Global Web Privacy And Cookie Policy

PRIVACY POLICY

Version: 1.0 Last updated: October 13, 2025


This Privacy Policy describes how CBRE SA, a Belgian public limited company registered under number BE 0412.578.810 (hereinafter "we", "our", or "CBRE") collects, uses, and protects your personal information when you use PropertyWeb, accessible at https://propertyweb.be (the "Site" or the "Services").

Questions or concerns? Reading this Policy will help you understand your privacy rights and choices. We are responsible for decisions regarding the processing of your personal information. If you do not accept our policies and practices, please do not use our Services.


KEY POINTS SUMMARY

This summary presents key points from our Privacy Policy. You can find more details on each point by clicking the corresponding link or using our table of contents below.

What personal information do we collect?
When you create an account or use our Services, we collect the information you provide: email, password, name, first name (if Google), phone (optional), saved search strategies, notification preferences. Learn more about the information we collect.

Do we collect sensitive information?
No. We do not process any sensitive information.

Do we collect information from third parties?
Yes. If you sign in via Google, we receive your email, name, first name, and profile photo. Learn more about information collected from third parties.

How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, and ensure security. Learn more about how we use your information.

When do we share your information?
We may share your information with our hosts (Digital Ocean, Firebase), our CRM (Efficy), and other technical subcontractors. We may also contact you outside PropertyWeb context for CBRE marketing purposes if you consented. Learn more about when and with whom we share your information.

What are your rights?
Depending on your location, you have certain rights regarding your personal information. Learn more about your rights.

How to exercise your rights?
The easiest way is to log into your account (/profile) or contact us directly via [email protected] or [email protected]


TABLE OF CONTENTS

  1. What information do we collect?
  2. How do we use your information?
  3. When and with whom do we share your information?
  4. Do we use cookies and tracking technologies?
  5. How do we handle Google sign-in?
  6. Is your information transferred internationally?
  7. How long do we keep your information?
  8. Do we collect information from minors?
  9. What are your privacy rights?
  10. Do-Not-Track controls
  11. Do we make updates to this policy?
  12. How can you contact us?
  13. How can you review, update, or delete your data?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you provide to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you:

  • Create an account on PropertyWeb
  • Complete the supplementary data form
  • Use the Services
  • Contact us

A. Account created by email and password

When you create an account with email and password, we collect:

  • Email address (required)
  • Password (encrypted and hashed by Firebase)
  • Account creation date
  • Last login date

B. Account created via Google

When you create an account via Google, we receive from Google:

  • Email address
  • First name and last name
  • Profile photo (if available)
  • Google unique identifier (for authentication)

Important: We NEVER receive your Google password.

C. Supplementary data from form

You may voluntarily provide via our form:

Contact information:

  • First name and last name (if not provided by Google)
  • Phone number (optional)
  • Language preference (FR/NL/EN)
  • Title (optional)

Search strategies:

  • Type of search strategy (e.g., purchase, lease)
  • Surface area criteria
  • Rental price range
  • Purchase price range
  • Country searched
  • Province searched

We do NOT collect:

  • Postal address
  • Company name or position (unless voluntarily provided in title field)
  • Detailed browsing history
  • Geolocation data

D. Service usage data

When using PropertyWeb, we collect:

  • Saved search strategies:
    • Search criteria (property type, location, surface area, price, etc.)
    • Name given to the search (optional)
    • Creation and last use dates
  • Notification preferences:
    • Activation/deactivation of email notifications for new properties
    • Language preference (FR/NL/EN)

E. Data stored in CRM

Important: Your contact information and search strategies are also stored in our CRM (Efficy) for customer relationship management purposes.

If you consent to marketing communications, we may contact you outside the PropertyWeb context for other CBRE real estate services and opportunities.

Sensitive information

We do not process any sensitive information (racial or ethnic origin, political opinions, religious beliefs, health data, sexual orientation, etc.).

Information accuracy

All personal information you provide must be truthful, complete, and accurate. You must inform us of any changes from your /profile page.


Information automatically collected

In short: Certain information (IP address, browser and device characteristics) is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate our Services. This information does not reveal your specific identity but may include:

  • IP address
  • Browser type and version
  • Operating system
  • Language preferences
  • Referring URL
  • Country (via IP address)
  • Visit date and time
  • Pages viewed

Connection history managed by Firebase:

  • Login dates and times
  • Authentication method used (email/password or Google)
  • Session duration

Technical logs managed by Firebase:

  • Error logs
  • Performance metrics
  • Security events

This information is primarily necessary to maintain the security and operation of our Services, as well as for internal analysis purposes.

Like many businesses, we also collect information via cookies and similar technologies. See the Cookies section for more details.


2. HOW DO WE USE YOUR INFORMATION?

In short: We use your information to provide, improve, and administer our Services, communicate with you, and ensure security and fraud prevention.

We process your personal information for various reasons, depending on how you interact with our Services:

A. Account management (Legal basis: Contract performance)

  • Create and manage your user account
  • Authenticate you during login (via Firebase)
  • Uniquely identify you
  • Respond to your requests and questions

B. Services functionality (Legal basis: Contract performance)

  • Save your search strategies: Store your search criteria for quick access
  • Synchronize across multiple devices: Allow you to access your searches from different devices
  • Personalize your experience: Display your recent and frequent searches

C. Communications (Legal basis: Consent)

PropertyWeb context:

  • Email notifications: Inform you of new properties matching your saved search strategies (only if you activated this option)

CBRE marketing context (outside PropertyWeb):

  • Marketing communications: If you consented to receive marketing communications, we may contact you about other CBRE real estate services and opportunities based on your contact information stored in our CRM
  • Promotional emails: Information about CBRE events, services, and market insights

Service emails (no consent required):

  • Account creation confirmation
  • Password reset
  • Account deletion confirmation

D. Services improvement (Legal basis: Legitimate interest)

  • Analyze site usage to improve our features
  • Identify and correct bugs
  • Optimize performance
  • Develop new features

Search strategies for analytics:

  • After account deletion, search strategies are anonymized (unlinked from your contact information) and retained for analytical purposes to improve our services and understand market trends

E. Security and compliance (Legal basis: Legal obligation / Legitimate interest)

  • Prevent fraud and abuse
  • Ensure Site security (managed by Firebase)
  • Comply with our legal obligations
  • Enforce our Terms of Use

3. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?

In short: We may share your information in specific situations described in this section and with certain third parties.

A. Hosts and technical infrastructure

We share your information with our hosting and infrastructure providers:

Digital Ocean

  • Services: Server hosting
  • Location: Amsterdam (Netherlands) and London (United Kingdom)
  • Data processed: All application data

Firebase (Google Cloud)

  • Services: Database (Firestore), file storage (Storage), authentication
  • Location:
    • Firestore: eur3 (Europe)
    • Storage: us-east1 (United States)
    • Authentication: Multi-region
  • Data processed: Account data, saved searches, authentication credentials (hashed passwords), connection history, technical logs

B. CRM and management tools

Efficy CRM

  • Services: Customer relationship management
  • Location: Servers in London (United Kingdom), managed by CBRE Digital & Technology
  • Data processed: Contact information (email, phone, name, title, language), search strategies
  • Purpose: Customer relationship management, potential contact for CBRE services outside PropertyWeb context (if you consented to marketing communications)

C. Authentication providers

Google (OAuth) If you sign in via Google, your information is also processed by Google in accordance with their privacy policy: https://policies.google.com/privacy

D. CBRE affiliates

We may share your information with other CBRE group entities to:

  • Provide integrated services
  • Improve our Services
  • Manage our international technical infrastructure (CBRE Digital & Technology)

E. Business partners

We may share information with real estate advertisers and agents to:

  • Offer you properties matching your searches
  • Process your contact requests for properties

F. Specific situations

We may also disclose your information:

Business transfers: In case of merger, acquisition, sale of assets, or CBRE restructuring

Legal obligations: When required by law, court order, administrative authority, or to:

  • Comply with our legal obligations
  • Protect our rights and property
  • Prevent fraud
  • Ensure user safety

With your consent: In other situations with your explicit agreement


4. DO WE USE COOKIES AND TRACKING TECHNOLOGIES?

In short: Yes, we use cookies and similar technologies to collect and store information.

What is a cookie?

A cookie is a small text file stored on your device (computer, phone, tablet) by a website. Cookies facilitate navigation and make site use more user-friendly.

How do we use cookies?

We use session cookies (temporary, deleted when browser closes) and persistent cookies (remain on your device until expiration or deletion).

Cookies used on PropertyWeb

Required cookies (no consent required)

These cookies are essential for Site operation:

| Cookie | Duration | Purpose | | ----------- | ---------- | ----------------------------------------------------- | | __session | 1 year | Maintain your connection, session management | | __cf_bm | 30 minutes | Cloudflare Bot Management - security, DDoS protection |

Functional cookies (consent required)

These cookies improve your experience:

| Cookie | Duration | Purpose | | ------------ | -------- | ---------------------------------------------------- | | user-prefs | 1 year | Remember your cookie consent choices and preferences |

Analytics cookies (consent required)

To analyze Site usage and improve it:

| Cookie | Duration | Purpose | | ---------------- | -------- | ------------------------------------------------------ | | _ga | 1 year | Google Analytics - main cookie for user identification | | _ga_JPHC6L0NT9 | 1 year | Google Analytics 4 - session and engagement tracking |

These cookies are anonymized and do not allow personal identification.

Advertising cookies (consent required)

For targeted advertising:

| Cookie | Duration | Purpose | | --------- | -------- | ---------------------------------------------------- | | _gcl_au | 90 days | Google Ads - conversion tracking and ad optimization |

Additional tracking technologies

We also use:

  • Web beacons (invisible pixels) in emails to know if they were opened
  • Browser local storage to improve performance

Third-party cookies

Third parties (Google, advertisers) may also place cookies on your device when using PropertyWeb. We do not control these third-party cookies. Consult their respective privacy policies.

How to manage your cookies?

Option 1: Consent banner On your first visit, a banner allows you to:

  • Accept all cookies
  • Customize your preferences
  • Refuse non-essential cookies

Option 2: Browser settings You can configure your browser to:

  • Block all cookies
  • Accept only certain cookies
  • Delete existing cookies

Useful links:

  • Chrome: chrome://settings/cookies
  • Firefox: about:preferences#privacy
  • Safari: Preferences > Privacy
  • Edge: edge://settings/privacy

More information: https://www.allaboutcookies.org

Warning: Blocking certain cookies may affect Site operation (inability to stay logged in, loss of preferences).


5. HOW DO WE HANDLE GOOGLE SIGN-IN?

In short: If you choose to sign in via Google, we receive certain information from your Google profile.

Google sign-in

PropertyWeb offers the ability to register and sign in using your Google account.

Information received from Google

When you choose this option, Google transmits to us:

  • Email address
  • First name and last name
  • Profile photo
  • Google unique identifier

Exact information may vary depending on your Google privacy settings.

Use of this information

We use this information only to:

  • Create and manage your PropertyWeb account
  • Authenticate you during logins
  • Personalize your experience (display your name and photo)

What we do NOT do

  • We do NOT access your other Google data (Gmail, Drive, Calendar, etc.)
  • We NEVER receive your Google password
  • We do NOT post anything to your Google account without your permission

Control your permissions

You can at any time:

Revoke PropertyWeb access:

  1. Go to https://myaccount.google.com/permissions
  2. Find "PropertyWeb" in the list
  3. Click "Remove access"

Disconnect your Google account from PropertyWeb:
From your "My Account" page (/profile)

Google Privacy Policy

Use of your Google account is also governed by Google's Privacy Policy: https://policies.google.com/privacy

We recommend reviewing it to understand how Google collects, uses, and shares your information.


6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In short: Your information may be transferred to and processed in countries other than your own.

Location of our servers and services

Our services are hosted on different infrastructures:

Digital Ocean

  • Location: Amsterdam (Netherlands) and London (United Kingdom)
  • Compliance: Servers located in European Union and United Kingdom

Firebase (Google Cloud)

  • Firestore (database): Region eur3 (Europe)
  • Storage (files): Region us-east1 (United States)
  • Authentication: Multi-region

Efficy CRM

  • Location: Servers in London (United Kingdom)
  • Management: CBRE Digital & Technology

International transfers

Your information may be transferred to countries outside the European Economic Area (EEA), particularly to the United States (Firebase Storage).

Safeguards for transfers outside EU

When we transfer your personal data outside the European Union, we ensure that:

Standard Contractual Clauses (SCC): We have implemented Standard Contractual Clauses approved by the European Commission with our subcontractors

Appropriate security measures:

  • Data encryption in transit (HTTPS/TLS)
  • Data encryption at rest
  • Strict access controls
  • Regular security audits

GDPR compliance: All transfers comply with GDPR requirements and are governed by compliant subprocessing agreements

Services complying with data protection decisions

  • Google Cloud/Firebase: Complies with EU Standard Contractual Clauses
  • Digital Ocean: EU/UK servers with GDPR compliance
  • Efficy: UK servers with GDPR compliance

Your rights

If you are a resident of the European Economic Area (EEA), United Kingdom, or Switzerland, you benefit from full GDPR protection, even if your data is transferred outside the EU.


7. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information as long as necessary to fulfill the purposes described in this Policy, unless longer retention is required by law.

Retention period by data type

| Data type | Retention period | | --------------------------- | --------------------------------------------------------------------- | | Active account | As long as your account exists | | Saved search strategies | As long as your account exists | | User preferences | As long as your account exists | | Connection history | Managed by Firebase, deleted upon account deletion | | Technical logs | Managed by Firebase, deleted upon account deletion | | Cookies | See Cookies section |

After account deletion

When you delete your account from /profile:

Temporary retention (1 month maximum):

  • Your data is retained for 1 month to allow:
    • Recovery in case of accidental deletion (if you contact us quickly)
    • Completion of ongoing technical processes
    • Compliance with our legal obligations

Permanent deletion (after 1 month):

  • Email and password (Firebase authentication)
  • Name and first name
  • Phone
  • Contact information in CRM
  • Connection history (Firebase)
  • User preferences

Anonymization (retained indefinitely):

  • Search strategies: Unlinked from your contact information and retained for analytical purposes
    • Purpose: Improve our services, understand market trends, optimize property recommendations
    • These anonymized strategies cannot be traced back to you

Legal exceptions

We may retain certain information longer if:

  • Required by law (accounting, tax obligations)
  • Necessary to defend our legal rights (ongoing litigation)
  • Necessary to prevent fraud

In these cases, data is isolated and access is strictly limited.


8. DO WE COLLECT INFORMATION FROM MINORS?

In short: No. We do not knowingly collect data from persons under 18 years of age.

PropertyWeb is not intended for persons under 18 years of age.

We do not knowingly collect personal information from minors under 18 years of age, nor do we market our Services to them.

If you are a minor

If you are under 18 years old, you may not create an account on PropertyWeb without authorization and direct supervision of a parent or legal guardian.

If you are a parent or guardian

By using the Services, you represent:

  • That you are at least 18 years old
  • OR that you are the parent or guardian of a minor and consent to their use of the Services

If we discover data from minors

If we learn that we have collected personal information from a person under 18 years of age without parental consent verification:

  1. We will immediately disable the account
  2. We will take reasonable measures to promptly delete such data

If you believe we have data from a minor, contact us immediately: [email protected]


9. WHAT ARE YOUR PRIVACY RIGHTS?

In short: Depending on your location, you have rights regarding your personal information. You can view, modify, or delete your account at any time via /profile.

Your rights under GDPR (EU/EEA/Belgium residents)

If you are a resident of the European Union, European Economic Area, or Belgium, you have the following rights:

1. Right of access Obtain confirmation that we process your data and receive a copy of your personal information.

How to exercise:

2. Right to rectification Correct any inaccurate or incomplete information.

How to exercise:

  • Modify your information from /profile
  • Or contact us

3. Right to erasure ("right to be forgotten") Request deletion of your personal data.

How to exercise:

  • Click "Delete my account" on your /profile page
  • Or contact us

Note: Your data will be retained for 1 month then permanently deleted.

Exceptions: We may refuse if we must retain data to:

  • Comply with legal obligation
  • Establish, exercise, or defend legal rights

4. Right to data portability Receive your data in structured, commonly used, machine-readable format, and transmit to another controller.

How to exercise:

You will receive: A JSON file containing all your data (email, name, phone, saved search strategies, dates).

5. Right to object Object to processing of your data for reasons relating to your particular situation.

How to exercise: Contact us at [email protected] or [email protected]

6. Right to restriction of processing Request restriction of processing of your data under certain circumstances.

How to exercise: Contact us.

7. Right to withdraw consent If we process your data based on your consent (email notifications for new properties, marketing communications), you can withdraw it at any time.

How to exercise:

  • Deactivate notifications from /profile
  • Click "Unsubscribe" in received emails
  • Contact us

Note: Withdrawal of consent does not affect lawfulness of processing prior to withdrawal.

Account management

Modify your information

  1. Log into PropertyWeb
  2. Go to /profile
  3. Modify your information
  4. Save changes

Delete your account

  1. Log into PropertyWeb
  2. Go to /profile
  3. Click "Delete my account"
  4. Confirm deletion

Consequences of deletion:

  • Retention for 1 month then permanent deletion
  • Loss of access to saved searches
  • Impossible to recover your account after 1 month
  • You will receive confirmation email

Unsubscribe from notification emails

To unsubscribe from new property notifications:

Option 1: Deactivate from /profile > "Notification preferences"

Option 2: Click "Unsubscribe" in any received email

Option 3: Send email to [email protected] with "UNSUBSCRIBE" as subject

To unsubscribe from CBRE marketing communications (outside PropertyWeb):

Contact: [email protected] or [email protected]

Note: You will continue to receive essential service emails (account confirmation, password reset, deletion confirmation).

Complaint to data protection authority

If you believe your rights have not been respected, you may lodge a complaint with:

Belgium - Data Protection Authority (DPA)
Rue de la Presse, 35
1000 Brussels
Belgium
Phone: +32 2 274 48 00
Email: [email protected]
Website: https://www.autoriteprotectiondonnees.be

European Union - Other countries
Consult list of data protection authorities: https://edpb.europa.eu/about-edpb/board/members_en


10. DO-NOT-TRACK CONTROLS

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

Our position: Currently, no uniform technology standard for recognizing and implementing DNT signals has been finalized. Therefore, we do not currently respond to DNT signals.

If a standard for online tracking is adopted that we must follow in the future, we will inform you of this practice in a revised version of this Privacy Policy.


11. DO WE MAKE UPDATES TO THIS POLICY?

In short: Yes, we will update this policy as necessary to stay compliant with applicable laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Policy.

How will you be informed of changes?

Minor changes: Update of date at top of Policy

Significant changes: We will inform you by:

  • Email to address associated with your account
  • Prominent notice on Site
  • Banner upon next login

Your acceptance

Your continued use of Services after publication of changes constitutes your acceptance of changes.

We encourage you to review this Policy regularly to stay informed about how we protect your information.


12. HOW CAN YOU CONTACT US?

If you have questions or comments about this Privacy Policy, you can contact us:

General contact

Email: [email protected]
Phone: +32 2 643 33 33

Postal address:
CBRE SA
Boulevard de Waterloo, 16
1000 Brussels
Belgium
Enterprise number: BE 0412.578.810

Data protection contact

For any specific questions regarding your personal data and rights:

Global:
[email protected]

Europe, Middle East, Africa (EMEA):
[email protected]

Asia, Pacific (APAC):
[email protected]

Response time: We commit to respond to your requests within a maximum of 1 month from receipt.


13. HOW CAN YOU REVIEW, UPDATE, OR DELETE YOUR DATA?

Depending on applicable laws of your country, you have the right to request access to personal information we collect, details on how we processed it, correct inaccuracies, or delete your personal information.

You may also have the right to withdraw your consent to processing of your personal information.

Options to exercise your rights

Option 1: From your account (fastest)

  1. Log into PropertyWeb
  2. Go to /profile
  3. View, modify, or export your data
  4. Delete your account if desired

Option 2: By email

Send your request to: [email protected]

Or for specific data protection questions:

Include in your request:

  • Your full name
  • Your email address associated with account
  • Nature of request (access, rectification, deletion, portability)
  • Proof of identity if necessary

Option 3: By mail

CBRE SA
Boulevard de Waterloo, 16
1000 Brussels
Belgium
Attention: Data Protection Service

Processing time

We will process your request within a maximum of 1 month from receipt.

If your request is particularly complex, this period may be extended by 2 additional months. We will inform you within 30 days of receiving your request.

Identity verification

To protect your privacy and security, we may ask you to verify your identity before acting on your request.


CONTACT US FOR ANY QUESTIONS

For any questions regarding this Privacy Policy or your personal data:

General email: [email protected]
Data protection email (Global): [email protected]
Data protection email (EMEA): [email protected]
Phone: +32 2 643 33 33
Address: Boulevard de Waterloo, 16, 1000 Brussels, Belgium

We are committed to protecting your privacy and personal data.


This Privacy Policy is governed by Belgian law and the General Data Protection Regulation (GDPR).

Prices and rents on this website are indicative only, non-binding and subject to change.

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