Comenstay is dedicated to safeguarding the privacy of its users and regards the protection of personal data as a crucial responsibility.

The Comenstay Privacy Policy regulates the collection, usage, maintenance, and disclosure of information obtained from users through the www.comenstay.be website, and any other services offered by Comenstay, regardless of the user’s (referred to as “you”, “your”, or “yours”) location. It is important for you to read the Comenstay Privacy Policy.

By using our services, you will be considered to have agreed to the conditions set forth in the Comenstay Privacy Policy.

About Comenstay

The Website (described below) is operated by Comenstay. Our handling of your personal data is regulated by the General Data Protection Regulation (GDPR). For the purposes of the GDPR, we are a controller of your personal data. Further information on how to contact us is set out below in Section “Contact Us”.

Definition

“Comenstay“ means us, a company that manages properties in Brussels, Belgium, and rents them to couples and groups for gatherings, events, and team buildings.

“Website“/”Site” means the Comenstay Website, www.comenstay.be, used to discover Comenstay, look for a property, contact Comenstay to book a property, learn about Brussels and Belgium, etc. It is the property of and is managed by Comenstay and its subsidiaries.

“Services“ means the delivery of accommodation services through our Website.

“User“ means any individual who provides their email address or personal information on the Site, whether they are a client, prospective client, or visitor. Personal information may be collected directly from the User or through the use of cookies or other technologies, as outlined in this Policy and our Cookies Policy.

What information do we collect?

The categories of personal data we collect vary based on the activities performed on the Website. Here are a few examples of the types of data we may collect:

Category	Examples
Identity Data	Name, first name, birth date
Contact Data	Current address, location, telephone numbers, email addresses
Financial Data	Bank details for rent payments
Transaction Data	Bookings, services requested, rent payments, refunds
Profile Data	Account information
Marketing and Comm. Data	Newsletter and cookie preferences
Device Data	IP address, device information
Location Data	GPS location for bookings
Sensitive Data	Photograph, image, and video footage with consent
Technical Data	Website use, browser type, plug-ins
Usage Data	Website usage statistics

We may collect, utilize, and distribute aggregated data, such as statistical or demographic data, which may be derived from your personal data. This data is not legally classified as personal data because it does not disclose your identity, either directly or indirectly. However, if we combine this aggregated data with your personal data in a manner that directly or indirectly discloses your identity, we will treat it as personal data.

We do not gather special categories of personal data. However, we may collect this type of data if we have a legitimate reason, such as protecting the security of our properties with video systems.

How we collect information about you

Comenstay collects and processes information in various different ways:

1. Information you provide to us

Correspondence: information, including Identity and Contact data, gathered when you contact any of the Comenstay staff. We collect this information to maintain a record of the conversation and obtain the required details to prepare your booking or categorize your inquiry, provide a response, and, if necessary, investigate any violation of our Privacy Policy. While we do not utilize this information for advertising, we may use it to detect and monitor potential issues and trends, as well as personalize our Services for you.

2. Information we learn about you from your use of the Website

We may gather or handle certain non-personal information or aggregated data, such as Device, Content, and Usage Data, about how and when you use the Website. This information is typically technical in nature (device settings and information such as browser type, operating system, keyboard language, screen resolution, IP address, location, etc.) and behavioral in nature (the actions taken by you on the Website, such as access times, pages requested, actions executed, etc.). It is used to compile statistical data about the usage of our Website. We gather this information using cookies and other similar technologies. For further details on this, please refer to our Cookies Policy.

3. Information we receive from other sources including third parties and publicly available sources

We might receive information such as device data from analytics providers (e.g. Google), WordPress plugins, and other sources. We do not use any automated processing or automated decision-making (such as profiling) in any way.

Purposes and legal bases of collecting information

Lawful basis for collecting information

We must have a lawful basis for collecting and using your personal data, as required by law. The specific lawful basis we rely on depends on the type of personal data collected and the purpose for which it is collected. It is possible that we may need to process your personal data on more than one lawful basis. We rely on the following lawful bases:

• Your Consent to receive electronic communications: Comenstay may use your electronic contact information, such as your name, first name, and email address, to send you newsletters containing personal information, advertisements, activities, news, programs, agendas, events or proposals from Comenstay. However, we will ask for your prior consent before processing your personal data for this purpose. You may withdraw your consent at any time by contacting us (refer to Section 10 below).
• Contract: for instance, we may need to use your information to fulfill a contract with you or to carry out certain actions that you have requested before entering into a contract.
• Legal Obligation: we may need to use your personal information to comply with legal requirements, such as fulfilling our tax and accounting obligations
• Legitimate Interests: We may use your personal information to operate, protect, and improve our business, as it is necessary for our legitimate interests. However, if there is an important reason to protect your personal information that overrides our legitimate interests, we will not use it.

Kindly note that if we are legally or contractually obligated to collect your personal information and you decline to provide it, it may hinder us from fulfilling our contract with you. In such a scenario, we will attempt to communicate with you to seek a resolution.

Purposes of collecting information

For the purposes described above, we may be required to disclose your information to third parties, such as:

Recipient	Type of Information Shared	Purpose
Payment parties	Financial Data (e.g. payment method, booking information)	To transfer necessary financial information to a credit or debit card company for payment processing
Law enforcement	Personal data as required by law enforcement agencies	To comply with the law, enforce policies and protect the rights, property, and safety of users
Trusted third-party	Personal data necessary for providing services (e.g. SaaS)	To assist in operating the Website, conducting business, and servicing users

When using the Website, you may come across links to third-party websites. Please be aware that these websites are not affiliated with the Website, and we do not assume any responsibility or liability for their privacy policies or any other legal matters. It is recommended that you carefully review the privacy policies and terms and conditions of these third-party websites.

International transfers

Generally, Comenstay will not disclose your personal information outside the European Economic Area (EEA) unless you reside outside the EEA or if a third-party supplier, such as a payment website, is located outside the EEA. In the event that your personal information is disclosed outside the EEA, we will make every commercially reasonable effort to implement the same protective measures as described in this Privacy Policy.

If personal data is transferred outside the EEA, it may not receive the same level of protection as personal information transferred within the EEA. Nevertheless, to maintain the same level of protection for your personal data as it would receive within the EEA, any transfer will adhere to the appropriate safeguards outlined in the GDPR. We require all parties outside of the EEA to adhere to sufficient safeguards to protect your personal information as per our contractual obligations. If you require further information, please contact us using the details provided in the ” Contact Us” section.

Security of your personal data

To ensure the security of your personal data on the Website and to provide you with a secure online experience, we have put in place various technical and organizational security measures that meet industry standards. These measures protect the confidentiality of your personal information and ensure your online safety. Access to your personal information is limited to those who require it for legitimate reasons. While we cannot guarantee that unauthorized access will never occur, we take all necessary precautions to prevent it. Additionally, we have established procedures to handle any suspected security breaches, and we will notify you and any relevant authorities if legally required to do so.

Storage of personal data

We ensure that your personal data is not stored or processed for longer than necessary. We retain your personal data as long as it is necessary to enable you to use our Website or to fulfill our contractual obligations to you.

However, in some instances, we may be required by law to retain basic personal data even after you have stopped using our Services, for instance, Financial Data or Transaction Data may be kept for tax purposes, or other personal data may be retained for defending or pursuing a legal claim in accordance with applicable legal limitation periods.

You have the right to access, modify, or delete your personal data free of charge at any time. Further information on your rights is described in Section “Your choices and rights” below.

Your choices and rights

Request	Information
Request access	You can ask us to provide you with any information that we hold about you in our records.
Request correction	You can ask us to correct any incorrect information or out-of-date information.
Request erasure	You can ask us to erase your personal information or restrict its use and we must comply in certain situations.
Object to processing	You can object to us using your personal information in certain situations, such as asking us to stop sending you direct marketing communications.
Request restriction of processing	You can ask us to suspend the processing of your personal data in certain circumstances.
Request transfer	You can ask us to provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Withdraw consent (note: withdrawing consent might affect the Services we can provide you)	You can withdraw consent at any time when we are relying on your consent to process your personal data.

Withdraw consent for electronic communications

You have the right to withdraw your consent for receiving electronic communications for direct marketing purposes or sharing our newsletter with you at any time without any reason. You can do this by any of the following methods:

• By clicking on the link at the bottom of emails sent by Comenstay;
• By sending us an e-mail (See Contact Us)
• By modification of this Privacy Policy

The Privacy Policy was first published in March 2023 and was last updated on March 10th, 2023. We reserve the right to modify this Privacy Policy at any time, and any changes to it will be posted on the Website. We recommend that you regularly review this Privacy Policy. In the event of any material changes to this Privacy Policy that affect how we process your personal data, we will notify you by posting a notice on the Website or sending you an email notification. The changes will take effect on the date of the last revision stated in the Privacy Policy. By continuing to use the Website after the latest update, you are agreeing to the changes in the Privacy Policy.

Cookies

Comenstay uses cookies to store small pieces of information on your computer or mobile device’s hard drive via your browser, which can help provide features such as remembering room search details to speed up subsequent searches. We always ask for your consent for non-essential cookies. Further details on how we may use cookies can be found in our Cookies Policy.

Contact Us

Ensuring the safety of your personal data is our top priority, and we strive to provide you with a sense of confidence when using our Website. If you have any concerns, please do not hesitate to contact us.

We will investigate your concerns and provide a written response with our proposed solution within a reasonable timeframe. Our aim is to resolve any queries or concerns you may have about how we use your information in a timely and satisfactory manner.

If you believe that we may have processed your personal information unlawfully or in breach of your rights, you have the right to file a complaint with the European Data Protection Authority. You may file the complaint in your place of residence, work, or in the jurisdiction where the processing occurred.