- Who are we and what do we offer?
We are Brxs Properties B.V. (“BRXS” or “BRXS Properties”). We provide a Platform where you, as a retail investor, can invest in real estate (Investment Services).
You can access our Platform via our Website: www.brxsproperties.com and www.brxs.com or via our App, available in the Google and Apple App stores. The use of the Platform, the Website, the App and our Investment Services are collectively: our Services.
- Privacy Notice
This is our Privacy Notice. In this document we explain what kind of Personal Data we collect via our Services. We also explain what role we have in the processing of Personal Data, how long we retain Personal Data and what rights you have as a data subject.
- Personal Data and Controller
We process Personal Data. Personal Data means all information by which a person can be directly or indirectly identified. Under the General Data Protection Regulation (GDPR) we are the so-called Controller of your Personal Data. If you have questions about the processing of your Personal Data, you can always contact us through the contact details listed at the bottom of this Privacy Notice.
- What Personal Data do we collect as Controller?
As the Controller, we may process your Personal Data in different contexts.
We will process your Personal Data if you use our Investment Services. In addition, we may process Personal Data in a general context, e.g. via our Website and social media accounts (General). We will also process your Personal Data if you apply for a job at BRXS or any of our group companies (Applicants).
If you use our Investment Services, we may process the following Personal Data:
Legal Basis
Purpose(s)
We may process this Personal Data, because we need this Personal Data to perform our contract with you.
We may process these Personal Data to perform our contract with you, i.e. with respect to providing our Investment Services via our Platform.
We use these data to:
- verify your account details and register an account to provide you with access to our Platform;
- communicate with you and approach you appropriately in our communications; and
- grant you a preferred status if your friend signs up on our Platform with your referral code, or if you (as a referral) sign up on our Platform. This status includes i.a. getting discounts and/or early access to our property listings.
Personal Data
Account details:
- First name, last name, country of residence and email address.
We use these data to:
- provide an online dashboard where you can keep track of your investments and/or sales on the Platform; and
- provide you with quarterly overviews of your income and recent developments about the property.
Investment information:
- (Financial) information on your investments, such as the mortgage amount, property value, rental incomes, etc.
- Other information you provide when you invest in and/or sell property on the Platform.
We may process this Personal Data, because we need this Personal Data to perform our contract with you.
We are also legally obligated to process and/or share (some of) these data for/with the national tax authorities.
We use these data to:
- process and administer payments (i.e. your investments and/or sales on the Platform, and the fees charged by BRXS Properties); and
- include in our (financial) administration to comply with Tax and Customs Administration regulations.
Payment and tax details:
Name, home address, bank details (account number, IBAN and BIC-code).
Personal Data that we may process of all users of the Services:
If you subscribe to our newsletter:
Name and email address.
We use these data to:
- send you our newsletter and keep you informed on all our (future) Services.
We may process these data, if you gave us yourconsent to do so (by subscribing via our Website).
We may send our users – who paid for our Services – newsletters, because we have a legitimate interest to do so.
In every newsletter there is a link via which you can unsubscribe.
Legal Basis
If you have signed up for our waiting list (which was previously available on our Website):
Name and email address.
We use these data to:
- contact you for the Services as requested.
We may process these Personal Data to perform our contract with you, i.e. with respect to placing you on our waiting list.
Purpose(s)
We may process this Personal Data, because we have a legitimate interest to process this data and because the visitors voluntarily made such information public.
Our social media pages are also controlled by the social medium itself. Please check their own privacy notices, to see how each social medium handles Personal Data:
- LinkedIn: Privacy Notice
- Facebook: Data Policy
- Instagram: Privacy Notice
We may process these data because we have a legitimate interest to do so, i.e. to provide you with a good functioning Website and improve our Services for our users.
For the processing of your Personal Data via (some of) our cookies, we will ask for your consent.
Please see our cookie statement for more information.
We use these data to:
- communicate in the same language of the browser;
- adapt our Website to the used device;
- enable you to use our Website; and
- improve the usability of our Website.
Personal Data
Technical information:
Information on your device type, browser type, session date and time, IP address and browser type.
We use these data to:
- contact the visitors in reply of their post and/or comment via our social media pages; and
- process the feedback left on our social media pages.
Via our social media pages:
Information of visitors who leave a comment or otherwise post something on our social media pages, including the Personal Data within these comments and/or posts.
We may process this data, because we have a legitimate interest to contact and assist you based on your comment or question and to improve our Services as a result of the questions and feedback we receive.
We use these data to:
- answer your questions and/or handle any complaints;
- support you in using our Services; and
- improve our Services as a result of questions and feedback from you.
If you contact us:
Your email address and the content of the correspondence (if the correspondence takes place via email).
Personal Data we may process if you are an Applicant:
We use these data to:
- Assess whether the Applicant suits the job and BRXS or its group companies;
- Determine which Applicant is the most suitable candidate.
We have a legitimate interest to process these Personal Data as we need them to process and assess the application.
We only process information that is relevant for the application and the Applicant gets the opportunity to react to our findings.
Legal Basis
Purpose(s)
We may process this Personal Data, because we have a legitimate interest in processing these data and because the Applicant provides this data itself voluntarily. We need the data to get (and keep) in touch with the Applicant and to process and review the application.
We may process these Personal Data, because we have a legitimate interest in processing these data. We need the data to get (and keep) in touch with the Applicant and to process and review the application.
We use these data to:
- contact the Applicant about the application.
Personal Data
Contact details:
First name and surname, email address, address and telephone number.
We use these data to:
- assess whether the Applicant suits the job and BRXS Properties or its group companies; and
- determine which Applicant is the most suitable candidate.
Application information:
Information provided by the Applicant, among others: Personal Data included in the curriculum vitae and motivation
We may process these Personal Data, because we have a legitimate interest in processing these data. We need the data to get (and keep) in touch with the Applicant and to process and review the application.
We use these data to:
- Assess whether the Applicant suits the job and BRXS or its group companies; and
- Determine which Applicant is the most suitable candidate.
Information retained during application process:
Notes from interviews.
Information from public sources:
Information in public profiles, such as LinkedIn and other social networks (where applicable).
5. Mandatory information
When you engage our Services, it may be legally or contractually required that you provide us with certain Personal Data, as indicated with a (*). For example, we may need your payment details so that we can process and administer your investment(s) and/or sales on our Platform. Where you do not provide us with such information, this will usually imply that we will not be able to provide you with specific Services or perform part of our agreement with you.
6. Cookies
We may use functional, tracking and/or analytical cookies on our Website. A cookie is a simple small text file that can be stored in your device when visiting the Website. This text file identifies your browser and/or device. When visiting our Website again, the cookie ensures that your browser/device is recognized.
For more information on our use of cookies, please refer to our cookie statement.
7. How long do we keep the Personal Data?
We will not process or store any Personal Data that we do not need. We store Personal Data for as long as we need it for the above purposes, unless we are legally obliged to retain the Personal Data for a longer period. In this respect, we apply the following retention periods:
- Personal data of potential clients | These data are stored as long as necessary to determine whether we enter into an agreement with a potential client and for a maximum period of 24 months after our last contact.
- Personal data of clients | These data are stored as long as we have a contract with our client and for a maximum period of 5 years after, unless we are legally obliged to retain the data for a longer period.
- Newsletters | We retain the Personal Data used for sending newsletters until you unsubscribe from our newsletter.
- Personal Data in our correspondence | This data is stored as long as necessary to handle your message/question/complaint and for a period of 5 years thereafter.
- Personal Data in our records for the (tax) authorities | These data are stored for seven (7) years, unless we are legally obliged to retain the data for a longer period.
- Personal data of job applicants | We store these Personal Data for a maximum of 1 year after the application process (e.g. in order to include you in our talent pool), if we have your consent.
After expiry of the aforementioned retention period(s), we may process and retain certain Personal Data to comply with legal retention obligations and/or for fraud/misuse investigations or to substantiate a (judicial) claim. In such events, we will retain the Personal Data separately and only use such Personal Data for the aforementioned purposes.
8. Do we share your Personal Data with others?
Processors
We use third parties (Processors) who support us in providing our Services. Within this context these Processors receive Personal Data from us which they process on our behalf. For instance, we use Processors for building and maintaining our Website and Platform, sending our newsletters and hosting our data.
These Processors may only use or disclose the data collected and processed by us within the scope of our instructions to them and under no circumstances for other purposes. We enter into a data processing agreement with all of our Processors.
External Controllers
In addition, some of the Personal Data may be processed by other controllers (External Controllers):
- Payments on the Platform will be processed by our third-party payment providers (Stripe) and (Plaid).
- We share our financial administration with the national tax authorities, because we are legally obliged to do so.
Any Personal Data provided to these External Controllers will be processed in accordance with their own privacy policies.
Joint controllers
In order to provide the Services, BRXS Properties may involve other companies within its group. Where BRXS Properties and another entity jointly determine the purposes and means of processing, BRXS Properties acts with such other parties as joint controllers within the meaning of Article 26 of the GDPR (Joint Controllers). In that case, BRXS Properties has defined the respective responsibilities, roles and relationships with those parties in a mutual arrangement within the meaning of Article 26 of the GDPR. In this agreement parties agree, among other things, that each party will be responsible for complying with their obligations under the GDPR, and who will be the first point of contact for your rights (as described in this Privacy Notice). Insofar any Personal Data will be processed by an entity outside the EU, Standard Contractual Clauses have been incorporated to secure an adequate level of protection.
Brxs Properties B.V. is the main contact point for all privacy and data protection related matters regarding Personal Data collected through the Services. You can contact us via the contact details at the bottom of this Privacy Notice.
Apart from the above, we will not share your Personal Data with third parties, unless we are legally obliged to do so.
9. Export of Personal Data outside the European Union
We may transmit Personal Data to parties outside the European Union, if one of our Processors or Controllers is established outside the European Union. The Personal Data will only be transferred to countries and/or parties that provide an adequate level of protection in accordance with the European standards. You contact us if you wish to receive more information or a copy of the safeguards we take in this scope where necessary.
10. Third party websites
You may find advertising or other (hyper)links on our Website that link to the websites, products and services of partners, suppliers, advertisers, sponsors, licensors or other third parties. We do not control the content or the links that appear on these websites and we are not responsible for the practices employed by websites linked to or from our Website. In addition, these websites, products and services, including their content and links, may be constantly changing. These websites, products and services may have their own privacy notices, user terms and customer service policies. Browsing and interaction on any other website, including websites that are linked to or from our Website, are subject to the terms and policies of that website.
11. Changes of the Privacy Notice
The Privacy Notice may be changed from time to time. Please check our Privacy Notice frequently. The new Privacy Notice will be effective immediately upon posting on our Website. If we change our Privacy Notice significantly, then we will state so on our Website together with the revised Privacy Notice.
12. Your rights as a data subject and our contact data
You are always entitled to file a complaint with a data protection supervisory authority if you believe that we are not processing your Personal Data in accordance with the GDPR. In the Netherlands, the supervisory authority for data protection is:
Autoriteit Persoonsgegevens
Website: https://www.autoriteitpersoonsgegevens.nl
If you have questions or concerns about this Privacy Notice or your privacy, you can contact us at info@brxsproperties.com.
Brxs Properties B.V.
Singel 542
1017 AZ Amsterdam
The Netherlands
W: www.brxsproperties.com or www.brxs.com
Chamber of Commerce: 89185188