website and enhance its user-friendliness.
    • Analytical cookies: These cookies enable us to analyse the use of the site so we can measure and improve its performance (e.g. Google Analytics).
    • Third-party cookies: This website includes Facebook functions. Joni Invest s.p.r.l. has no influence on third-party cookies and the data these cookies process. Read the Facebook privacy declaration to find out what they do with the (personal) data that is processed via these cookies.

25. The cookies, web beacons, log files and other files and technologies used by Joni Invest s.p.r.l. can be disabled to the extent and in the way described below. Removing and/or refusing cookies, web beacons, log files and other files and technologies may impact the usability of the website.

    The mode of operation depends on your browser and can be consulted by clicking on the links below.

    • Google Chrome: Click here
    • Internet Explorer: Click here
    • Firefox/Mozilla: Click here
    • Safari: Click here
    • Opera: Click here