| De Spitter |

When you purchase a real estate property, sell us products or services, want to obtain information about the Vitruvi, use our services or visit our website [www.vitruvi.be] (the "Website"), we will collect some personal information about you ("personal data").

The purpose of this privacy policy (the "Policy") is to inform you how we, Vitruvi and the entirety of its subsidiaries, ("Vitruvi", "our" or "us"), collect your personal data in this way, why we collect it, with which third parties we share it and for how long we keep it, as well as what rights you have and how you can exercise them.

1. Who are we?

Vitruvi is responsible for the processing of your personal data (data controller), its head office is located at 8760 Meulebeke, Ooigemstraat 47, and it is registered in the Crossroads Bank for Enterprises (CBE) under the number: 0726.899.885. You can contact us using the general contact information below:
Email: info@vitruvi.be

2. What personal data do we process?

2.1 Categories of personal data

2.1.1 Personal data that you provide to us

2.1.1.1 General information such as, but not limited to, the following:

• Your surname*, first name*, title*, language* and date of birth
• Your postal address,* email address*, phone and/or mobile number*, other
• Any personal information that you provide to us voluntarily and without obligation (e.g.: family composition, profession, etc.)
• With your consent, your preferences for communication and marketing purposes.
• Copy of your ID Card.

2.1.1.2 If you are a professional, the following information, among others:

• The contact details of your company/association/institution: name, postal address, landline and/or mobile number, email address, your VAT and business number, legal form.*

2.1.1.3 Information related to real estate property, including but not limited to the following:

• The type of real estate properties for which you have expressed an interest
• The real estate properties that you currently own or rent
• The real estate properties that you have rented or purchased in the past

The details marked with an asterisk (*) are mandatory and essential for entering into any contract. You are therefore required to supply us with these personal details; otherwise it will not be possible to enter into a contract.

2.1.2 Personal data that we collect about you

2.1.2.1 Information from third parties, including but not limited to the following:

We can also, when permitted by law, collect personal data about you from public databases, social media or the owners of marketing files, which will help us to update your personal data, to improve the quality of or complete the same, in order to help us better understand the type of properties that may interest you.

2.1.2.2 Automatic collection of personal data

When you visit the Website, we also collect personal data, especially when you fill out forms in order to obtain information about a real estate project or financial information, or even automatically through the use of cookies and similar technologies.

We collect the following personal data:

• when you fill in the forms via the Website or other channels (for example, if you express an interest in the real estate projects that we are developing or if, as an investor or interested person, you have asked us to provide you with financial information about our group); and
• when you sign a contract with a view to purchasing a real estate property; and
• when you contact us, for example when you write to our customer services; and
• when you sign a contract with us with a view to selling a product or service to Vitruvi; and
• Automatically, on the Website, through the use of cookies and similar technologies. (see Vitruvi’s cookie policy)

3. Why is your personal data processed?

We process the aforementioned personal data for the following reasons:

In the context of contractual or pre-contractual relations with suppliers, customers and prospective customers, in order (i) to deal with your requests for information about our current or future projects, (ii) to manage the contractual relationship, (iii) to create, accept and follow-up your real estate purchase, the after-sales service, (iv) for accounting purposes, (v) in order to tackle potential fraud, offences and breaches, and for handling disputes and potential legal proceedings; etc.

On the basis of our legitimate interest, in order (i) to follow up of your requests for information, (ii) to update, correct and consolidate your personal data, using useful information from external partners that may be available where appropriate, (iii) to contact you if we experience difficulties responding to one of your requests, (iv) to check or improve the quality of your contacts with Vitruvi based on your answers, (v) to improve our products or services, adapt our events, websites or mobile apps according to the preferences of our visitors, customers or prospective customers, or in order to improve security, (vi) send you financial information about our company, (vii) in order to tackle potential fraud, offences and breaches, and for handling disputes and potential legal proceedings; etc.

On the basis of our legitimate interest and/or with your consent, in order (i) to send you marketing material according to your communication preferences, such as, for example, send you newsletters to which you have subscribed; (ii) to send you reminders concerning your real estate properties, renew any service or contract that we offer and that is about to expire, (iii) inform you in a generalised or personalised way about Vitruvi's offers of products and services, (iv) send you information about events organised by Vitruvi, (v) for the purposes of participating in satisfaction or market surveys about our products and/or services or about the real estate market; etc.

Based on the law, in order (i) to comply with our legal and regulatory responsibilities (in particular with regards to financial information), (ii) to respond to legal proceedings or requests for information from government authorities or other third parties, (iii) to prevent and detect criminal offences and fraud, or to protect your rights, or those of others, (iv) to fulfil legal guarantees; etc.

From time to time, we may combine the personal data collected on the Website or via other channels with data collected from third parties (such as marketing agencies) in order to help us determine which real estate properties interest you. We may then use this data in order to send you the relevant information. We may also work with third parties to show you personalised advertisements on social networks or, if you have agreed to the use of cookies, when you browse on the Internet or visit other sites (see Vitruvi’s cookie policy). If you no longer wish to receive marketing material from us, you can object to it. To this effect, we refer you to the "What rights do you have?" section 10. below.

4 .Lawful basis for processing your personal data

The personal data that we collect is processed according to the legal bases below:

4.1 Processing for the purposes of executing a contract or pre-contractual measures (art. 6, paragraph 1, point b) of the GDPR)

The personal data is processed for the purposes of executing the contracts that we enter into with you. The personal data may also be processed in order to implement measures and operations within the context of pre-contractual relations, for example when you request an offer for a real estate property.

4.2 Processing for the purposes of legitimate interests pursued by us or by third parties (art. 6 paragraph 1, point f) of the GDPR)

We also process your data whenever this processing is necessary in order to protect our legitimate interests or those of the third parties with whom we have shared your personal data, and especially to help us find the information, products and services most likely to be of interest to you and to send or show you information, offers and advertisements for these products or services; to personalise your experience of our products and services if you do not object to the use of your personal data for this purpose.

4.3 Processing with your consent (art. 6 paragraph 1, point a) of the GDPR)

With your consent, we may collect and process technical information such as cookies and similar technologies that we describe in the “Cookie Policy” and/or use your personal data for marketing by email. In principle, you may revoke this consent at any time. See the "What are your rights?” section 10. on this subject below.

4.4 Processing necessary with regards to regulatory requirements (art. 6, paragraph 1, point c) of the GDPR)

We will also use your personal data if these are necessary for us to comply with the legal obligations to which we are subject, and in particular our obligation to make available to the public all of information necessary for the transparency, integrity and smooth running of the markets. It may therefore turn out to be necessary to use your data in order to comply with the statutory and regulatory provisions to which we are subject.

5. Is your personal data shared with third parties?

Your personal data is not sold or passed on to third parties for commercial purposes. We are only permitted to transfer your personal data to third parties if one of the following applies:

• You give your prior formal consent in this respect;
• We have a legal obligation to transfer your personal data in the context (of preventing) fraud and abuse;
• We call upon third parties to perform a part of the contract that we have entered into with you, in which case, we ensure that these third parties also respect this privacy policy.

Specifically, your personal data is or may be shared with the following third parties, for the reasons listed below:

• Companies or other organisations that we have subcontracted to provide services on our behalf, such as web hosting companies, direct mail suppliers, suppliers of analyses, events services and suppliers of information technologies;
• Partner companies, when it is necessary in order to provide you with a product or service that you have requested.

Vitruvi may also share your personal information with other Vitruvi companies in the European Union.

When we transfer your personal data, we will ensure that it is only used for the purposes described in this notice.

6. Transferring your personal data in the European Economic Area

Your personal data will be processed in accordance with the Belgian legislation on data protection and may be transferred within the European Economic Area ("EEA").

7. For how long is your personal data kept?

Your personal data may not be kept longer than is necessary in order to fulfil the objectives for which it was collected and to satisfy our legal obligations. Independently of this period for which we keep your personal data, we also delete your personal data if you explicitly ask us to do so, by notifying us using the contact details appearing above.

8. Other websites or social networks

When you surf on the website, the latter may also offer you the possibility of sharing or following information about Vitruvi, the Website or the products and/or services available, using the third party social network function (for example, the "share", "like" or "follow" buttons).

We offer this function in order to generate interest in the Website among the members of your social networks, and to enable you to share and to follow the opinions, news and recommendations on the Website with your contacts. However, you should be aware that the sharing of personal data with a social network may result in such information being collected by the social network supplier and in the public dissemination of the same, including via internet search engines. We advise you to always carefully read the privacy policy of any website you access or social network through which you share information, in order to understand their privacy practices.

9. How do we protect your data?

Your personal data is only accessible to persons who need it in order to perform their task. These people have a duty of confidentiality and must ensure that all of the technical and organisational measures we have implemented to assure the security and confidentiality of your personal data are respected.

10. What rights do you have?

You have different rights that you may exercise by contacting us using the contact data shown above.

• The consultation of personal data about you that has been processed by us, the rectification of inaccurate/incomplete personal data, where applicable, as well as, in some cases, the restricted processing of your personal data or objection to the processing of the same.
• The transfer of your personal data, either by supplying it to you in a readable format, or when we send it directly to the third party service provider that you have designated.
• The objection to the use of your personal data for the purposes of direct marketing.
• The withdrawal of a consent previously given for the purpose of processing your personal data.
• The filing of a complaint to the supervisory authority, if you are not satisfied with our processing of your request or claim, using the following contact details:
  Autorité de protection des données
  Rue de La Presse, 35, 1000 Bruxelles
  +32 (0)2 274 48 00
  commission@privacycommission.be

11. How can you exercise your rights?

If you have any questions or complaints regarding the use of your personal data, you can contact us using the contact details shown above.

If you want to withdraw your consent for the use of your personal data and/or if you no longer wish to receive marketing communications from Vitruv, you can contact us at any time by sending your request to:
Postal address: Vitruvi - Privacy – Ooigemstraat 47, 8760 Meulebeke
Email: privacy@vitruvi.be

We may amend this Policy from time to time. If we make substantial or important changes to the way in which we wish to use your personal data, we will communicate this to you by supplying a visible notice on the Website or by contacting you directly. If you surf on the Website and you do not agree with these changes, please refrain from using the website.