Privacy notice

LAST UPDATED: May 2024

The Woluwe Shopping Center is owned and exploited by Eurocommercial Properties Belgium S.A. (the “Company,” “we,” or “us”). When you visit the Woluwe Shopping Center, make use of our services or otherwise interact with us in the context of our shopping center (collectively, we refer to these as our “Services”), we may collect and use information that identifies you as an individual or relates to you as an identifiable individual (“Personal Information”). This Privacy Notice describes our processing practices of Personal Information in the context of our Services.

If you are a tenant of the Woluwe Shopping Center, please refer to our separate ECP Connect Privacy Notice. If you are a stakeholder or press contact, please refer to Eurocommercial N.V.’s Privacy Notice.

COLLECTION AND PROCESSING OF PERSONAL INFORMATION

How we collect Personal Information

We collect Personal Information for various purposes and in various contexts as part of our Services (see descriptions in the table below).

Optional versus mandatory Personal Information fields

Certain Personal Information elements are necessary in order to provide you with a requested Service, as detailed and explained in the tables below where we discuss the specific purposes for which we process Personal Information. Any such necessary fields will always be marked “required” or “mandatory”. Alongside these required fields, you will also have the possibility to share Personal Information that is not necessary for the Services, which will be marked as “optional”. When you choose to share Personal Information by completing optional fields, we will use this information to get to know you better and to personalize our interactions with you, as described in “Relationship building and personalization” below. Your choice not to provide optional Personal Information in each given instance will not affect your ability to receive the requested Service.

If you disclose any Personal Information relating to other people to us, such as of your family members, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

Events

Purpose

Personal Information

Legal Basis

Retention Period

Sources

Contest management.

We offer various contests at our shopping center that you may choose to participate in. We ask you to provide Personal Information so we can administer your participation.

We collect the following necessary information to provide you with our Service:

First and last name,
Phone number and/or email
Communication preferences

We process the required Personal Information in order to administer your participation in the contest. We rely on the legal basis of “performance of a contract.”

We retain your Personal Information until the contest has ended.

We receive the Personal Information directly from you.

Animation and Event management.

Woluwe Shopping regularly organizes events at the shopping center. For certain events, we will ask you to sign up to participate. In this context, we will collect certain Personal Information from you to process your participation in the event.

We collect the following necessary information to provide you with our Service:

First and last name
Email and/or phone number
Type of activity
Date and place of activity
Communication preferences

We process the required Personal Information in order to register your participation in the event. We rely on the legal basis of “performance of a contract.”

We retain your Personal Information until the event has ended.

We receive the Personal Information directly from you.

Loyalty Program

Purpose	Personal Information	Legal Basis	Retention Period	Sources
Loyalty program management. We offer a loyalty program that you can choose to participate in. As part of the loyalty program, we will send you personalized offers and allow you to benefit from various exclusive services and offers. As a member of our loyalty program, we would like to know you better so you can make the most use of your membership. We collect your Personal Information to provide you with all the benefits that come with being a member.	We collect the following necessary information to provide you with our Service: Account credentials First and last name Phone number Email address Zip code Gender Shopping history and/or behavior (e.g., coupon usage) Marketing or communication preferences You may optionally also provide us with additional information so that we can further personalize our Services and (marketing) communications with you, as described in “Relationship building and personalization”.	We process the required Personal Information in order to administer your participation in the loyalty program. We rely on the legal basis of “performance of a contract.” We rely on your consent to send you marketing communications, and to personalize our interactions with you.	We retain your Personal Information for as long as you are a loyalty program member.	We receive the Personal Information directly from you or through your interactions with our Services or website.

Purpose

Personal Information

Legal Basis

Retention Period

Sources

Loyalty program management.

We offer a loyalty program that you can choose to participate in. As part of the loyalty program, we will send you personalized offers and allow you to benefit from various exclusive services and offers. As a member of our loyalty program, we would like to know you better so you can make the most use of your membership. We collect your Personal Information to provide you with all the benefits that come with being a member.

We collect the following necessary information to provide you with our Service:

Account credentials
First and last name
Phone number
Email address
Zip code
Gender
Shopping history and/or behavior (e.g., coupon usage)
Marketing or communication preferences

You may optionally also provide us with additional information so that we can further personalize our Services and (marketing) communications with you, as described in “Relationship building and personalization”.

We process the required Personal Information in order to administer your participation in the loyalty program. We rely on the legal basis of “performance of a contract.” We rely on your consent to send you marketing communications, and to personalize our interactions with you.

We retain your Personal Information for as long as you are a loyalty program member.

We receive the Personal Information directly from you or through your interactions with our Services or website.

WiFi Connection

Purpose	Personal Information	Legal Basis	Retention Period	Sources
Management of WiFi connection We offer free WiFi to all of our visitors at the shopping center. We do request that you register for your connection to ensure the security of our WiFi network. We will also process your Personal Information to facilitate future connections to the WiFi, for example by prefilling certain fields when you try to connect with your email address.	We collect the following necessary information to provide you with our Service: First name and last name Email address	We rely on our legitimate interest to ensure the security and appropriate use of the WiFi connection, and to improve user experience.	We retain the Personal Information for 12 months following the date of your last interaction with us.	We receive the Personal Information directly from you.

Purpose

Personal Information

Legal Basis

Retention Period

Sources

Management of WiFi connection

We offer free WiFi to all of our visitors at the shopping center. We do request that you register for your connection to ensure the security of our WiFi network.

We will also process your Personal Information to facilitate future connections to the WiFi, for example by prefilling certain fields when you try to connect with your email address.

We collect the following necessary information to provide you with our Service:

First name and last name
Email address

We rely on our legitimate interest to ensure the security and appropriate use of the WiFi connection, and to improve user experience.

We retain the Personal Information for 12 months following the date of your last interaction with us.

We receive the Personal Information directly from you.

Customer Services

Purpose	Personal Information	Legal Basis	Retention Period	Sources
Customer service We will process your Personal Information when you contact us with requests for support, complaints or questions. This includes when you contact us through the contact form on our website.	We collect Personal Information as needed to process your request, complaint or question. First and last name Email Phone number Content of your message	We rely on our legitimate interest to respond to questions or complaints. If you request a specific service from us, we will rely on the performance of the contract to process Personal Information needed to provide you with such service. If you submit a request on the basis of a law (such as an access request based on your rights under European data protection law), we will process your Personal Information as needed to comply with our legal obligation to respond and process your request.	We retain your Personal Information for as long as needed to process your request, complaint or question.	We receive the Personal Information directly from you.
Communicating important changes / Service messages In certain situations we may need to contact you directly to communicate administrative information with you. This may include important information regarding our relationship with you, our Services, any changes to our terms, conditions, policies and procedures, and/or other administrative information.	We use your first and last name and at least one contact method to contact you. Depending on the content of the communications, we may also process other Personal Information related to you for this purpose.	We rely on our legitimate interest, such as to ensure our Services are used in accordance with our terms, conditions, and policies. We rely on the performance of contract, where the communication relates to our website Terms of Use. In certain instances we may also have a legal obligation to inform you of material changes to our Terms of Use or Privacy Notice (e.g., in case of mergers, acquisitions and other reorganizations and restructurings of our business).	We retain your Personal Information for this purpose as long as you have a relationship with us (e.g., as long as you are a loyalty member or receive marketing communications from us).	N/A

Purpose

Personal Information

Legal Basis

Retention Period

Sources

Customer service

We will process your Personal Information when you contact us with requests for support, complaints or questions. This includes when you contact us through the contact form on our website.

We collect Personal Information as needed to process your request, complaint or question.

First and last name
Email
Phone number
Content of your message

We rely on our legitimate interest to respond to questions or complaints.

If you request a specific service from us, we will rely on the performance of the contract to process Personal Information needed to provide you with such service.

If you submit a request on the basis of a law (such as an access request based on your rights under European data protection law), we will process your Personal Information as needed to comply with our legal obligation to respond and process your request.

We retain your Personal Information for as long as needed to process your request, complaint or question.

We receive the Personal Information directly from you.

Communicating important changes / Service messages

In certain situations we may need to contact you directly to communicate administrative information with you. This may include important information regarding our relationship with you, our Services, any changes to our terms, conditions, policies and procedures, and/or other administrative information.

We use your first and last name and at least one contact method to contact you. Depending on the content of the communications, we may also process other Personal Information related to you for this purpose.

We rely on our legitimate interest, such as to ensure our Services are used in accordance with our terms, conditions, and policies.

We rely on the performance of contract, where the communication relates to our website Terms of Use.

In certain instances we may also have a legal obligation to inform you of material changes to our Terms of Use or Privacy Notice (e.g., in case of mergers, acquisitions and other reorganizations and restructurings of our business).

We retain your Personal Information for this purpose as long as you have a relationship with us (e.g., as long as you are a loyalty member or receive marketing communications from us).

N/A

Marketing and user engagement

Purpose	Personal Information	Legal Basis	Retention Period	Sources
Send you promotional information about our Services, newsletters, promotions, offers and other news about our shopping center or the individual shops. If you sign up to receive marketing communications from us (e.g., our newsletter), we will send you periodic marketing communications, in accordance with your preferences. This may include e-mail or SMS marketing messages with offers related to the Woluwe Shopping Center or its shops.	We collect the following necessary information to provide you with our Service: First and last name Email address or phone number Marketing and communication preferences	We rely on your consent to send you marketing communications.	We retain your Personal Information until you unsubscribe from receiving marketing communications from us.	We receive the Personal Information directly from you, or our third-party partners, such as Giftify, when you give them permission to share your Personal Information with us.
Relationship building and personalization We offer you the opportunity to make the most out of your experience at Woluwe Shopping. If you agree, we would like to get to know you better in order to give you a seamless and personalized experience. For this purpose, we will use the Personal Information that we collect from our interactions with you (e.g., when you sign up for a contest, connect to our WiFi, become a loyalty program member, or information that is collected from you automatically through cookies or similar technologies) to personalize our interactions (e.g., send you gifts on your birthday) and offer you content based on your interests.	Personal Information used for this purpose includes (depending on the Personal Information that you choose to optionally share with us, see above under “Optional versus mandatory Personal Information fields”: First and last name Email address Account credentials (if you are a member of the loyalty program) Gender Zip code Phone number Date of birth Areas of interest Household composition Shopping history and/or behavior (if you are a member of the loyalty program) WiFi log-in event Marketing and communication preferences Information collected through cookies or similar technologies	We rely on your consent to personalize our communications with you. See “Your choices regarding our use and disclosure of your Personal Information” below for information on how you can opt out from personalization.	We retain your Personal Information for this purpose until such time that you opt out from personalization, as described under “Your choices regarding our use and disclosure of your Personal Information” below.	We receive the Personal Information directly from you, through your interactions with our Services or website, or from our third party partners when you give them permission to share your Personal Information with us.

Purpose

Personal Information

Legal Basis

Retention Period

Sources

Send you promotional information about our Services, newsletters, promotions, offers and other news about our shopping center or the individual shops.

If you sign up to receive marketing communications from us (e.g., our newsletter), we will send you periodic marketing communications, in accordance with your preferences. This may include e-mail or SMS marketing messages with offers related to the Woluwe Shopping Center or its shops.

We collect the following necessary information to provide you with our Service:

First and last name
Email address or phone number
Marketing and communication preferences

We rely on your consent to send you marketing communications.

We retain your Personal Information until you unsubscribe from receiving marketing communications from us.

We receive the Personal Information directly from you, or our third-party partners, such as Giftify, when you give them permission to share your Personal Information with us.

Relationship building and personalization

We offer you the opportunity to make the most out of your experience at Woluwe Shopping. If you agree, we would like to get to know you better in order to give you a seamless and personalized experience. For this purpose, we will use the Personal Information that we collect from our interactions with you (e.g., when you sign up for a contest, connect to our WiFi, become a loyalty program member, or information that is collected from you automatically through cookies or similar technologies) to personalize our interactions (e.g., send you gifts on your birthday) and offer you content based on your interests.

Personal Information used for this purpose includes (depending on the Personal Information that you choose to optionally share with us, see above under “Optional versus mandatory Personal Information fields”:

First and last name
Email address
Account credentials (if you are a member of the loyalty program)
Gender
Zip code
Phone number
Date of birth
Areas of interest
Household composition
Shopping history and/or behavior (if you are a member of the loyalty program)
WiFi log-in event
Marketing and communication preferences
Information collected through cookies or similar technologies

We rely on your consent to personalize our communications with you. See “Your choices regarding our use and disclosure of your Personal Information” below for information on how you can opt out from personalization.

We retain your Personal Information for this purpose until such time that you opt out from personalization, as described under “Your choices regarding our use and disclosure of your Personal Information” below.

We receive the Personal Information directly from you, through your interactions with our Services or website, or from our third party partners when you give them permission to share your Personal Information with us.

Improving our Services

Purpose	Personal Information	Legal Basis	Retention Period	Sources
Improving and developing new Services We will use the Personal Information that we collect about you for analytical purposes, so that we can improve our existing Services and develop new Services of interest. For example, we will conduct data analysis to monitor and analyze the usage of our Services and areas from which our visitors come to shop at Woluwe Shopping. We may also use the insights gained to develop new Services, such as on the basis of visitor feedback, or to improve existing Services or the way we promote them. We also want to be able to identify usage trends, and to monitor the effectiveness of our promotional campaigns.	We use the Personal Information that we have collected from or about you for this purpose. Where possible and feasible, we will do this in a manner that does not directly identify you (e.g., by creating aggregated insights from pseudonymized data, as described below).	We rely on our legitimate interest for these activities. We have an interest in making sure our Services remain relevant to our visitors, and our promotional campaigns remain effective.	We retain the Personal Information in identifiable form for the duration of the applicable retention period for the primary purpose of collection of the relevant Personal Information.	We receive the Personal Information directly from you or through your interactions with our Services or website.
Aggregating or anonymizing Personal Information. Where we don’t need your Personal Information in identifiable form to pursue our purposes (such as performing analytics to obtain aggregate insights), we will aggregate and/or anonymize your Personal Information so that it is no longer considered Personal Information.	We may aggregate, anonymize or pseudonymize any of your Personal Information as is necessary or required for the relevant purpose of anonymization or pseudonymization.	We rely on our legitimate interests to anonymize your information, such as the interest to generate other data for our use.	Where anonymized information no longer qualifies as Personal Information, we will keep such data in accordance with our retention policies.	We receive the Personal Information directly from you or through your interactions with our Services or website.

Purpose

Personal Information

Legal Basis

Retention Period

Sources

Improving and developing new Services

We will use the Personal Information that we collect about you for analytical purposes, so that we can improve our existing Services and develop new Services of interest.

For example, we will conduct data analysis to monitor and analyze the usage of our Services and areas from which our visitors come to shop at Woluwe Shopping. We may also use the insights gained to develop new Services, such as on the basis of visitor feedback, or to improve existing Services or the way we promote them. We also want to be able to identify usage trends, and to monitor the effectiveness of our promotional campaigns.

We use the Personal Information that we have collected from or about you for this purpose. Where possible and feasible, we will do this in a manner that does not directly identify you (e.g., by creating aggregated insights from pseudonymized data, as described below).

We rely on our legitimate interest for these activities. We have an interest in making sure our Services remain relevant to our visitors, and our promotional campaigns remain effective.

We retain the Personal Information in identifiable form for the duration of the applicable retention period for the primary purpose of collection of the relevant Personal Information.

We receive the Personal Information directly from you or through your interactions with our Services or website.

Aggregating or anonymizing Personal Information.

Where we don’t need your Personal Information in identifiable form to pursue our purposes (such as performing analytics to obtain aggregate insights), we will aggregate and/or anonymize your Personal Information so that it is no longer considered Personal Information.

We may aggregate, anonymize or pseudonymize any of your Personal Information as is necessary or required for the relevant purpose of anonymization or pseudonymization.

We rely on our legitimate interests to anonymize your information, such as the interest to generate other data for our use.

Where anonymized information no longer qualifies as Personal Information, we will keep such data in accordance with our retention policies.

We receive the Personal Information directly from you or through your interactions with our Services or website.

Security and legal reasons

Purpose	Personal Information	Legal Basis	Retention Period	Sources
Fraud prevention and security We may use your Personal Information if this comes up in the context of: Security purposes, including system security and on-site security of our premises. Note that where we have CCTV cameras installed in our shopping center, this will be made visible through an appropriate sign. Monitoring for and preventing fraud; and Audits to verify that our internal processes function as intended and are compliant with legal, regulatory and contractual obligations.	Depending on the specific purpose, this may include any Personal Information that we have collected about you, including images from CCTV cameras.	We rely on our legitimate interests, such as identifying and/or preventing fraudulent transactions or theft and ensuring the security of our shopping centers and systems. We have a legal obligation to conduct audits.	We retain the Personal Information as long as needed for the applicable purpose or in accordance with a legal obligation to retain certain Personal Information. We retain CCTV images for a period of 15 days unless misconduct was detected, in which case we may retain the images for a longer period as necessary to address the misconduct.	We receive the Personal Information directly from you or through your interactions with our Services or website (e.g., through the use of cookies and/or similar technologies or through our CCTV cameras).
Legal and compliance We have general legal and compliance obligations to process your Personal Information. This includes complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements. Enforcing our terms and conditions; protecting our operations; protecting our rights, privacy, or property; and allowing us to pursue available legal remedies, defend claims and limit the damages that we may sustain.	We use the Personal Information as relevant for the specific legal action, regulatory investigation, and/or legal processes in question.	We rely on our relevant legal obligation to process the relevant Personal Information. We rely on our legitimate interest, such as enforcing terms and conditions and bringing or defending legal claims.	As long as is required by the relevant legal obligation or necessary for the establishment, defence or exercise of a legal claim.	N/A
Emergency and incident response In exceptional circumstances, we may need to process your Personal Information to respond to an incident or emergency. This may include purposes such as: Ensuring the safety of on-site personnel and visitors; responding to, handling and documenting on-site accidents and medical and other emergencies; actively monitoring properties to ensure adequate incident prevention, response and documentation (including CCTV); requesting assistance from emergency services; and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio-visual device prompts, etc.).	We use Personal Information as necessary and relevant for the specific purpose and context.	We have a legal obligation to adequately address emergencies and incidents. In certain instances, processing Personal Information may also be necessary to protect an individual’s vital interests (such as when we need to contact medical or emergency services).	As long as is required by the relevant legal obligation or necessary for the establishment, defence or exercise of a legal claim.	N/A

Purpose

Personal Information

Legal Basis

Retention Period

Sources

Fraud prevention and security

We may use your Personal Information if this comes up in the context of:

Security purposes, including system security and on-site security of our premises. Note that where we have CCTV cameras installed in our shopping center, this will be made visible through an appropriate sign.
Monitoring for and preventing fraud; and
Audits to verify that our internal processes function as intended and are compliant with legal, regulatory and contractual obligations.

Depending on the specific purpose, this may include any Personal Information that we have collected about you, including images from CCTV cameras.

We rely on our legitimate interests, such as identifying and/or preventing fraudulent transactions or theft and ensuring the security of our shopping centers and systems.

We have a legal obligation to conduct audits.

We retain the Personal Information as long as needed for the applicable purpose or in accordance with a legal obligation to retain certain Personal Information.

We retain CCTV images for a period of 15 days unless misconduct was detected, in which case we may retain the images for a longer period as necessary to address the misconduct.

We receive the Personal Information directly from you or through your interactions with our Services or website (e.g., through the use of cookies and/or similar technologies or through our CCTV cameras).

Legal and compliance

We have general legal and compliance obligations to process your Personal Information. This includes complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements.

Enforcing our terms and conditions; protecting our operations; protecting our rights, privacy, or property; and allowing us to pursue available legal remedies, defend claims and limit the damages that we may sustain.

We use the Personal Information as relevant for the specific legal action, regulatory investigation, and/or legal processes in question.

We rely on our relevant legal obligation to process the relevant Personal Information.

We rely on our legitimate interest, such as enforcing terms and conditions and bringing or defending legal claims.

As long as is required by the relevant legal obligation or necessary for the establishment, defence or exercise of a legal claim.

N/A

Emergency and incident response

In exceptional circumstances, we may need to process your Personal Information to respond to an incident or emergency. This may include purposes such as: Ensuring the safety of on-site personnel and visitors; responding to, handling and documenting on-site accidents and medical and other emergencies; actively monitoring properties to ensure adequate incident prevention, response and documentation (including CCTV); requesting assistance from emergency services; and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio-visual device prompts, etc.).

We use Personal Information as necessary and relevant for the specific purpose and context.

We have a legal obligation to adequately address emergencies and incidents. In certain instances, processing Personal Information may also be necessary to protect an individual’s vital interests (such as when we need to contact medical or emergency services).

As long as is required by the relevant legal obligation or necessary for the establishment, defence or exercise of a legal claim.

N/A

The Second Life

If you make use of the The Second Life services, we will process certain Personal Information to facilitate this. Please refer to the The Second Life privacy policy for more information.

Disclosure of Personal Information

We disclose Personal Information to the following recipients:

Our parent company, Eurocommercial Properties N.V., to create aggregate insights and provide other (legal) support services.
The tenant association of Woluwe Shopping Center.
Woluwe Shopping Center property manager.
Our CRM platform service provider.
Our WiFi service provider.
Other IT and related infrastructure service providers, including website hosting and email delivery.
Contest platform providers.
Analytics service providers.
Advertising service providers.
Social media providers.
Animation and event agencies.

Other Disclosures

We will also disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

To public and/or government and/or regulatory authorities, including courts, tribunals, regulators, tax authorities and other government authorities;
To third persons (legal or natural), as relevant for the specific legal action and/or processes in question (such as lawyers, auditors, insurers, advisory firms, etc.);
To third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You will be notified of any such business transaction and of possible changes to the processing of your Personal Information in accordance with applicable law and the ‘Updates To This Privacy Notice’ section.

COOKIES AND SIMILAR TECHNOLOGIES

We may collect personal information through the use of cookies and similar technologies. Please see our Cookies and Similar Technologies Policy for more information.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND INDIVIDUALS’ RIGHTS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. As described above under “Marketing and user engagement” you can choose the kind of marketing communications you would like to receive from us. You can opt-in for non-personalized general marketing communications, or for personalized marketing communications tailored to your situation and interests.

You will have the ability, at all times, to opt out from:

1. Receiving marketing-related communications from us. If you no longer want to receive any marketing related communications from us on a going-forward basis, you may opt out by:

Clicking the “Unsubscribe” link at the bottom of the email that you receive from us; or
If you are a member of our loyalty program, you can change your marketing settings by logging in to your account.

This will opt you out from all marketing communications from us, including personalized marketing communications.

2. Receiving personalized marketing-related communications from us. If you agreed to receive personalized marketing communications, but want to opt out from personalization and still receive regular, non-personalized, marketing communications from us, you may opt out of personalization by:

Contacting us in accordance with the “Contacting Us” section below; or
If you are a member of our loyalty program, you can opt out from personalization by logging in to your account.

3. Personalization on the basis of certain categories of Personal Information. If you provided us with optional Personal Information for personalization purposes by completing optional fields, you can manage the optional Personal Information elements being used for personalization purposes by:

Contacting us in accordance with the “Contacting Us” section below; or

If you are a member of our loyalty program, you can opt out from personalization or change your information by logging in to your account.

You will still receive personalized marketing communications from us, but the personalization will no longer be based on the data element that you opted out from.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing from us, we may still send you important administrative messages, from which you cannot opt out.

How you can exercise your rights

Members of our loyalty program can access, update and/or delete their Personal Information, by logging in to their account.

In addition, if you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, withdraw your consent (which will not affect the lawfulness of processing prior to the withdrawal), or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such promotion).

You may lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide the Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

THIRD PARTY SERVICES

This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which we link. The inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed outside of the European Economic Area.

For such transfers, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Adequacy Decisions: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to UK or EEA standards (the full list of these countries is available here).

Standard Contractual Clauses: For transfers of Personal Information from the EEA to third countries where Personal Information is transferred, which are not considered adequate by the European Commission, we have put in place standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below or by following this link.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership).

UPDATES TO THIS PRIVACY NOTICE

The “LAST UPDATED” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice on the website.

CONTACTING US

Eurocommercial Properties Belgium S.A., Brussels, located at Rue Saint-Lambert 200, 1200 Woluwe-Saint-Lambert, Belgium, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Notice.

If you have any questions about this Privacy Notice, please contact us at GDPR@ecpnv.com.

Because email communications are not always secure, please do not include sensitive information in your emails to us.