Privacy Policy

Last updated: July 2026

Promiris Management Services SA ("Promiris", "we", "us", "our") is committed to protecting your personal data. This Privacy Policy explains what data we collect, why we collect it, how we use it, and what rights you have under the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable Belgian data protection law.

1. Who we are

Data controller: Promiris Management Services SA

Registered office: Chaussée de Bruxelles 135A, 1310 La Hulpe, Belgium

Telephone: +32 (0)2 486 23 90

Email: info@promiris.com

Company number: BE 0668.737.202

These details are based on the current Promiris General Conditions page and should be kept aligned with Promiris' official legal information.

This page should be updated if the legal entity, registered office, company number, telephone number or privacy contact email changes.

Promiris is a residential real estate developer active in Belgium, Portugal, and Spain. For questions about this Privacy Policy or your personal data, contact us at the email address above.

2. What data we collect and why

We collect personal data only for specific, legitimate purposes. The table below sets out each processing activity, the legal basis under Article 6 GDPR, and the retention period.

Maintenance note: review processing activities, legal bases and retention periods whenever Promiris adds or changes forms, tools, service providers, marketing activity or data-handling processes.

Processing activity	Data collected	Legal basis (Art. 6 GDPR)	Retention period
Responding to contact form enquiries	Name, email address, phone number (optional), message content	Art. 6(1)(b) — necessary to take steps at the request of the data subject prior to entering a contract	3 years from last contact
Sending project brochures or documents on request	Name, email address	Art. 6(1)(b) — pre-contractual steps	3 years from last contact
Newsletter subscription (media updates, project news)	Email address, first name (optional)	Art. 6(1)(a) — consent	Until unsubscribe; consent records kept 5 years
Managing the purchase or reservation process	Name, address, identification data, financial information as required by law	Art. 6(1)(b) — performance of a contract; Art. 6(1)(c) — legal obligation	Duration of contract + 10 years (Belgian statutory limitation period)
Anti-money laundering (AML) checks	Identification documents, beneficial ownership information	Art. 6(1)(c) — legal obligation (Belgian AML Law of 18 September 2017)	10 years from end of business relationship
Website analytics (aggregated, anonymised)	IP address (anonymised), pages visited, session duration, browser type	Art. 6(1)(f) — legitimate interest (improving website performance)	13 months (Google Analytics default; data anonymised at collection)
Cookie-based advertising and remarketing	Cookie identifiers, browsing behaviour on our site	Art. 6(1)(a) — consent	Until consent is withdrawn; maximum 13 months per cookie

3. Cookies

We use the following categories of cookies on this website:

Strictly necessary cookies — required for the site to function (e.g. session management, cookie consent record). No consent required.

Analytics cookies — help us understand how visitors use our site (e.g. Google Analytics). Only placed with your consent.

Marketing and remarketing cookies — used to show you relevant advertising on other platforms (e.g. Google Ads, Meta). Only placed with your consent.

You can manage or withdraw your cookie consent at any time by clicking "Cookie settings" in the footer of this page.

For full details, see our Cookie Policy.

4. Who we share your data with

We do not sell your personal data. We share it only where necessary:

Service providers acting as data processors: Our website host, email platform, CRM system, and document management tools. All are bound by data processing agreements and may not use your data for their own purposes.
Professional advisors: Lawyers, notaries, and accountants, where required in connection with a property transaction.
Regulatory authorities: Belgian tax authorities, the Financial Intelligence Processing Unit (CTIF-CFI), or other competent authorities, where we are legally required to disclose.
Co-developers: Where a project is developed jointly (e.g. with Thomas & Piron), your data may be shared with the co-developer to the extent necessary for the transaction. You will be informed separately in such cases.

Where service providers are located outside the European Economic Area (EEA), we ensure appropriate safeguards are in place (Standard Contractual Clauses or adequacy decision).

5. Your rights

Under the GDPR, you have the following rights regarding your personal data:

Right of access — you can request a copy of the data we hold about you.
Right to rectification — you can ask us to correct inaccurate data.
Right to erasure — you can ask us to delete your data, subject to legal retention obligations.
Right to restriction — you can ask us to restrict processing in certain circumstances.
Right to data portability — you can receive your data in a structured, machine-readable format.
Right to object — you can object to processing based on legitimate interest at any time.
Right to withdraw consent — where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at info@promiris.com. We will respond within 30 days.

6. Right to lodge a complaint

If you believe your data has been processed unlawfully, you have the right to lodge a complaint with the Belgian supervisory authority:

Autorité de protection des données (APD) — Gegevensbeschermingsautoriteit (GBA)

Rue de la Presse 35, 1000 Brussels

www.autoriteprotectiondonnees.be

contact@apd-gba.be

+32 (0)2 274 48 00

You may also lodge a complaint with the supervisory authority in the EU member state where you habitually reside or work.

7. How we protect your data

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorised disclosure. These include:

TLS encryption for all data transmitted via this website
Access controls limiting data access to authorised personnel only
Regular review of our security practices

8. Changes to this policy

We may update this Privacy Policy from time to time, including when our data practices, website tools, service providers, internal processes, applicable laws or regulatory guidance change. We will notify you of material changes by posting the updated policy on this page with a new "Last updated" date. We encourage you to review this page periodically.

^{This policy was last reviewed in July 2026. Promiris Management Services SA — Chaussée de Bruxelles 135A, 1310 La Hulpe, Belgium — info@promiris.com — BE 0668.737.202}