Privacy policy

Data Protection Policy  ?  Mykot

Latest update 15/05/2023

 

Introduction

About Mykot

 

The Mykot website (a name that refers to www.mykot.be) provides access to and provides certain services that you use and/or participate in.

 

The MyKot platform seeks to bring together students and landlords of kots in a simple way. This is only possible if personal data is provided and processed by the users. Through this Privacy Policy, Mykot wishes to inform users of the platform about how your personal data is collected, processed and used.

 

This Privacy Policy may be modified, for example, in response to new features on the website. We therefore recommend that you regularly consult this Privacy Policy. Important changes will be announced through our website. This version of the Privacy Policy was last amended on May 15th, 2023.

 

The MyKot platform is jointly managed by:

 

1. VZW Brik ? Student in Brussel (hereinafter ?Brik?), registered in the Crossroads Bank for Enterprises under the number 0464.281.788 and with registered office located at Zavelput 20, 1000 Brussels. 

 

2. PLATEFORME LOGEMENT ETUDIANT (hereinafter ?PLE?), registered in the Crossroads Bank for Enterprises under the number 0506.675.837 and with registered office located at Avenue Franklin Roosevelt 50, Box 129-05, 1050 Brussels.

In the context of its activities and services, MyKot processes, among other things, personal data of users. With respect to these processing activities, Brik and PLE act as "Joint Controllers" pursuant to Article 26 of the General Data Protection Regulation, they are responsible for the protection of your personal data. In this capacity, Brik and PLE shall endeavour to comply with applicable data protection laws, such as, as of May 25, 2018, the European General Data Protection Regulation 2016/679 (the "Regulation" or the "GDPR") and any applicable national laws implementing EU Directive 95/46 in relation to the processing of personal data or which further supplement the GDPR.

 

  1. Brik and PLE are committed to your privacy

 

Brik and PLE strive to be trusted partners and therefore want to respect and protect your personal data.

This Data Protection Policy aims to explain how we collect, store, use and disclose your personal data each time you use our products and services, our websites or otherwise interact with us. This Data Protection Policy also lists your rights and explains how to exercise those rights.

Please read this Data Protection Policy carefully so that our processing of your personal data is as transparent as possible.

Please also ensure that your employees are properly informed about the processing of their personal data by Brik and PLE, and that where necessary, their consent is obtained with the data processing, as described in this Data Protection Policy.

 

  1. The following principles are central to the way we process your personal data

 

  • Transparency and fairness: When we collect and process your personal data, we will inform you about who collects and receives it, and why.

  • Lawfulness:  Brik and PLE do not collect or process personal data without lawful grounds. Where required by law, we will always seek your prior consent (e.g. to the extent necessary in the context of a direct marketing campaign).

  • Finality: We use your personal data for pertinent business purposes (e.g., to provide services, to manage relationships with tenants or lessees, for marketing activities, to better serve users, to conduct satisfaction surveys, to prepare reports and to fulfill our legal obligations). We never use your personal data for purposes incompatible with those stated in this Data Protection Policy or communicated to you elsewhere.

  • Necessity and proportionality: We only collect personal data that is necessary for data processing, as explained in this Data Protection Policy. We collect sensitive data only when relevant. We take all reasonable measures to ensure that your personal data is accurate, complete and up-to-date. We provide your data to service partners and providers only to the extent necessary to provide our services or fulfill legal obligations.

These principles are further outlined in various points below.

  1. What activities does data collection cover?

This Data Protection Policy applies to all data sources collected and processed by Brik and PLE in the context of carrying out its activities and services.

 

  1. Whose personal data are processed?

We may collect and process your personal data depending on the capacity in which you use the Mykot platform.

 

If you register on this as a landlord, the following categories will be processed:

 

  • Name and first name
  • Language 
  • Gender
  • Phone number
  • Email address
  • Address information
  • Company data
  • Activity on the Mykot platform (e.g., IP address, location data, etc.).
  • Account number (optional)
  • Further data that you add to the Mykot platform (including landlord studios/rooms)

 

If you register on the Mykot platform as a tenant, the following categories will be processed:

 

  • Name and first name
  • Language 
  • Gender
  • E-mail address
  • Address information (optional)
  • School (optional)
  • Account number (optional)
  • Activities on the Mykot platform (e.g., IP address, location data, etc.).
  • Further data you add to the Mykot platform 

 

If you visit the platform purely without registering, personal data will be collected purely on the basis of cookies (see Title 5), mainly processing the IP address, location data and previous visits.

 

  1. How do we collect your personal data?

Brik and PLE may collect your personal information in several ways:

 

  • We collect your personal data directly from you during our interaction with you (e.g., when you contact Brik or PLE, Brik or PLE may retain that correspondence), when you fill out an online (application) form, when you create an account on one of our websites, etc.

 

  • We might also ask you to complete surveys that we use for research purposes, even if you are not required to respond to them.

 

  • We may store details of your visits to our website including, but not limited to, data traffic data, location data, weblogs and other communication data, and the resources you access.

 

  • We may also collect data about your computer or device, such as IP address, operating system, or browser type. This data is collected for the proper management and operation of our websites. To collect this data, we use cookies.

 

  1. Cookies 

To provide you with a better experience when you visit our website(s), we collect certain information automatically using technologies. Our website(s) uses cookies or similar technologies. Cookies are small text files that your browser stores on your computer when you visit a website. They serve, for example, to remember your preferences on a website, the IP address and location data or can be used for statistical purposes.

 

You can always choose to disable cookies and delete those already stored. You can do this by adjusting your browser settings. For this we refer you to the support page of your web browser.

 

If you use our websites, we may collect information about the browser you are using and your browsing habits.

For the rest, we refer you to our cookie policy, which contains more information about the processing of data in this context.

  1. For what purposes do we use your personal data?

Brik and PLE will only process your personal data in the cases permitted in accordance with the processing grounds provided by article 6.1 GDPR.

 

Brik and PLE will process your personal data for the following possible purposes and any other compatible purposes:

  • To comply with legal obligations and protect the interests and assets of Brik and PLE.

  • To communicate with you: you can contact us in various ways (through our website, by phone, by email ...) to ask us questions, request information, provide comments, etc. We use your personal data to communicate with you and answer your questions.

  • To provide services for which you register on the MyKot platform, namely putting landlords and tenants in the market of student rooms in contact with each other and making it possible to easily conclude an agreement between parties. In the process, data is exchanged between tenant and landlord (execution of agreement).

  • To collect anonymous statistical data about the Brussels student rental market.
  • To use internet portals.

  • To report to landlords on the results of satisfaction surveys.

  • For management reporting, such as audits, internal control, data analysis.

  • To maintain business records for legal, administrative and audit purposes.

  • For marketing purposes: we may use your information to contact you, about new offers or services and special offers that we think you will find valuable, or to send you marketing messages or newsletters. We may analyze your customer profile and preferences and run multi-channel marketing campaigns through automated tools, contact you via text message, email or send you brochures.

  • For customer/driver satisfaction surveys based on targeted marketing tools and analytics, we may send you qualitative surveys for our products and services.

  • For websites, cookies & occasional newsletters: we may collect data via cookies to enhance our know-how and noticeably improve your browsing experience by storing your preferences and parameters to save you time (such as language preferences), facilitate login, prevent fraud and analyze the performance of our websites and services. We may also occasionally notify you of events or communications that we believe are relevant to you, the user of the platform. These include, for example, new regulations or the 'OpenKotDagen'.

This data helps us improve our websites and better understand which products and services you would prefer.

We also use Internet analytics cookies to measure website activity and identify which areas of the websites are visited most frequently.

While we may install functional cookies to facilitate your visit to our websites, you can express your preferences regarding cookies used for behavioral advertising. This can be done through your browser's privacy settings options, which should include features to prevent data being stored on the terminal or processing data already stored on that terminal unless you enable the feature that allows such storage or processing.

Please consult our Cookies Policy on our websites for more information.

  • For profiling: to better understand your interests and concerns, we may use your personal data to improve our website and services, customize your experience with us, and tailor our marketing activities to your needs and interests.

 

  1. On what grounds do we process your personal data?

 If applicable, Brik and PLE will process your personal data on the following legitimate grounds:

  • the performance or preparation of your agreement with Brik and PLE ;

  • your prior and informed consent, where required;

  • compliance with our legal obligations ;

  • the legitimate interests of Brik, PLE or a third party, insofar as these interests prevail over your interests and fundamental rights and freedoms, such as, where appropriate, for thorough investigation of the counterparty, to provide you with useful information, etc.

 

  1. With whom do we share your personal data?

In principle, your data will only be processed internally by Brik and PLE (and any associated companies or legal successors). If necessary, third-party software will be used for this purpose. Under no circumstances will your data be sold to third parties.  Brik and PLE guarantees that any processing performed by or on its behalf by a processor will be done in accordance with applicable regulations.

 

In order to offer our services and also to keep them optimal, we sometimes need to use certain external parties. We limit the provision of your personal data to the following categories of recipients:

  • Internal staff of Brik and PLE
  • Our service providers such as:
    • Internet environment (hosting website); 
    • IT-infrastructuur (Servers, CRM, mailservice edm.);
    • ISP and telephony providers;
    • Platform management and data analysis regarding operation and digital strategy platform;
    • Software developers and administrators;

 

Since these external parties may come into contact with personal data, Brik and PLE always enter into the necessary processor agreements with such external parties in order to ensure adequate protection of personal data.

 

  • authorities when required by law, such as in response to a subpoena, including law enforcement agencies and courts, etc.

We understand that you do not want us to provide your personal data directly to third parties for their own marketing purposes without your consent.

Please note that we may also use and provide personal data about you that is not personally identifiable, i.e. data in aggregate form that no longer identifies you.

  1. How will your personal data be stored and transmitted?

Brik and PLE are committed to ensuring that your personal data:

 

  • are protected against accidental or intentional destruction / loss; 

  • are used properly and

  • are not accessible to unauthorized persons.

 

All information you provide to us is stored on our secure servers. Your personal data will be stored in our databases or in the database of our service providers.

 

  1. How long do we keep your personal data?

We generally retain your personal data for as long as necessary for the purposes described in Title 6 of this Data Protection Policy, or in accordance with relevant applicable laws. We will retain your personal data for no longer than is strictly necessary to fulfill the purposes for which the data was collected.

Brik and PLE will therefore retain your data for as long as you use and are registered on the MyKot platform. You can delete your account on the MyKot platform at any time. In this case, your personal data will be retained for a maximum of one month, except where the MyKot platform is required to do so by law. After this period, all personal data will be deleted.

For example, we will retain your personal data for as long as necessary to fulfill Brik and PLE's legal obligations.

In the event of a dispute, we may retain your personal data until complete settlement of the dispute. We will then delete or archive them according to applicable law.

 

  1. How do we ensure the security and integrity of your personal data?

We protect your data through technical and organizational security measures against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against any other form of unlawful processing.

 

In addition, Brik and PLE continuously monitor the security of personal data held and processed within their organization. As the controller, Brik and PLE undertake to take all necessary technical and organizational measures to prevent unauthorized persons from accessing the personal data entrusted to it. In doing so, it also seeks to prevent the loss, destruction or unauthorized distribution of such data.

 

Brik and PLE use systems that are regularly updated, allow encryption of the data and contain firewalls that comply with the applicable standard in this regard.  Brik and PLE undertake to inform you of any breach of this Privacy Policy that may have a serious impact on you.

 

When we outsource data processing, we impose contractual obligations to protect your information.

 

  1. How can you control and express your preferences for the use of your personal data?

You may exercise a number of rights with respect to the processing of your personal data against Brik and PLE, to the extent that you actually have these rights under applicable data protection laws, such as the GDPR.

To exercise the rights set forth in this section, you may at any time contact Brik and PLE's data protection correspondent (see section 13) who will handle your request.

Objection. You have the right to object at any time to the processing of your personal data on the grounds of a legitimate interest of Brik and PLE, for example when they are used for (direct) marketing purposes, for profiling to send you targeted advertising or to share your data with third parties or other entities within Brik and PLE.

Withdrawal. If you have previously consented to the processing of your personal data, you may withdraw such consent at any time. This does not affect the lawfulness of the processing based on the consent prior to its withdrawal.

Inspection. You may request to see or request a copy of the personal data we hold about you. You can also request information about the purposes of processing, data categories, categories of recipients, retention periods, etc.

Transferability. You may have the right to obtain a copy of all personal data we hold about you in a compatible format to enable you to exercise your right to data portability.

Restriction. You have the right to request a restriction on the processing of your personal data in the following cases:

  • for a period of time to allow Brik and PLE to verify the accuracy of your personal data if you dispute the accuracy of your personal data;

  • if the processing is unlawful and you wish to limit the use of your personal data instead of having it erased;

  • if you want Brik and PLE to retain your personal data because you need it for your defense in legal claims;

  • if you have objected to the processing but Brik and PLE needs to verify whether they have lawful grounds for such processing which may override your own rights.

Correction. You may also have the right to correct inaccurate personal data and complete incomplete personal data.

Erasure. You may have the right to request that your personal data be deleted in the following cases:

  • if your personal data are no longer necessary for the purpose of data processing;

  • if you have withdrawn your consent and there is no lawful ground for the processing;

  • if you have opposed the processing of the data and there is no predominant lawful ground for Brik and PLE;

  • if the personal data have been processed unlawfully;

  • if the personal data must be deleted in order to comply with a legal obligation applicable to Brik and PLE.

In case of erasure, we will take responsible steps to inform other entities of Brik and PLE that may be involved in data processing of such erasure.

Complaint. You also have the right to lodge a complaint with the competent supervisory authority if you are concerned about the terms of Brik and PLE's processing of your personal data (the Data Protection Authority, Drukpersstraat 35, 1000 Brussel, contact@apd-gba.bewww.gegevensbeschermingsautoriteit.be).

  1. Who should you contact if you have questions or concerns about the processing of your personal data?

Brik has a data processing officer (DPO). You can reach this DPO at info@mykot.be.

 

PLE has a data processing officer (DPO). You can reach this DPO at info@mykot.be

Consequently, any questions, complaints or comments regarding this Data Protection Policy or our data processing practices should be sent by email to the email address listed above.

 

  1. What happens when we change this Data Protection Policy?

Our Data Protection Policy may change from time to time to reflect changes in how we process your personal data. We encourage you to check our websites from time to time to have the most recent version of our Data Protection Policy. We will notify you of significant changes as required by law. 

You can check the date of the last revision of this Data Protection Policy at the beginning of this document.