Privacy Policy

I. Introduction

This Privacy Policy explains how Upkot processes the personal data of its customers (individuals) and any other private persons who come into contact with Upkot (hereinafter referred to as 'you').

Upkot is committed to protecting your privacy and processes your personal data in a transparent, fair, and lawful manner. 'Personal data' means any information that directly or indirectly identifies you as a natural person.

Upkot complies with all applicable data protection legislation, including the European General Data Protection Regulation (GDPR – Regulation No. 2016/679 of 27 April 2016) and any subsequent amendments.

Further information on data protection is available from the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit) at www.dataprotectionauthority.be.

Please read this policy carefully. It is updated periodically; the latest version is always available on our website. We will notify you of any significant changes through our usual communication channels.
 

II. Date controller

Upkot is the controller responsible for processing your personal data:

Upgrade Estate Group
Amelia Earhartlaan 2/201
9051 Gent
privacy@upgrade-estate.be
+32 9 233 76 66

Upkot determines the purposes and means of processing. It may engage specialised service providers ('processors') to process data on its behalf and under its instructions. Only the data strictly necessary for a given task will be shared with such processors.

III. Categories of personal data processed

The table below provides an overview of the categories of personal data Upkot may process, along with the context in which they are collected. Additional data may be processed where necessary for the continuation of the contractual relationship.

Upkot does not process special categories of data such as ethnic origin, political opinions, religious beliefs, trade union membership, health data, genetic data, sexual orientation, or biometric data.

IV. Pruposes of processing

Upkot processes your personal data only for the purposes described below, and only to the extent necessary for those purposes. Processing is based on one or more of the following legal grounds:

• Compliance with legal obligations applicable to Upkot;

• Performance of a contract with you, or taking pre-contractual steps at your request;

• Pursuit of Upkot's legitimate interests, balanced against your rights and freedoms;

• Your specific, informed, and unambiguous consent, which you may withdraw at any time.

Legal obligations

Upkot must process data to comply with applicable legislation, including:

• Anti-money laundering and counter-terrorism financing obligations;

• Legal obligations related to co-ownership management;

• Responding to formal requests from Belgian tax authorities and judicial bodies.

Contractual relationship

To enter into and manage contracts, Upkot processes data to:

• Respond to your requests and provide assistance;

• Assess suitability and risks for a potential contract;

• Carry out your instructions as intermediary;

• Fulfil administrative and accounting obligations.

Data may be shared internally across Upkot departments for contract management, customer overview, property management, and co-ownership administration.

Legitimate interests

Upkot processes data to pursue its legitimate interests, including:

• Personalising and improving our services;

• Evaluating and improving internal processes and campaigns through statistical analysis and surveys;

• Monitoring business activities (website visits, call volumes, customer enquiries, etc.);

• Preparing anonymised studies and statistics;

• Employee training using practical examples, including selected call recordings;

• Improving website usability through cookies (see our Cookie Policy);

• Storing evidence and defending Upkot's legal rights.

Direct marketing

Upkot may carry out customer segmentation to offer relevant properties and services. This may include analysing your behaviour, preferences and demographic data across channels (website, email, social media, events) to personalise communications and advertising.

Electronic direct marketing (consent)

Upkot may use your electronic contact details (mobile number, email address) to send you personalised commercial communications, newsletters, and advertising. Your prior consent is required for this purpose. By accepting this Privacy Policy, you consent to such electronic direct marketing.

V. Disclosure of personal data

Upkot handles your data with care and shares it only where necessary to deliver its services.

Data may be shared with:

• Other entities within the Upkot group (in Belgium and abroad) for operational support, IT security, and reporting;

• Supervisory or government authorities where required by law;

• Judicial investigation agencies upon formal request;

• Service providers for IT, advertising, communications, reporting, printing, and events;

• Online and social media platforms used for advertising;

• Bailiffs or lawyers in the context of legal proceedings.

In all cases, Upkot ensures that third parties receive only the minimum data necessary and are contractually bound to process it securely and confidentially.

Upkot stores all personal data within the European Economic Area (EEA). No data is transferred to countries outside the EEA.

VI. Retention periods

Upkot retains personal data only as long as necessary for the purposes for which it was collected, and in accordance with statutory obligations:

• 10 years under anti-money laundering legislation;

• 10 years in relation to Upkot's contractual liability;

• 7 years for accounting and administrative records relating to co-ownership management.

After these periods, personal data is erased or anonymised.

VII. Data security

Upkot applies rigorous technical and organisational security measures to protect your data against unlawful access, loss, alteration, or destruction. These include encryption, antivirus protection, firewalls, access controls, and careful vetting of staff and suppliers.

In the unlikely event of a data breach affecting your personal data, Upkot will take immediate action to identify and contain the incident. Where required by law, you will be notified promptly.
 

VIII. Your rights

Right of access, rectification, restriction, erasure, portability, and objection

You have the following rights regarding your personal data:

• Access: request confirmation of whether Upkot processes your data, and obtain a copy;

• Rectification: request correction of inaccurate or incomplete data;

• Restriction: request that processing be limited in certain circumstances;

• Erasure: request deletion of data that is no longer necessary, processed on the basis of consent you have withdrawn, or processed without a valid legal ground;

• Portability: receive your data in a structured, machine-readable format or request it be transmitted to another controller;

• Objection: object to processing based on legitimate interests or direct marketing.

To exercise these rights, send a signed, dated written request with a copy of your identity document to:

• Post: Upkot · Amelia Earhartlaan 2/201 · 9051 Ghent

• Email: privacy@upgrade-estate.be

• Contact form on our website

Right to withdraw consent for electronic marketing

You may withdraw your consent to receive electronic marketing at any time by:

• Clicking the 'unsubscribe' link in any Upkot email or newsletter;

• Sending an email to privacy@upgrade-estate.be with a copy of your identity document;

• Sending a written request by post to the address above;

• Submitting a request via the contact page on our website.

Withdrawal of consent does not affect Upkot's right to contact you for other purposes (e.g. contract performance or legal obligations).

Right to lodge a complaint

If you have concerns about the processing of your personal data, you may contact us at the details above, or file a complaint with the Belgian Data Protection Authority:

• Post: Drukpersstraat 35 · 1000 Brussels

• Email: contact@apd-gba.be

• Phone: +32 2 274 48 00

www.dataprotectionauthority.be