Last updated : 13/02/2026
1.Introduction and Scope
2. The person responsible for processing your personal data and Higgins’ contact details
3. Different processing carried out by Higgins for each category of data subjects
a. You use our form on our Website and are therefore a potential prospective buyer
b. You confirm your subscription of shares and are therefore a prospective partner
c. The minimum subscription amount is reached, and you are a partner
d. You agree that we process your data for commercial purposes
e. You are a visitor to the Website
4. Sharing data with third parties and subcontracting
5. Measures implemented by Higgins to protect your personal data
6. Your rights
7. Changes to this Policy
1. Introduction and Scope
Privacy and the security of personal data are of the utmost importance to Higgins. This Privacy Policy (“Policy”) describes how and for what purposes Higgins collects and processes personal data in the context of its activities.
For the purposes of applicable data protection laws and regulations, the data controller is:
HIGGINS SA
Avenue Winston Churchill 246, Box 7
1180 Uccle
Company Number: 1019.164.251
Hereinafter referred to as “Higgins,” “we,” or “our.”
[We have appointed a Data Protection Officer responsible for overseeing matters relating to this Privacy Policy.]
In this Policy, the term “personal data” refers to any information relating to an identified or identifiable natural person (each a “data subject”). The term “data subject” refers to any natural person whose personal data is processed by Higgins, regardless of their role in relation to Higgins (potential prospective buyer, prospective partner, partner, website visitor [www.higgins.be] (the “Website”), etc.) (hereinafter “data subject,” “you,” or “your”).
All capitalized terms not defined in this Policy have the meaning given to them in Regulation 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (“GDPR”).
When we process personal data, whether received directly from the data subject or collected from other sources, such processing is carried out in accordance with this Policy and in compliance with applicable laws and regulations, including the GDPR.
2. The person responsible for processing your personal data and Higgins’ contact details
Higgins is responsible for processing your data.
You can contact us using the following details:
HIGGINS SA
Avenue Winston Churchill 246, Box 7
1180 Uccle
Email: [email protected]
3. Different processing carried out by Higgins for each category of data subjects
Depending on the category of data subject to which you belong, Higgins may collect the following categories of data about you:
- Identification data: first name, last name, date and place of birth, copy of ID card or passport, national identification number
- Contact data: email address, billing address, phone number
- Administrative data: billing information, bank details
- Technical data: IP address (for more information about cookies, see our Cookie Policy)
Depending on your interactions with Higgins, you may fall into one or more of the following categories of data subjects.
a. You use our form on our Website and are therefore a potential prospective buyer
If you are a potential prospective buyer, we collect and process the information you provide when requesting information about a subscription in order to provide you with this information.
| Purpose of Processing | Data Processed | Legal Basis |
| Enable processing of your request; allow you to confirm the subscription | First name, last name, email address | Article 6(1)(b) GDPR: processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract. |
Data is retained for the duration of your relationship with us and up to a maximum of 2 years after the end of your relationship if you do not become a prospective partner.
b. You confirm your subscription of shares and are therefore a prospective partner
If you decide to confirm the subscription of shares, you become a prospective partner, and we collect and process your personal data to respond to your request and inform you if the minimum subscription amount has been reached.
| Purpose of Processing | Data Processed | Legal Basis |
| Respond to your request; inform you of the result | First name, last name, email, subscription form | Article 6(1)(b) GDPR : The processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures taken at the request of the data subject. |
| Comply with anti-money laundering obligations | First name, last name, date and place of birth, address, copy of ID card or passport, other information required by applicable law | Article 6(1)(c) GDPR: processing is necessary for compliance with a legal obligation to which Higgins is subject. |
Data is retained for the duration of your relationship with us and up to a maximum of 10 years after the end of your relationship.
c. The minimum subscription amount is reached, and you are a partner
If you are a prospective partner and become a partner, we collect and process your data to inform you and manage your role as a partner in the newly created company for which you subscribed.
| Purpose of Processing | Data Processed | Legal Basis |
| Inform you; manage your role as a partner | First name, last name, email, subscription form, information necessary to exercise your partner rights | Article 6(1)(b) GDPR : The processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures taken at the request of the data subject |
Data is retained for the duration of your relationship with us and up to a maximum of 10 years after the end of your relationship.
d. You agree that we process your data for commercial purposes
| Purpose of Processing | Data Processed | Legal basis |
| Provide information on other products and services we offer (e.g., new investment projects on other properties) | First name, last name, email | Article 6(1)(f) GDPR: processing is necessary for the purposes of legitimate interests pursued by us unless overridden by the interests or fundamental rights and freedoms of the data subject |
Data is retained for five years after our last contact with you unless you consent to a longer retention period. You may withdraw your consent at any time; in that case, we will no longer be able to contact you about other products or services.
e. You are a visitor to the Website or contact us by email
If you visit our Website, we may automatically collect certain information about your use of our Website using technologies described in our Cookie Policy.
When you contact us via email or phone, we may collect and process the information you provide.
| Purpose of Processing | Data processed | Legal basis |
| Respond to your request | First name, last name, email, phone number | Article 6(1)(f) GDPR: processing is necessary for the purposes of legitimate interests pursued by us unless overridden by the interests or fundamental rights and freedoms of the data subject |
Higgins will retain your personal data for up to one year after your contact or longer if indicated elsewhere in this Policy if we enter into a (pre-)contractual relationship with you.
4. Sharing data with third parties and subcontracting
We may share your personal data with third parties in the following circumstances:
- For legal or regulatory reasons: if required by law or necessary to comply with applicable laws/regulations or to protect rights, property, or safety.
- To provide services: with third-party service providers who assist us in delivering or improving our services.
Third parties may include:
- External service providers (IT infrastructure, software, accounting, banks, etc.) processing data on our behalf. Higgins ensures they take appropriate technical and organizational measures and follow our instructions.
- Financial or judicial authorities, state agencies, or public bodies, as permitted by law.
- Certain regulated professionals such as lawyers or notaries.
- Any other third party, but only with your prior consent or as provided in this Policy.
Higgins will not transfer personal data outside the European Economic Area unless there is an adequacy decision by the European Commission (Article 45 GDPR) or adequate safeguards (Article 46 GDPR) or when necessary to perform your contract or pre-contractual measures.
We will never share personal data with commercial partners for marketing without your consent.
5. Measures implemented by Higgins to protect your personal data
Higgins has implemented appropriate technical and organizational measures, such as firewalls, antivirus software, secure internal networks, and IT infrastructure, to process personal data in accordance with Belgian and European regulations, protecting against loss, misuse, or unauthorized alteration.
Despite these measures, you should be aware that risks remain when transmitting personal data over the Internet. Security cannot be guaranteed 100%.
6. Your rights
Under the limits provided for by Articles 15 to 22 of the GDPR and by other applicable laws and regulations, data subjects have the following rights with regard to their personal data that are processed by us:
- The right to access their personal data: data subjects may ask us to access the data that we store;
- The right to have their personal data rectified: data subjects may ask us to correct inaccurate data or to complete incomplete data, including by providing a supplementary statement;
- The right to erasure of their personal data: data subjects may ask us to erase personal data whose processing no longer has a valid purpose;
- The right to restrict the processing of their personal data: data subjects may ask us to “freeze” their personal data in order to limit its processing in the future;
- The right to object: data subjects may ask us to stop or prevent the processing of their personal data for reasons related to their particular situation;
- The right to data portability: data subjects have the right to transfer the personal data that we process, in a user-friendly and secure manner, from one IT environment to another.
Data subjects may exercise these rights by contacting us by ordinary mail or by email using the contact details below:
Ordinary mail:
Higgins SA
Avenue Winston Churchill 246, Box 7
1180 Uccle
Email:
[email protected]
Higgins will make every reasonable effort to respond to any relevant request you make within thirty (30) days of its receipt. However, if the complexity of your request or the volume of information makes it impossible to respond within thirty days, Higgins will inform you in writing within that period of the reasons for the delay and will make every reasonable effort to respond to your request as soon as possible, and in any case within a maximum of an additional two months.
Higgins reserves the right not to respond to your request if it is deemed manifestly unfounded or excessive, and will inform you of the reasons why your request will not be satisfied.
In all cases, you have the right to lodge a complaint with the Data Protection Authority (https://www.autoriteprotectiondonnees.be/citoyen):
- Via the online form: https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte
- By mail: Rue de la Presse 35, 1000 Brussels
7. Changes to this Policy
We reserve the right to make changes to this Policy from time to time. These changes will be brought to your attention via the Website and/or by any other appropriate means, taking into account the nature of the change, and will take effect 10 days after publication, unless otherwise indicated.
The latest version of the Policy will be published on our Website.