FIRST REAL ESTATE – PRIVACY POLICY

Introduction

This Privacy Statement applies to the processing of personal data of all our users in relation to the services of First Real Estate B.V., statutorily established and having its offices at (1119 PB) Schiphol-Rijk, Boeingavenue 245, registered in the trade register of the Chamber of Commerce under number: 90865154 (hereinafter referred to as: “First Real Estate”).

This Privacy Statement describes how this data processing takes place and for what purposes this data is processed. By using our website and accepting this Privacy Statement, the user agrees to the following terms that apply to it.

Providing personal data is not mandatory
A user always has the choice whether or not to provide their personal data. However, in order to use some of our services, it is necessary to provide us with your personal data. If the entry and/or submission of your data is requested, we will indicate which data is “necessary” in order to use the products and/or services and which data can be provided “optionally”.

Processing of personal data
By using our services, we process your personal data. This data is collected for specific purposes based on a legitimate legal basis. This concerns the following categories of data, purposes, and legal grounds. The processing of personal data takes place for the following purposes:

  1. For the establishment and performance of an agreement concluded with the user;
  2. For administrative handling: to offer the user the agreed services;
  3. For invoicing: in the event a payment is not made, we may transfer the claim to third parties such as a debt collection agency.

In the aforementioned cases, the full (company) name and address details, contact person’s name, telephone number, ID document (on which special personal data is rendered illegible), email address, Chamber of Commerce number, VAT number, and account number are essential for performing the agreement.

  1. To send the user newsletters, offers, user information, service announcements, and/or other electronic messages that may be relevant to the user, if the user has explicitly consented to this;
  2. To make direct offers to the user or for other promotional purposes, via social media and/or email, if the user has explicitly consented to this.

In the aforementioned situations, the personal data, namely full (company) name and address details, contact person’s name, telephone number, and email address, are provided optionally, for which the user gives consent.

  1. For managing, analyzing, maintaining, optimizing, and securing our products and/or services and to prevent misuse and/or fraud of our services;
  2. For determining strategic analyses and reports of our services.

In the aforementioned cases, personal data, such as name and/or address details, is processed and we have a legitimate interest for this.

We will only process the provided personal data for the performance of our products and/or services and specifically for the explicit purpose for which this personal data is collected.

Data collected automatically
Apart from cookies, as mentioned below, we do not collect any data automatically.

Sensitive personal data
We do not process sensitive personal data.

Retention periods
Personal data will only be retained for the period necessary for the proper performance of the aforementioned purposes. If longer statutory retention periods apply, the statutory retention periods as prescribed by law will apply.

User rights
Under GDPR legislation, all our users have certain rights to manage their own personal data:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to object;
  • The right to data portability;
  • The right to restriction.

A user can also withdraw the consent they have given for the processing of their data at any time. Furthermore, the user has the right to lodge a complaint about our data processing activities with a data protection authority.

If a user wishes to exercise one or more of these rights, they can contact First Real Estate via hello@fre.nl.

Data obtained from third parties
First Real Estate does not process personal data obtained from third parties.

Disclosure to third parties
Only persons authorized by First Real Estate to secure and/or otherwise process personal data and/or perform IT maintenance work have access to the personal data of Users.

If we work with third parties, such as postal companies and payment services, for the performance of the services in this Privacy Policy, we have concluded an agreement with those processors, so that the processor provides sufficient guarantees regarding technical and organizational security measures for personal data.

Should you unexpectedly discover a data breach, it is of great importance that we are informed immediately. You can report data breaches directly via: hello@fre.nl. Your report and data will always be treated confidentially.

Otherwise, we will not provide the personal data of our users to third parties, unless this is necessary for the performance of our services on the basis of a statutory provision or in an emergency insofar as this is, in our reasonable judgment, in the interest of our users. This also includes lawful requests from authorities, subpoenas or court orders, actions to detect or prevent damage or fraud, or actions to guarantee the security of our network and services.

Storage of personal data
The personal data processed by us will only be stored in the Netherlands and will not go beyond the borders of the EU. The GDPR therefore applies to this stored personal data.

Security
We have taken appropriate technical and organizational measures to secure users’ personal data against accidental or unlawful destruction, loss, or alteration, or unauthorized disclosure of or access to personal data that is transmitted, stored, or otherwise processed.

Contact information
If you have any questions or complaints about this Privacy Policy, or if you have a question or complaint regarding our working methods, you can contact us via: hello@fre.nl.