1 Data controller and contact
O.T. Projects SRL, under the name RealtyCare, is responsible for the processing of the data described in this charter when it determines the purposes and means of the processing. It can also act as a subcontractor within the specific framework of a management mandate; this situation is governed by the contractual annex reproduced in chapter 5.
Privacy contact: ot@realtycare.be – Rue de la Borne 14 B03, 1080 Brussels, Belgium.
2 Persons and activities concerned
The charter concerns in particular visitors to the site, prospects, customers, owners, lessors, tenants, candidate tenants, sellers, buyers, candidate buyers, agents, beneficial owners, suppliers, partners and contact persons. It covers brokerage, rental, sales, research, estimation, rental management, technical management, commercial relations and site administration activities.
3 Data processed
- identity, contact details, language, signature and quality of contact;
- data relating to the property, real rights, rental, urban planning, technical, energy and financial situation;
- search criteria, visits, exchanges, offers, applications and decisions;
- contractual, accounting, banking data, invoicing and payment;
- data necessary to identify the client, agent and beneficial owner, risk assessment and compliance with anti-money laundering obligations;
- solvency data or proof of rental application, only to the extent relevant and legitimate;
- technical data of the site, IP address, security logs and cookie choices;
- communication preferences and history
requests.
RealtyCare does not request excessive data. Sensitive documents should only be transmitted when necessary and through the indicated channel.
4 Purposes and legal bases
| Purpose | Main legal basis |
| Respond to a request and prepare a mission | Pre-contractual measures or legitimate interest to respond |
| Execute a brokerage or management mandate | Execution of the contract |
| Organize visits, applications, offers and negotiations | Performance of the contract or pre-contractual measures |
| Identification, vigilance, accounting and professional obligations | Legal obligation |
| Security, fraud prevention and advocacy | Legitimate interest |
| Communication to existing customers on similar services | Legitimate interest, with right of opposition |
| Newsletter or prospecting when consent is required | Consent, withdrawable at any time |
| Cookies not strictly necessary | Consent |
5 Brokerage-specific data
In a brokerage mission, RealtyCare processes the data necessary for authorized prospecting, estimation, constitution and publication of the advertisement, organization of visits, analysis of applications or offers, negotiation, preparation and monitoring of documents, proof of due diligence and compliance with its legal and ethical obligations.
The data of a candidate or interested party may be communicated to the seller, the lessor or his representative to the extent necessary for the examination of the offer or application. RealtyCare avoids transmitting a complete document when limited information is sufficient. A final decision rests with the seller or lessor, subject to compliance with applicable law and the prohibition of discrimination.
6 Data sources
The data is obtained from the data subject, the client, his agent, the parties involved in the file, from legitimate public sources such as the ECB or registers accessible in accordance with the law, as well as from professional partners when this communication is authorized.
7 Recipients
Depending on the file, the data may be accessible to authorized members of RealtyCare, to the owner, seller, lessor or candidate concerned, to notaries, experts, insurers, accountants, IT service providers, photographers, real estate platforms, entrepreneurs, administrations, control authorities and other professionals necessary for the mission. Each recipient only receives the data useful for their intervention.
8 Preservation
The data is kept for the period necessary for the purpose concerned, then for the deadlines imposed by legal, professional, accounting, tax, anti-money laundering and proof obligations. The data in a contractual file is in principle kept until ten years after the end of the relationship when this period is necessary. Prospects without a contractual relationship are subject to a shorter period, set in the internal retention register. Consent and cookie choices are kept for the period necessary for their proof.
9 Transfers outside the European Economic Area
If a service provider processes data outside the European Economic Area, RealtyCare ensures the existence of a mechanism recognized by the GDPR, such as an adequacy decision or standard contractual clauses, and puts in place the necessary additional guarantees. Information can be requested from the contact address.
10 Security and data breach
RealtyCare implements technical and organizational measures proportionate to the risks, including access management, confidentiality, safeguarding, traceability and awareness. In the event of a violation presenting a risk, RealtyCare applies the obligations of notification to the Data Protection Authority and, where applicable, of informing the persons concerned.
11 Your rights
Under the conditions of the GDPR, the data subject may request access, rectification, erasure, limitation, portability and opposition, in particular to direct prospecting. She can withdraw her consent without affecting previous treatments. RealtyCare may request proportionate proof of identity and responds in principle within one month, subject to extensions provided for by the GDPR.
A request can be sent to ot@realtycare.be. A complaint can be lodged with the Data Protection Authority, rue de la Presse 35, 1000 Brussels – www.autoriteprotectiondonnees.be.
12 Mandatory nature of data and automated decisions
Certain data is necessary to respond to a request, conclude or perform a contract or comply with a legal obligation. Otherwise, RealtyCare may not be able to process the file. RealtyCare does not make decisions producing legal effects exclusively on the basis of automated processing, unless specific information is provided in accordance with the law.
13 Update
This charter can be adapted. The date of its last update is indicated at the top of the document. A substantial modification is indicated by an appropriate means.