Version: 1.0
Date: 01/06/2021

Content

  1. Identity of the data controller
  2. What is the scope of application of this Privacy Statement?
  3. Which of your data do we process?
  4. For which purposes and based upon which legal bases do we process your data?
  5. When and why do we transfer your data to third parties?
  6. For how long do we store your data?
  7. From whom do we obtain your data?
  8. Where do we store your data and how do we protect it?
  9. What are your rights as a data subject?
  10. How can you exercise your rights?
  11. What if we modify this Privacy Statement?

 

1.     Identity of the data controller

The European Housing Network (hereafter “EURHONET”, “we”, “us”) is an international network of public and social housing companies, currently counting around 40 members from 6 countries (France, Germany, Italy, Sweden, Austria, Denmark, and the UK).

As a not-for-profit organisation we unite public and social housing companies that share the ambition of improving professional practices and performances in the housing sector. This Privacy Statement therefore applies to the personal data that we process from you in the context of this activity.

Data protection and privacy are of a particularly high priority for us. We commit ourselves to process your personal data (hereafter your “data”) in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection rules applicable to EURHONET. This Privacy Statement explains how we process your data and what rights you have in this regard.

Legally, EURHONET is an international not-for-profit organisation, registered as a company in Belgium. You can find all our relevant details below. Via the mentioned contact details, you can always reach us for further questions or comments regarding the processing of your data by us.

Name and legal form:                           The European Housing Network (international not-for-profit organisation, in Belgium legally an “A.I.S.B.L.” or “i-vzw”)

Company registration number:       0889.222.061

Registered office address:                  Square de Meeûs 18, 1050 Elsene (Brussels) Belgium

E-mail address:                                      eurhonet@eurhonet.eu

 

2.     What is the scope of application of this Privacy Statement?

This Privacy Statement is only applicable when EURHONET is in charge of the processing of your data. This means that EURHONET acts as data controller and determines why and how your data is being processed.

‘Processing’ means any kind of data processing that could identify you as a natural person. Which specific data this may concern, will be explained in detail below. The concept of ‘processing’ is broad and includes for example the collection, storage, disclosure and distribution of your data.

This Privacy Statement is applicable on the processing of data by EURHONET from the categories of persons mentioned hereunder. For reasons of transparency and clarity, we will keep distinguishing between these categories of persons throughout the Privacy Statement, where relevant. Which data we process from you, the purposes for which we process your data, and other relevant elements are after all dependent on your relationship with EURHONET. The categories include persons who belonged to these categories in the past (e.g. former member), and persons who may belong to these categories in the future (e.g. potential future member).

  • visitors of our public websites eurhonet.eu and www.whitebook.eurhonet.eu (hereafter the “Website”);
  • the members of our international housing network, and their related use of our members platform eurhonet.eu/extranet/ (hereafter the “Platform”);
  • our business partners, that assist us in the performance of our activities as international housing network;
  • candidate employees.

If one of the persons referred to above is a legal person, we still process data from our contact persons at these entities and the GDPR applies.

Our Website and Platform use cookies. For more detailed information about the processing of your data by the use of cookies on the Website and the Platform, please refer to our Cookie Statement, which forms an integral part of this Privacy Statement.

 

3.     Which of your data do we process?

Below we clarify which data we can process from you. We do not necessarily process all data mentioned below from you. Which data we process in a specific case, depends on your specific situation, the way in which you contact us, and your preferences. For clarity, below we first of all clarify which data we may potentially process from all our contacts. We then clarify which data we additionally process for specific categories of contacts, in particular our members, business partners and candidate employees.

General

We may process the following data from all of our contacts:

  • identification data: a copy of your ID card (solely for the verification of your identity should this be necessary in the context of privacy related requests);
  • electronical identification and user data: including your browser type and version, operating system, IP address, location data, the date and time of access to the Website or Platform, your internet service provider, interactions with the Website or Platform, how you end up on the Website or Platform, the type of device you visit the Website or Platform with, the pages you visit, the way in which you navigate on these pages;
  • contact details and contact history: your name, job title, postal address, email address, telephone number, mobile phone number, messages sent and received (e.g. e-mails you send to the e-mail addresses of EURHONET as provided on the Website, or messages sent via the contact form on the Website).

Since we mainly rely on the use of cookies for processing the electronical identification and user data mentioned above, we refer to our Cookie Statement for more detailed information on this subject.

EURHONET members

From the members of our international housing network, we may additionally process the data mentioned below:

  • Platform registration details: username, password, first name, last name, address, city, state, zip code, country, day phone, cell phone, email address, company name, job title, EURHONET role;
  • Platform usage data: additional data you would actively provide via your personal account on the Platform, such as discussion posts, or any other content you would request to be published on the Platform (pictures, audio, video, …);
  • data related to EURHONET activities: our co-operation agreement and additional arrangements we may have, presentations, pictures and video recordings of our meetings together, details of events and programmes in which you participate as a EURHONET member such as workshops and our CEO Academy, Junior Executive Academy and Exchange Programme;
  • payment details: invoices, payment card details, bank account number;
  • feedback: any feedback you may have, as a member, on our activities.

Business partners

From our business partners, we may additionally process the data mentioned below:

  • transactional information: our co-operation agreement (e.g. supplier agreement) and additional arrangements we may have;
  • payment details: invoices, payment card details, bank account number;
  • feedback: any feedback you may have, as a business partner, on our co-operation.

Candidate employees

From candidate employees, we may additionally process the data mentioned below. Naturally, this will largely depend on which information you wish to provide to us in the context of your application.

  • Personal details: age, gender, date of birth, nationality.
  • Work-related data: curriculum vitae, education, certificates and transcripts, language skills, professional career, publications, portfolio.
  • Personality profile: motivation letter, hobbies, social activities, personality, job interview notes.
  • Audiovisual data: pictures and video recordings that you would provide to us in the context of your application.

 

4.     For which purposes and based upon which legal bases do we process your data?

We only process your data for legitimate purposes and based upon the legal bases that are listed in the General Data Protection Regulation (GDPR). Hereunder we clarify upon which legal bases we rely to process your data, depending on your relationship with EURHONET.

For clarity, below we first provide an overview of the purposes and legal bases of the general data processing activities within our organisation. We then list the processing operations that are relevant to specific categories of contacts, in particular our members, business partners and candidate employees. Under each process, we have listed the legal basis in the sense of the GDPR, upon which we rely to process your personal data.

General

  • answering your question when you contact us, when your contact request cannot be framed under an existing relationship with EURHONET (such as the membership of your company of EURHONET, or the co-operation agreement you have with EURHONET), via e-mail, via the contact form on our Website or in any other way;
    • Legal basis: our legitimate interests
  • offering you a Website that functions well on a technical level by the use of strictly necessary cookies, so that we can offer you a safe and well-functioning Website;
    • Legal basis: our legitimate interests
  • the use of analytical cookies on our Website to gain insight into how you use our Website, including with a view to detecting navigation problems, and to make the website more user-friendly and attractive;
    • Legal basis: your consent
  • the use of marketing cookies on our Website, for the purpose of displaying advertisements, implementing features on our website provided by social media, and measuring how often these advertisements and features are respectively displayed and used;
    • Legal basis: your consent
  • compliance with our legal obligations as a company, such as in the field of data protection and tax/accounting.
    • Legal basis: legal obligation
  • assuring the possibility of exercising or defending the interests of EURHONET in court, if we believe that our interests are being harmed and that legal action is required, or if legal action would be taken against us by a person who feels disadvantaged by us;
    • Legal basis: our legitimate interests
  • the prevention, detection and investigation of fraud and abuse that would be made of our activities as an international housing network.
    • Legal basis: our legitimate interests and those of our members

EURHONET members

  • fulfilling the pre-contractual and contractual obligations arising from the (potential) membership of your company of EURHONET including managing our contractual relationship, informing you about our activities, terms and conditions and policies, providing you with the services resulting from your membership, invoicing your membership fee and obtaining payment thereof, and communication with your contacts at EURHONET regarding your membership and the related services;
    • Legal basis: the establishment or performance of our contract
  • offering you, as our contact person for one of our members, the possibility to register a personal account to make use of the Platform, subject to manual verification by EURHONET, as a way for members of our network to connect and interact with each other, and allowing you to make use of related functionalities and benefits, such as participating in (online) events, interacting with other members of EURHONET, consulting presentations, pictures and video recordings of our meetings together, publishing additional data via this personal account such as discussion posts, sending personal messages to other users of the Platform and to receive such messages from other users, and notifying you about new content that is posted on the Platform by EURHONET or other members;
    • Legal basis: the performance of our contract, or our legitimate interests or those of our members where applicable, e.g. should no direct contract be in place between us
  • offering you a Platform that functions well on a technical level by the use of strictly necessary cookies, so that we can offer you a safe and well-functioning Platform;
    • Legal basis: our legitimate interests
  • the use of analytical cookies on our Platform to gain insight into how you use our Platform, including with a view to detecting navigation problems, and to make the Platform more user-friendly and attractive;
    • Legal basis: your consent
  • making presentations and taking pictures and recording videos of our meetings together, in an online or offline context, for internal sharing within the network or for external publication should you agree to this;
    • Legal basis: our legitimate interests, or your consent if you are specifically targeted in a picture or video, or for any external publications
  • increasing our added value as international housing network, by requesting your valuable feedback on our activities as our current or former member, or examining your interest in activities we do not yet engage in with a view to potentially expanding our offering;
    • Legal basis: our legitimate interests
  • sending you newsletters with information about EURHONET’s activities, through electronic channels or otherwise, that we believe may be of interest to you based on your existing relationship with EURHONET as our member. You have an absolute right to object to the processing of your data for direct marketing purposes and to withdraw your consent where applicable. Regarding marketing material that we send to you by e-mail, you always have the option to unsubscribe via the unsubscribe link provided at the bottom of each such e-mail;
    • Legal basis: our legitimate interests, or your consent where expressly requested
  • checking your satisfaction as our member.
    • Legal basis: our legitimate interests

Business partners

  • entering into, executing or terminating the specific agreement with you, such as IT related agreements, or any other co-operation agreement;
    • Legal basis: the establishment or performance of our contract, or our legitimate interests or those of your company should no direct contract be in place between us
  • promoting the activities of EURHONET, by using your contact details to send you newsletters and other marketing messages, by e-mail or by other means of communication.
    • Legal basis: our legitimate interests, or your consent where expressly requested

Candidate employees

  • assessing whether EURHONET wishes to enter into an employment, internship or co-operation agreement with you;

o       Legal basis: the establishment of our contract

  • keeping the information you provided us in the context of an application for a maximum period of 2 years, if you have an interesting profile, but we could not initially make a proposal because there was no suitable position available. Should a suitable position become available, we will use your details to contact you again and to gauge your interest in further discussions.
    • Legal basis: your consent

 

5.     When and why do we transfer your data to third parties?

General

We will not transfer your data to third parties, unless this is necessary for achieving one of the aforementioned purposes, you give your consent for such transfer, or we are required to do so by law.

Where necessary we engage external service providers, so called “data processors”, to support our operational purposes such as providing our services, managing our IT systems or performing any other (internal) business processes such as the digital storage of our member files. These external service providers may perform certain processing activities on your data on our behalf. We will only share your data with these external service providers to the extent necessary for the relevant purpose. The data may not be used for any other purposes by these third parties. In addition, these service providers are contractually bound to ensure the confidentiality of your data by means of a so-called “data processing agreement” concluded with these parties.

Identification of third parties to whom we may transfer your data

In concrete terms, this means that we may share your data, to the extent necessary as specified below, with the following third parties for the following purposes, with these third parties acting as data processors on our behalf in certain cases. Below each transfer, we have listed the legal basis in the sense of the GDPR, upon which we rely to transfer your data to these parties.

  • postal, transport and delivery companies regarding your contact details for the purpose of sending mail to you as our current, former or future member or business partner, or as candidate employee;
  • the processors who assist us in the IT field in operating our housing network, with the aim of efficient digital data management within our organisation, including the digital storage of our member files, the delivery of transactional e-mails such as invitations and guidelines for our members in connection with their membership of our organisation, or information with regard to the provision of the services we provide to you or you to us in the context of our relationship as business partners, the delivery of e-mails for the purpose of promoting the activities of EURHONET, the hosting and management of the Website, Platform and our mailboxes, the support to EURHONET in understanding how you use the Website and Platform through the services offered by Google Analytics;
  • payment service providers for the data relevant for processing the payments from and to our members and business partners, in order to efficiently manage the payment administration within EURHONET;
  • other members of EURHONET that have access to the Platform, concerning your profile and additional data you would upload to or post on the Platform, in accordance with the terms of use and other legal texts applicable on your use of the Platform;
    • Legal basis (for all of the above): the establishment or performance of our contract, or our legitimate interests or those of our members where applicable e.g. should no direct contract be in place between us, or your consent where relevant (e.g. for newsletters)
  • governmental bodies and practitioners of regulated professions such as accountants and lawyers, in order to comply with our legal obligations as a company, and the efficient defence of our interests in the event of any legal dispute, with regard to the data that is strictly necessary for achieving this purpose.
    • Legal basis: a legal obligation, or our legitimate interests

 

6.     For how long do we store your data?

General

We do not store your data longer than is necessary for the purposes for which the data was collected. Depending on your relationship with EURHONET, we explain below how long we store your data.

We will always comply with specific legal requirements regarding the retention of your data, for example in the context of our accounting obligations as a company.

Analytical data related to your use of our Website and Platform

Data that we collect via our use of Google Analytics on the Website and Platform, is stored for a period of 26 months.

We mainly rely on the use of cookies to process analytical data from users of the Website and the Platform. For more information on how you consent to the use of cookies that are not strictly necessary for your use of the Website or Platform, and the storage time on your device of the cookies placed, please refer to our Cookie Statement.

Members of EURHONET

We will keep your data as long as necessary for the efficient management of your membership of EURHONET. When you create a personal account for the Platform as contact person for one of our members, the data obtained in this regard will be stored as long as your account is active. Should your organisation withdraw its membership of EURHONET, we will delete your account and the data that is related to it, as far as technically possible, within a reasonable timeframe. Your data that is (to a limited extent) included in our accounts, will be kept for at least 7 years in view of our legal obligations in this regard.

Business partners

We will keep your data as long as necessary for the efficient management of the business relationship we have, had or will have with you under the agreement that is, was or will be in place between us. Your data that is (to a limited extent) included in our accounts, will be kept for at least 7 years in view of our legal obligations in this regard.

Candidate employees

If we come to the final decision to not make you a proposal as candidate employee, we will delete your data within a reasonable timeframe. However, if you give your specific consent to keep your details so that we can contact you again in the future in light of new opportunities, we will keep your data for a maximum of 2 years.

 

7.     From whom do we obtain your data?

We may obtain your data from you directly, because you represent or work for an organisation that is (interested in becoming) member of EURHONET, or because you represent or work for a company that we (may wish to) collaborate with.

We may also obtain your data indirectly from our members or business partners. This can be the case when you work for one of our (potential) members, or are otherwise connected to one of our members and we need your data in the context of the membership of your organisation. The same applies when you work for one of our (potential) business partners and we need your information in this regard.

We may also obtain your data indirectly from public sources. This mainly concerns limited data about your organisation that is publicly available, such as on the website of your organisation, or in the company register of your country. We do so to verify your membership application or your proposal to collaborate on behalf of an organisation.

Finally, we may consult the profile of candidate employees on professional social media platforms, or receive your details from a recruitment agency should you apply with us this way.

In the event we obtain your data indirectly, we will inform you about the processing of your data no later than at the time of our first contact with you.

 

8.     Where do we store your data and how do we protect it?

Your data is mainly stored externally with specialised third parties, such as the external service providers we engage for hosting our Website and Platform. We outsource the majority of our technical processing activities to third parties, who act as data processors on behalf of EURHONET (please refer to our explanation under title 5). We make sure your data is stored as much as possible on IT systems in the European Economic Area (EEA). The servers of the Website and Platform are located in France in particular.

Should we, for limited and specific processing activities, rely on service providers that operate from outside the EEA, data transfers will only occur to countries from which the European Commission has confirmed that they guarantee an adequate level of protection for your data, or where other measures have been taken to ensure the lawful processing of your data in these third countries.

We and our processors have taken the necessary technical and organizational measures with a view to protecting your data against loss or any form of unlawful processing. We only grant access to the data to our own employees and third parties if they need access for legitimate, relevant business purposes.

 

9.     What are your rights as a data subject?

You have various rights concerning the data we process from you. If you would like to exercise one of the rights described below, please contact us via the contact details provided under the first title of this Privacy Statement.

You have the following rights:

Rights to access and copy
You can have access to your data and receive a copy of it.

Right to rectification

You can obtain the rectification of inaccurate personal data that concerns you.

Right to erasure (‘right to be forgotten’)

You can ask us to delete your data. It is possible that it is still necessary to process this data limitedly for other purposes. For example: storing the necessary data in order to ensure we will not contact you again for marketing purposes.

Right to withdraw your consent

If the processing is based on your consent (see above under titles 5 and 6), you have the right to withdraw this consent at any time by contacting us. For newsletters or other promotional comunications that you receive from us via e-mail based on your consent, you can easily withdraw this consent by opting out via the unsubscribe link at the bottom of any such message.

Right to object

You can object to the processing of your data that is based on the legal basis of the legitimate interests of EURHONET or third parties. You also have an absolute right to object to the use of your data for direct marketing purposes, regardless of the legal basis we invoke for this processing activity. If you choose to object to the use of your data for direct marketing purposes, we will discontinue the relevant processing activities as soon as possible.

Right to restriction of the processing

You can exercise your right to restrict the processing, if you think that we process your personal data unlawfully. You can also ask we restrict the processing when you think we process inaccurate data about you, for the period needed to verify the accuracy of your data. The same applies when you object to the processing of your data. In this case you can restrict the processing for the time needed to verify our legitimate grounds to process your data.

Right to data portability

You have the right to obtain the data you provided to us in a structured, commonly used and machine-readable format. This enables you to easily transfer your data to another organisation. You can also ask us to directly transmit your data to another organisation. It might however be technically impossible to directly transmit your data to another organisation.

Right to lodge a complaint with a data protection authority

You also have the right to lodge a complaint with a competent supervisory authority in the field of data protection. Hereunder we refer to the contact details of the Belgian Data Protection Authority, since our network is administered by our Secretariat in Belgium. However, you can also lodge a complaint with the national supervisory authority of the EEA state where you have your habitual residence or place of work, or where the potential infringement occurred. For further information and the contact details of the supervisory authority of each EEA state, we refer to this web page of the European Data Protection Board.

Belgian Data Protection Authority

Drukpersstraat 35
1000 Brussels
+32 (0)2 274 48 00

contact@apd-gba.be

Website DPA – file a complaint

Finally, you also have the option to file a legal claim against EURHONET with the competent court in the EEA state where you have your habitual residence.

 

10.  How can you exercise your rights?

You can exercise the rights mentioned under title 9 by contacting EURHONET via the contact details provided under the first title of this Privacy Statement.

When you submit a request to exercise your rights, we will verify your identity if we have any doubts in this regard. We do so to prevent your data from falling into the wrong hands. If we have doubts about your identity, we will request you to provide us with documents that enable you to identify yourself without a reasonable doubt, such as a copy of your identity card. In this case we urge you to cross out the non-relevant information for the verification of your identity, such as your national citizen number and photo.

Exercising your rights is in principle free of charge. However, if your request appears to be manifestly unfounded or excessive (in particular because of its repetitive character), we may charge you a reasonable fee to charge our own administrative costs. In such cases, we may also simply opt to reject your request. In this event, you will be notified of the reasons for such decision.

In normal circumstances, you can expect a substantive answer to your request or complaint within one month. In case of complex or multiple requests, this period can be extended to 3 months, in which event you will be notified by EURHONET of the reasons for the delay.

 

11.   What if we modify this Privacy Statement?

We may unilaterally decide to modify this Privacy Statement. The most recent version is available on our Website and Platform at any time. We will however inform you directly – if possible – in the event of a substantial modification of the Privacy Statement that is relevant for you. You can find the date on which our Privacy Statement was last modified at the top of this page.