a.s.r. real estate

Privacy Statement of a.s.r. real estate

Responsibility for your data

ASR Vastgoed Vermogensbeheer B.V., a.s.r.’s real estate investment management business (hereinafter referred to as a.s.r. real estate), is a division of ASR Nederland N.V. As a division of ASR Nederland N.V., a.s.r. real estate is responsible for processing personal data. We treat your personal data securely, confidentially and with due care.

ASR Nederland N.V. has notified the Dutch Data Protection Authority that it processes personal data. This notification has been included in the notifications register. The privacy policy of ASR Nederland N.V. is applicable.

We respect your privacy

We are committed to protecting your privacy. That is why we do everything possible to treat your personal data securely, confidentially and with due care. This privacy statement is designed to give you a clear idea of what we do with your personal data.

Personal data are all data that are known to relate to you, e.g. your name and date of birth, contact details and bank account number. We process and use your personal data in compliance with the Dutch Personal Data Protection Act. We also comply with other legislation that contains privacy provisions, e.g. the Dutch Telecommunication Act.

If you request or purchase a product or service from a.s.r. real estate, we ask you for your personal data. You provide us with these personal data through our website, by email or telephone, or through a manager or third party we have engaged.

This is how we protect your personal data

We treat your data with due care. We have taken technical and organisational measures to protect your data against loss and unlawful processing. Examples include measures to secure our website and IT-systems, and prevent abuse. Other examples are measures to secure areas where data are stored, information security policy and staff training. We also ensure that we keep personal data no longer than strictly necessary. 

What data of yours do we process?

Besides the information we receive from you, we can request information from public and external sources that we consider reliable. This may form part of the integrity screening we carry out in the course of our client acceptance policy.

For what purposes do we use your personal data?

We use your personal data to process your application and to create and perform an agreement. We may also use your personal data to:

  • conclude and perform an agreement with third parties for the provision of the agreed service;

  • deal with any complaint you lodge or settle any damage or loss;

  • prevent and combat fraud. For this purpose, we may also use any public data about you that are available online;

  • preserve the security and integrity of the financial sector;

  • comply with rules and regulations;

  • in so far as permissible, share them with our business partners such as advisers, debt collection agencies, valuers, managers and civil-law notaries;

  • carry out market research;

  • carry out statistical analyses;

  • improve our services and ensure that they are better suited to your personal circumstances;

  • maintain and develop our relationship with you;

  • inform you about our services.

Exchange of personal data

ASR Nederland N.V. does not disclose personal data to third parties unless this is necessary and permitted by law or in cases of fraud.

Service by third parties 
a.s.r. real estate occasionally engages other organizations to perform services on its behalf that are connected to the performance of the agreement with you. Examples include managers, debt collection agencies or loss adjustment firms. In such circumstances, a.s.r. real estate remains responsible for the processing of your personal data. We make contractual arrangements with these parties about the treatment of your data in order to protect your continued privacy.

Integrity analysis
a.s.r. real estate is an institution that has a reporting obligation under the Dutch Money Laundering and Terrorist Financing (Prevention) Act. For certain types of services, it may be necessary for us to gather information enabling us assess the origin and source of your assets. This may involve examining your business operations and the underlying ownership and control structure, the legal structure of transactions and other matters that can shed light on the integrity risk incurred by a.s.r. real estate. As an institution under a reporting obligation, a.s.r. real estate has a duty to report any unusual transaction to the Financial Intelligence Unit (Netherlands). If a.s.r. real estate decides to file a report, you will not be informed of this.

Special personal data
Special personal data includes information on previous convictions. Criminal data are requested if the parties are covered by the definition of businesses with ‘commercial real estate activities’.

Such activities involve:

  • property development in the commercial real estate sector;

  • financing of investment property or development properties in the commercial real estate sector;

  • investments in the commercial real estate sector.

These data are supplied to officers of ASR Nederland N.V. on a strict need-to-know basis. Data are also recorded in the context of investigations into fraud, abuse and improper use. 

What are your rights?

Inspecting or correcting data
You are entitled to ask us what personal data of yours we are processing and to correct or delete any incorrect data.

If you ask us a question concerning yourself or any other persons in relation to your product, contract or services, we cannot answer your question until we are sufficiently certain that we are dealing with you. If you wish to authorise others to handle matters on your behalf, we would kindly request you to submit an application for each authorisation. This is the only way that we can prevent the abuse or incorrect use of your data.

For this purpose, please send a request to inspect or correct your data to a.s.r. real estate, for the attention of: Complaints Service/Information Service, P.O. Box 2008, 3500 HB Utrecht, quoting ‘Request for Inspection/Correction’ or send an email to asr.klachten.asrvv@asr.nl. Please enclose a copy of your ID. On this copy, you can block out your passport photo and citizen service number (BSN). We would advise you to specify on the copy the purpose for which it is intended. You will receive a reply from us within four weeks.

Unsubscribing from personal offers
We may also use your personal data for marketing purposes. In commercial offers, we always inform you of the option of unsubscribing. We may phone you for commercial purposes. In this connection, we comply with the rules of the Do Not Call Registry. You can unsubscribe from commercial telephone calls on the www.bel-me-niet.nl website.

Amendment of the privacy statement
We may decide to amend this privacy statement. We may do so in the event of new developments, e.g. where there is a change in our business operations or in statute or case law. For this reason, we advise you to regularly check this privacy statement when you visit one of our websites. The wording was last amended on 7 February 2017.
Do you have any questions or complaints?
If you have any questions about this privacy statement or if you want to file a complaint about how we deal with your personal data, we invite you to contact the Privacy Officer of ASR Nederland N.V. Please send an email to asr.klachten.asrvv@asr.nl or a letter to:

a.s.r. real estate
Attn: Klachtenservice (Complaints Service)
PO Box 2008
3500 GA Utrecht

You can also reach us by telephone at +31 (0)30 257 23 80.