Protecting your personal data is very important to us. We are fully committed to respecting all applicable laws and regulations on the protection of personal data, including, but not limited to, the General Data Protection Regulation (GDPR).

This Privacy Notice explains which information we may process about you, how we use such information, and with whom we share it.

1. Who are we?

We are Spotable BV, a company with registered office at Lentedreef 4, 8520 Kuurne, Belgium, and registered in the Belgian Crossroads Bank for Enterprises under number BE 1008.603.030.

We are responsible for determining why and how your personal data is processed and therefore act as the data controller for such processing activities.

Contact details

• Address: Lentedreef 4, 8520 Kuurne, Belgium
• Email: sebastien@spotable.be
• Telephone: +32 479 805 919

2. Which personal data do we collect and how do we use it?

(i) Property data processed when a real property is listed (end users)

When a real property is listed on a public real estate website, we automatically collect property-related data using a technique called web scraping.

The collected data may include the following information, some of which may constitute personal data:

• Property information: sold date, property type, price
• Building details: EPC score, plot size
• Outdoor features: pool presence, garden area
• Indoor features: internet connection presence

We only collect data relating to real property. We do not collect personal data relating to the property owner other than the data linked to the real property itself.

Purpose and legal basis

We process this property data based on our legitimate interest in efficiently linking sold properties to suppliers and or service providers who may offer relevant products or services to new property owners. This enables suppliers to send postal marketing messages only.

Because:

• we only facilitate postal marketing,
• we do not process any additional personal data,
• and the marketing is relevant to a recently purchased property,

we believe this processing does not disproportionately interfere with your right to privacy.

Further information on the balancing test performed can be found in our Legitimate Interest Assessment, available upon request.

Opt-out

You may opt out of our data processing activities at any time by emailing sebastien@spotable.be.

You may also opt out of receiving postal marketing more generally by registering your address on the Robinson List (Robinson Lijst).

(ii) Personal data processed when you buy services from us (B2B clients)

When your company purchases services from us, we may process the following personal data about you as a company contact:

• Name and surname
• Company name
• Job title
• Address
• Email address
• (Mobile) phone number

Purposes and legal bases

We process this data exclusively for the following purposes:

1. Project execution and communication
   Necessary to perform the contract concluded between us and your company.
2. Follow-up and future collaboration
   Based on your consent or our legitimate interest where we reasonably believe we can assist your company with similar future projects.
3. Administrative and financial processing
   Including account creation, invoicing, and payment follow-up, necessary to execute the contract.

Your personal data will not be used for any other purpose. If you do not provide the required information, we may be unable to provide our services.

(iii) Personal data processed when you contact us via our website

When you use the contact form on our website, we collect the following personal data:

• Name and surname
• Email address
• Telephone number
• Company
• Message

This information is required to allow us to respond to your request. By submitting the contact form, you consent to us contacting you using the provided data.

We may also use cookies and social media plugins on our website to optimise user experience. For more information, please consult our Cookie Notice.

3. With whom do we share your data?

We share property data related to a specific property with our B2B clients as part of our services. Once received, these clients act as independent data controllers. We encourage you to consult their respective privacy notices for further information.

Your personal data may also be shared with external service providers acting as data processors on our behalf, such as IT providers. Appropriate data processing agreements are in place to ensure adequate protection.

Your data may also be shared with other group companies.

We do not share personal data with third parties unless legally required, for example due to statutory obligations or court or government orders.

4. Are your data transferred abroad?

In principle, personal data is not transferred outside the European Economic Area (EEA).

If such transfers become necessary, we will ensure appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission or your explicit consent.

5. How long do we keep your personal data?

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected.

Retention periods

• Property data: retained for 24 months after collection or until you opt out
• B2B customer data: retained for 10 years following the end of the customer relationship

Data may be retained longer where legally required or necessary for legal claims.

6. How are your personal data secured?

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, misuse, alteration, or disclosure. These measures include restricted access policies and strong password protection.

7. Your rights

Under the GDPR, you may have the right to:

• Access your personal data
• Request deletion of your data
• Request rectification or completion
• Request data portability
• Restrict processing
• Object to processing

To exercise these rights, contact us at sebastien@spotable.be. We will respond within four weeks of receiving your request.

8. Questions or complaints

If you have any questions or complaints about our data processing, please contact us at sebastien@spotable.be.

You may also lodge a complaint with the Belgian Data Protection Authority:

Data Protection Authority
Rue de la Presse 35
1000 Brussels, Belgium
Tel: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
Email: contact@apd-gba.be
Website: https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte

9. Applicable law

This Privacy Notice is governed by and interpreted in accordance with Belgian law.

10. Amendments

We may amend this Privacy Notice from time to time without prior notice. The updated version will apply from your next visit to the website. Please consult the latest version regularly.

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