Privacyverklaring Propertytraders.com

Privacy statement Beleggingspanden.nl B.V.

Six Seasons B.V. and its affiliated companies, including Beleggingspanden.nl B.V. (“PropertyTraders.com”, “we”, “us” or “our”) respect your privacy. This privacy statement describes how we handle your personal data that we obtain and use in connection with the products and services we offer as a data controller, including through our websites, apps, and other domains. This privacy statement also describes how you can exercise your legal rights. This privacy statement applies to: https://www.propertytraders.com/.

We may update this privacy statement from time to time. The last changes were made on January 20, 2023.

About us

We are the data controller for the processing of your personal data and the use of your personal data described in this privacy statement. Beleggingspanden.nl B.V. is a private company with limited liability, located at Bos en Lommerplantsoen 1, 1055AA in Amsterdam, registered in the Commercial Register of the Chamber of Commerce under number 30210797.

If you have any questions or comments about this privacy statement or the processing of your personal data by us, please feel free to contact us. Our contact details are listed at the bottom of this privacy statement.

The way we collect your personal data

We may collect or obtain your personal data in the following way(s):

  • From yourself. When you make information available to us, such as in connection with an account for our services or through an inquiry form. Or when you contact us or buy or use our products or services. During this contact, you may be asked to provide certain personal data, such as contact information when you request information or contact and payment information when you order products or services. When we ask for your (personal) data, we may indicate which data fields are optional, and which are mandatory. If you do not provide us with the mandatory information, we may not be able to (fully) fulfill your request
  • From third parties, for example other Six Seasons entities, advertising networks, recruitment agencies or other partners. We will always ask this third party to confirm that making the data available to us is in accordance with the law, for example because you have given your consent for such transfer of data.
  • By your use of our products or services, for example by using cookies and similar technologies. For more information about our use of cookies, please see our cookie statement: https://www.propertytraders.com/cookie-statement.
  • Using publicly accessible sources, such as the trade register of the Chamber of Commerce.

Personal data we process, and the purposes for which

What personal data we process depends on the purpose for which we collect and use it, for example, the provision of services and products. Where possible, we will pseudonymize or anonymize your personal data. You are not always required to provide your personal data. Our products or services may not function as well if you decide not to provide any or all of your personal data. In certain situations, however, providing personal data is required, such as when entering into an agreement requiring us to provide goods or services. We do not process special categories of personal data, such as health data or a BSN.

We may process your personal data for the following purposes:

  • to provide the agreed services or products, for example in the context of selling an advertisement on our website, the message service with the offer of investment properties and facilitating contact between you and the advertiser or person interested in an investment property. Your information will only be shared with the advertiser or interested party when they themselves send or receive a message through PropertyTraders.com. This is done for the performance of our service;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; copy of identification document without BSN; (business) address details; (business) contact details, such as email address and phone number; bank and payment details; account details; transaction details (e.g. purchase history); photo and video material; other data you (actively or voluntarily) provide to us, such as CVs; location data; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to process payments for products or services offered;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and phone number; banking and payment details; account details; transaction details (e.g. purchase history); photo and video material; other data you (actively or voluntarily) provide to us, such as CVs; location data; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to process your complaint or request, for example to send you the information you have requested or to establish your identity;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and telephone number.  

  • to process your application for a position at PropertyTraders.com or another entity of Six Seasons B.V.;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and telephone number; banking and payment details; account details; transaction details (e.g. purchase history); photo and video material; other data you (actively or voluntarily) provide to us, such as CVs; location details; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to create and manage your account with PropertyTraders.com (if applicable);

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and telephone number; bank and payment details; account details; transaction details (e.g. purchase history); photo and video material; other data you (actively or voluntarily) provide to us, such as CVs; location details; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to ask you to participate in surveys and to manage the result of surveys in which you have participated;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and telephone number; bank and payment details; account details; transaction details (e.g. purchase history); photo and video material; other data you (actively or voluntarily) provide to us, such as CVs; location data; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • for (tele)marketing purposes, including by sending you information or newsletters about new features or new products or services that may be relevant to you based on Six Seasons' products and services that you have previously purchased;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and phone number; banking and payment details; account details; transaction details (e.g., purchase history); photo and video footage; other information that you (actively or voluntarily) provide to us, such as resumes; location information; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to analyze your use of our products and services for quality control, product development and marketing purposes;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and phone number; banking and payment details; account details; transaction details (e.g., purchase history); photo and video footage; other data you (actively or voluntarily) provide to us, such as resumes; location data; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to improve your online experience on our services, including to provide you with personalized recommendations;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and phone number; banking and payment details; account details; transaction details (e.g., purchase history); photo and video footage; other data you (actively or voluntarily) provide to us, such as resumes; location data; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to secure and protect our systems and websites, for example by testing our information security measures;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and phone number; banking and payment details; account details; transaction details (e.g. purchase history); photo and video material; other data that you (actively or voluntarily) provide to us, such as CVs; location data; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to comply with legal obligations, such as statutory retention periods and record-keeping requirements;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and phone number; banking and payment details; account details; transaction details (e.g. purchase history); photo and video material; other data that you (actively or voluntarily) provide to us, such as CVs; location data; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • to prevent and combat fraud and unlawful conduct;

We may process the following personal data for this purpose: First and last name, title, job title and subtitle; gender and date of birth; (business) address details; (business) contact details, such as email address and phone number; banking and payment details; account details; transaction details (e.g. purchase history); photo and video material; other data that you (actively or voluntarily) provide to us, such as CVs; location data; URL, IP address, browser type and language, and the date and time of your visit to our website(s); marketing preferences.

  • for other purposes disclosed to you in advance.

We will then also inform you which personal data we will process for this purpose.

Basis for processing.

We will process your personal data in accordance with applicable law, including the General Data Protection Regulation (GDPR). When we process your personal data, such processing will be based on one of the following bases:

  • your consent. You can withdraw your consent at any time. This does not affect our past use of your personal data;
  • the performance of an agreement to which you are a party (or to take steps at your request prior to the conclusion of an agreement);
  • the fulfillment of a legal obligation to which PropertyTraders.com is subject, such as tax law; or
  • the legitimate interests of PropertyTraders.com or a third party, for example studies to improve our services. When applying this basis, we weigh your privacy interest against our legitimate interest.

Sharing personal data with third parties

We may share your personal data within our group of companies, for example with other entities that fall under Six Seasons B.V.. To this end, PropertyTraders.com uses a central database to store its data. 

We may use third parties, processors, who perform certain work on our behalf and under our responsibility, such as Google Analytics, IT providers offering storage services, collection agencies, administrative offices and other service providers. If and to the extent that these third parties thereby process your personal data on our behalf, we will enter into a processor agreement with these third parties to ensure the careful processing of your personal data and protection of your privacy rights.

We may also share your personal data with commercial partners, such as advertisers on the PropertyTraders.com website. This may involve the use of cookies (see our Cookie Policy on cookies). Your personal data may also be provided to sellers and (potential) buyers of the investment properties and their contact persons, to the extent you have given permission or instructed us to do so. If a sale is concluded, we also share your personal data, if necessary, with other parties involved in its execution, such as the notary.

We also provide your personal data to regulators or tax and investigation authorities, but only if we are legally obliged to do so.

We do not sell your personal data to third parties for the purpose of offering you services and products from those parties.

Links to websites and services of others

Our services may contain hyperlinks to websites, applications or other products and services of third parties. The processing of personal data by third parties is subject to the privacy statement of those third parties. Beleggingspanden.nl is not responsible for the content of these websites or other services of third parties and the processing of personal data by these third parties.

International data transfer

We process your personal data primarily in the European Economic Area (“EEA”). We may also transfer your personal data to parties located in countries outside the EEA. Where the countries in which these parties are based do not provide sufficient safeguards for the protection of personal data, we will only do so if we have taken additional measures to properly protect your personal data in accordance with the AVG. For this purpose, we may use, for example, contracts approved by the European Commission for the transfer of data to such countries. Standard contracts for such transfers can be found on the European Commission's website. Upon request, we can send you a copy of such agreements where we use standard contracts.

Retention period

We will not retain your personal data for longer than necessary to fulfill the purposes stated in this privacy statement, unless we need to retain your personal data longer to comply with legal retention periods applicable to us. For example, Spring is required to keep billing and payment information for seven years under tax law. Spring is also obliged under the Prevention of Money Laundering and Financing of Terrorism Act (Wwft) to retain (personal) data arising from a client investigation for five years after the business relationship or transaction has ended.

In some cases we anonymize your personal data, for example to identify trends. Anonymized data cannot be traced back to you. We may use and retain anonymized data indefinitely.

Security of your personal data

We ensure that your personal data is treated confidentially and with care. We employ appropriate technical and organizational measures to prevent the loss of personal data or unlawful processing (such as disclosure or unauthorized access). For example, we encrypt personal data, we only use processing systems that can guarantee us confidentiality, integrity, availability and resilience, we have measures in place to restore access to personal data in a timely manner in the event of a technical incident, we have established a procedure to test, assess and evaluate effectiveness of technical and organizational measures to secure processing, and only authorized personnel have access to your personal data to prevent loss and/or unauthorized use or processing.

We have established procedures to deal with data breaches, such as unauthorized access to or use of personal data. We will notify you and the appropriate regulator of a data breach if we are required to do so by law.

Your rights and opt-out

You have the following rights regarding your personal data:

  • Right to access, correct, restrict or delete personal data. You may at any time obtain from us access to the data about you that we process. You can then request us to amend or supplement this data to the extent that the data we process is incomplete or incorrect. In many cases, the account management system also allows you to update the information you have provided yourself or delete your account. Under circumstances, the AVG also offers the possibility of having personal data deleted. We assess whether a request to this effect is feasible, since in some cases we have to retain the data you have provided, for example due to a legal obligation. You can also request us to restrict data processing, including in cases where deletion is not feasible. In these cases, we must temporarily stop data processing.
  • Right to object. You may object to our use of your personal data to the extent that we base the processing on our legitimate interest, including the processing of your personal data for marketing purposes. To the extent processing is based on consent, we inform you that you can always withdraw your given consent.
  • Right to Data Portability. In certain cases, you can receive the personal data you have provided to us in a structured, common and machine-readable format or have it transferred (if technically possible) to another party. This right applies only to automated information for which you have initially given us permission to use it, or in the event that we have used the information to perform a contract with you.
  • Complaint Right. Please contact us with any complaints using the contact information at the bottom of this privacy statement. You also have the right to file a complaint with the regulator, the Personal Data Authority, or any competent supervisory authority in your country.
  • Right to withdraw consent. If the processing of your data is based on your consent, you have the right to withdraw that consent at any time, without prejudice to the lawfulness of the processing based on the consent before its withdrawal.
  • Opt-out commercial communications. You may notify us at any time that you no longer wish to receive newsletters or other commercial communications from us via email. We will then process your notification and remove you from our mailing list.

If we process your personal data, you may exercise these rights (free of charge) by contacting us using the contact details provided at the bottom of this privacy statement. We will respond to your message within 4 weeks.

We reserve the right to refuse requests if your identity cannot be proven by you and/or we can invoke one of the exceptions mentioned in the AVG. In this case, we will inform you of the refusal.

When processing inspection, correction, deletion or restriction requests, we may ask you for additional information and documents to verify your identity. If we request a copy of your proof of identity, we remind you never to send us all the details of the document. We refer in this context to the information on the website of the Central Government.

Changes to this privacy statement

We reserve the right to make changes to this privacy statement without notifying you. We therefore recommend that you review this privacy statement from time to time.

Contact details

If you have any questions, comments or complaints about our use of your personal data or about this privacy statement, please contact us using the contact details below.

Beleggingspanden.nl B.V.

+31 (0)30 225 31 12

info@beleggingspanden.nl

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