Privacy Policy

Last Updated:

1. Who are we and what do we offer?

We are Brxs B.V. (“BRXS”). We provide a Platform where you, as a retail investor, can invest in real estate (Investment Services).

You can access our Platform via our Website (www.brxs.com) or via our App, available in the Google and Apple App stores. The use of the Platform, the Website, the App and our Investment Services are collectively: our Services.

2. Privacy Policy

This is our Privacy Policy. In this document we explain what kind of Personal Data we collect via our Services. We also explain what role we have in the processing of Personal Data, how long we retain Personal Data and what rights you have as a data subject.

3. Personal Data and Controller

We process Personal Data. Personal Data means all information by which a person can be directly or indirectly identified. Under the General Data Protection Regulation (GDPR) we are the so-called Controller of your Personal Data. If you have questions about the processing of your Personal Data, you can always contact us through the contact details listed at the bottom of this Privacy Policy.

4. What Personal Data do we collect as Controller?

As the Controller, we may process your Personal Data in different contexts.

We will process your Personal Data if you use our Investment Services. In addition, we may process Personal Data in a general context, e.g. via our Website and social media accounts (General). We will also process your Personal Data if you apply for a job at BRXS or any of our group companies (Applicants).

If you use our Investment Services

We may process the following Personal Data:

  • Account details: First name, last name, country of residence and email address.
    • Purpose: To verify your account details and register an account to provide you with access to our Platform; communicate with you and approach you appropriately in our communications; grant preferred status related to referrals.
    • Legal Basis: Performance of our contract with you.
  • Investment information: (Financial) information on your investments, such as the mortgage amount, property value, rental incomes, etc.; other information you provide when you invest in property on the Platform.
    • Purpose: To provide an online dashboard where you can keep track of your investments; provide you with quarterly overviews of your income and property developments.
    • Legal Basis: Performance of our contract with you.
  • Payment and tax details: Name, home address, bank details (account number, IBAN and BIC-code).
    • Purpose: Process and administer payments (i.e. your investments, fees charged by Brxs B.V.); include in our financial administration to comply with Tax and Customs Administration regulations.
    • Legal Basis: Performance of our contract with you; Legal obligation.

General Processing (All Users of Services)

  • Newsletter Subscription: Name and email address.
    • Purpose: To send you our newsletter and keep you informed on our Services.
    • Legal Basis: Your consent (if subscribing via Website); Legitimate interest (if you are a paying user of our Services). You can unsubscribe via the link in every newsletter.
  • Waiting List (Historical): Name and email address.
    • Purpose: To contact you for the Services as requested when you signed up for the waiting list (previously available).
    • Legal Basis: Performance of our contract with you (at the time of signup).
  • Contact Us: Your email address and the content of the correspondence.
    • Purpose: To answer your questions, handle complaints, support you in using our Services, and improve our Services based on feedback.
    • Legal Basis: Legitimate interest to assist you and improve our Services.
  • Social Media Interaction: Information visitors leave in comments or posts on our social media pages.
    • Purpose: To contact visitors in reply to their posts/comments; process feedback left on our pages.
    • Legal Basis: Legitimate interest to process this data; visitors voluntarily made such information public. Note: Our social media pages are also controlled by the respective platforms (LinkedIn, Facebook, Instagram). Please review their privacy policies.
  • Technical and Usage Information (Website Usage):
    • Information such as your device type, browser type, IP address, operating system, referring URLs, pages viewed, and timestamps of visits.
    • If you consent to Analytics Cookies, we use Google Analytics (via Google Tag Manager) to collect pseudonymized data about your interaction with our Website. This includes information like page views, session duration, navigation paths, and general location (e.g., city). This helps us understand website traffic and improve user experience. For more details on how Google Analytics operates under different consent states, please see our Cookie Policy.
    • If you consent to Marketing Cookies, we use services like Meta Pixel (via Google Tag Manager) to collect data about your interactions with our Website. This may include pages visited, products viewed, or actions taken. This information can be used to measure ad effectiveness and show you more relevant advertising on other platforms. For more details on how Meta Pixel operates under different consent states, please see our Cookie Policy.
    • Purpose: To provide a functioning Website; communicate in the browser language; adapt the Website to the device; enable usage; analyze usage patterns and improve usability (based on legitimate interest for essential functions, and consent for analytics and marketing activities).
    • Legal Basis: Legitimate interest (for essential website functionality and security); Your consent (for non-essential cookies and data processing related to analytics and marketing). See our Cookie Policy (/cookie-policy/) for comprehensive details on cookies, Google Tag Manager, and Google Consent Mode.

If you are an Applicant

  • Contact details: First name and surname, email address, address and telephone number.
    • Purpose: To contact the Applicant about the application.
    • Legal Basis: Legitimate interest (processing the application, communication).
  • Application information: Information provided by the Applicant (e.g., CV, motivation letter).
    • Purpose: To assess suitability for the job and Brxs B.V. or its group companies; determine the most suitable candidate.
    • Legal Basis: Legitimate interest (processing the application, assessment); data provided voluntarily by Applicant.
  • Information retained during application process: Notes from interviews.
    • Purpose: Assess suitability; determine the most suitable candidate.
    • Legal Basis: Legitimate interest (processing the application, assessment).
  • Information from public sources: Information in public profiles (e.g., LinkedIn).
    • Purpose: Assess suitability; determine the most suitable candidate.
    • Legal Basis: Legitimate interest (processing the application, assessment); data made public by Applicant. We only process relevant information, and Applicants can respond to findings.

5. Mandatory information

When you engage our Services, it may be legally or contractually required that you provide us with certain Personal Data. For example, we may need your payment details to process your investments. Where you do not provide us with such information, this will usually imply that we will not be able to provide you with specific Services or perform part of our agreement with you.

We use functional, analytical, and marketing cookies on our Website. We utilize Google Tag Manager to manage many of these scripts and have implemented Google Consent Mode v2 to respect your privacy choices. For detailed information on our use of cookies, the specific services deployed via Google Tag Manager (like Google Analytics and Meta Pixel), and how Google Consent Mode works, please refer to our Cookie Policy (/cookie-policy/). Your consent choices in our cookie banner directly influence how these tools operate.

7. How long do we keep the Personal Data?

We will not process or store any Personal Data that we do not need. We store Personal Data for as long as we need it for the purposes outlined above, unless we are legally obliged to retain the Personal Data for a longer period. We apply the following general retention periods:

  • Personal data of potential clients: Stored as long as necessary to determine whether we enter into an agreement, and for a maximum of 24 months after our last contact.
  • Personal data of clients: Stored as long as we have a contract with our client and for a maximum period of 5 years after, unless legally required otherwise.
  • Newsletters: Data retained until you unsubscribe.
  • Personal Data in our correspondence: Stored as long as necessary to handle your message/question/complaint and for 5 years thereafter.
  • Personal Data in our records for (tax) authorities: Stored for seven (7) years, unless legally required otherwise.
  • Personal data of job applicants: Stored for a maximum of 1 year after the application process with your consent (e.g., for talent pool).

Data collected via third-party services like Google Analytics or Meta Pixel (managed through Google Tag Manager) is subject to the retention policies of those respective services and your consent settings. For example, Google Analytics data retention can be configured within your Google Analytics account.

After expiry of these periods, we may retain certain Personal Data only to comply with legal retention obligations, for fraud/misuse investigations, or to substantiate a claim, retaining the data separately and only for these specific purposes.

8. Do we share your Personal Data with others?

Processors: We use third parties (Processors) who support us in providing our Services (e.g., for hosting, platform maintenance, sending newsletters, live chat via Crisp). These Processors receive Personal Data from us and process it only on our behalf and under our instructions, governed by data processing agreements.

External Controllers: Some Personal Data may be processed by other controllers (External Controllers):

  • Payments on the Platform may be processed by third-party payment providers (e.g., Stripe).
  • We share necessary financial administration data with national tax authorities due to legal obligations.
  • Google (for Google Tag Manager, Google Analytics, and potentially Google Ads): If you consent to analytics or marketing cookies/tags managed via Google Tag Manager, data related to your website interaction may be processed by Google. This processing is subject to your consent choices managed via Google Consent Mode. Google acts as an independent controller for some of the data it collects. Please refer to Google’s Privacy Policy and our Cookie Policy (/cookie-policy/) for details.
  • Meta (for Meta Pixel): If you consent to marketing cookies/tags, data related to your website interaction may be processed by Meta (Facebook, Instagram) via the Meta Pixel (managed by Google Tag Manager). This processing is subject to your consent choices. Meta acts as an independent controller for some of the data it collects. Please refer to Meta’s Privacy Policy and our Cookie Policy (/cookie-policy/) for details.

Any Personal Data provided to these External Controllers will be processed in accordance with their own privacy policies.

Joint Controllers: Brxs B.V. may involve other companies within its group to provide Services. Where Brxs B.V. and another entity jointly determine the purposes and means of processing, they act as Joint Controllers under Article 26 GDPR. A mutual arrangement defines responsibilities, roles, and designates Brxs B.V. as the primary contact point for your rights under this Policy. If data is processed outside the EU in such cases, appropriate safeguards (like Standard Contractual Clauses) are used.

Apart from the above, we will not share your Personal Data with third parties, unless we are legally obliged to do so.

9. Export of Personal Data outside the European Union

We may transmit Personal Data to parties outside the European Economic Area (EEA), if one of our Processors or External Controllers (such as Google or Meta, for services like Google Analytics or Meta Pixel) is established or processes data outside the EEA. The Personal Data will only be transferred to countries and/or parties that provide an adequate level of protection according to European standards. This is typically ensured through mechanisms such as an adequacy decision by conundrums European Commission, or by implementing Standard Contractual Clauses (SCCs) as approved by the European Commission, along with any necessary supplementary measures. You can contact us for more information on the specific safeguards used for these transfers.

10. Third party websites

Our Website may contain links to other websites, services, or resources. We do not control these third-party sites and are not responsible for their practices. Interaction on any other website is subject to that website’s own terms and policies.

11. Changes of the Privacy Policy

This Privacy Policy may be changed from time to time. Please check our Privacy Policy (/privacy-policy/) frequently. The new Privacy Policy will be effective immediately upon posting on our Website. Significant changes will be highlighted on our Website.

12. Your rights as a data subject and our contact data

Under the GDPR, you have the right to:

  • Access your Personal Data.
  • Rectify incorrect Personal Data.
  • Erase your Personal Data.
  • Restrict the processing of your Personal Data.
  • Data portability.
  • Object to the processing of your Personal Data.

You can exercise these rights by contacting us using the details below.

You are always entitled to file a complaint with a data protection supervisory authority if you believe that we are not processing your Personal Data in accordance with the GDPR. In the Netherlands, the supervisory authority is:

Autoriteit Persoonsgegevens Website: https://www.autoriteitpersoonsgegevens.nl

If you have questions or concerns about this Privacy Policy or your privacy, you can contact us:

Brxs B.V.
Singel 542
1017 AZ Amsterdam
The Netherlands

E: hello@brxs.com
W: https://www.brxs.com/
Chamber of Commerce: 89185188