Privacy Policy

ARTICLE 1 – INTRODUCTION

The purpose of this Privacy Policy is to inform you about the processing of personal data carried out by Respace (hereinafter “Respace,” “we,” “us,” or “our”), as well as the rights you have with respect to such processing.

This Policy has been drafted in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), as well as any applicable national legislation regarding the protection of personal data.

In particular, Respace provides coworking spaces, private offices, meeting rooms, event spaces, hospitality services, and related services for businesses, professionals, organizations, and individuals.

This Policy applies, in particular, when:

you visit our website
you contact Respace
you request information about our services
you schedule a tour of our spaces
you become a prospect or customer
you reserve an office, a meeting room, or an event space
you attend an event
you subscribe to a newsletter
you provide a service to Respace
you act as a supplier or partner
you apply for a job or a collaboration opportunity
you work for Respace as an employee, consultant, director, or collaborator
you participate in a meeting, workshop, training session, or professional exchange involving Respace

ARTICLE 2 – DATA CONTROLLER

The data controller is:

RESPACE
Respace SA
Place Poelaert 6, 1000 Brussels
Company number: 1011.299.432
pierre.colaiacovo@respace.be

When this Policy refers to “Respace,” it should be understood to mean the data controller as defined by the GDPR.

ARTICLE 3 – CATEGORIES OF DATA SUBJECTS

The processing described in this Policy applies in particular to the following categories:

website visitors
prospects
customers
space occupants
users of coworking spaces
event participants
job applicants
employees
administrators
consultants and freelancers
suppliers
service providers
partners
co-contractors
representatives of legal entities
guests
in-person visitors to Respace locations
any person participating in a meeting, interview, or professional discussion with Respace

ARTICLE 4 – DATA PROCESSING BY RESPACE

4.1 Management of the Website and Information Requests

Purposes

Respace processes certain data in order to:

enable navigation on the website
respond to requests submitted via the website
organize visits
manage contact forms
ensure the security of the website
improve the user experience
provide user support

Data Processed

Depending on the circumstances:

last name
first name
email address
phone number
company
job title
content of requests
information provided voluntarily
technical browsing data
IP address
technical browser identifiers

Legal Basis

Respace’s legitimate interest
implementation of pre-contractual measures
consent when required

4.2 Management of Prospects and Sales Activities

Purposes

Respace processes prospect data in order to:

provide information
prepare quotes
schedule visits
follow up on sales leads
prepare offers
expand business activities

Data Processed

identity
contact information
represented company
position
interests
contact history
stated needs
requests made

Legal basis

legitimate interest
pre-contractual measures
consent when required

4.3 Management of Customers, Occupants, and Users of Spaces

Purposes

The data processed enables:

the conclusion of contracts
the management of reservations
managing subscriptions
access management
managing services
monitoring space occupancy
billing
customer support

Data Processed

identification data
contact information
Company represented
contractual information
reservation history
billing information
communications with Respace

Legal basis

performance of the contract
legitimate interest
legal obligations

4.4 Event Management

Purposes

Respace may process personal data in order to:

organize events
manage registrations
to handle logistics
manage access
to communicate with participants
to provide related services

Data Processed

identity
contact information
company
job title
event details
organizational needs communicated by the participants

Legal Basis

performance of the contract
legitimate interest
consent when necessary

4.5 Accounting, Financial, and Administrative Management

Purposes

Respace processes certain data in order to:

issue invoices
receive payments
to maintain its accounting records
to comply with its tax obligations
to comply with its legal obligations

Data Processed

identity
contact information
billing information
accounting information
banking information
administrative information

Legal Basis

legal obligation
performance of the contract
legitimate interest

4.6 Management of Suppliers and Partners

Purposes

Respace processes data from suppliers and partners in order to:

review their proposals
enter into contracts with them
manage services
to monitor business relationships
to manage payments

Personal Data Processed

identity
business contact information
job title
company
contractual information
billing information

Legal Basis

performance of the contract
legitimate interest
legal obligations

4.7 Marketing Communications, Newsletters, and Invitations

Purposes

The data may be used to:

send newsletters
to provide information about Respace’s activities
to promote new spaces
to publicize events
send invitations

Data Processed

last name
first name
email address
company
communication preferences
information regarding consent or objection

Legal basis

consent
legitimate interest in cases permitted by applicable law

4.8 Recruitment

Purposes

Candidate data is processed in order to:

evaluate applications
to schedule interviews
to select candidates
to maintain a recruitment pool when the candidate consents

Data Processed

Resume
cover letter
degrees
professional experience
skills
certifications
identification information
other information voluntarily provided

Legal Basis

pre-contractual measures
legitimate interest
consent for the recruitment pool

4.9 Human Resources Management

Purposes

In its capacity as an employer or contracting entity, Respace processes the personal data of its employees, staff members, consultants, freelancers, directors, interns, and other members of its workforce in order to:

to manage the hiring process
to enter into and execute employment or collaboration contracts
manage compensation and benefits
manage schedules, absences, and time off
to comply with social security and tax obligations
manage insurance
manage training
to handle administrative tasks related to personnel
to comply with the legal obligations imposed on the employer
to ensure occupational health and safety
manage the company’s internal organization

Data Processed

Depending on the circumstances:

identification data
personal and professional contact information
administrative data
compensation data
banking information
data related to absences
career-related data
training
performance evaluations
data necessary to comply with legal obligations
data regarding equipment provided
other data necessary for managing the professional relationship

Legal Basis

Data processing is based on:

the performance of the employment or collaboration contract
compliance with Respace’s legal obligations
Respace’s legitimate interest
consent, when required

4.10 Management of IT Tools and Internal Security

Purposes

To ensure the smooth operation of its activities, Respace uses various IT tools and collaborative platforms.

Personal data may be processed for the following purposes:

create and administer user accounts
manage access to systems
to ensure IT security
to prevent security incidents
to protect the company’s assets
secure document repositories
manage backups
to ensure the proper functioning of the tools used
to ensure business continuity

Data Processed

Depending on the systems involved:

last name
middle name
work email address
user credentials
connection information
access history
technical logs
information about the devices used
usage data for business tools

Legal Basis

The processing is based on:

Respace’s legitimate interest
the performance of the contract
compliance with applicable legal obligations regarding information system security

4.11 Transcription, Archiving, and Document Management of Meetings

Purposes

As part of its activities, Respace may transcribe, summarize, classify, document, archive, and retain certain meetings, interviews, workshops, professional exchanges, or discussions.

This processing is carried out, in particular, for the following purposes:

to ensure follow-up on decisions
to document discussions
preserving the organization’s memory
to ensure business continuity
to improve case management
coordinate projects
facilitate information sharing
build structured professional archives
improve operational efficiency

People Affected

The following may be affected:

employees
directors
consultants
freelancers
customers
residents
partners
service providers
suppliers
prospects
meeting participants
any other person involved in Respace’s activities

Data Processed

Transcripts may include, in particular:

identification information
business contact information
project-related information
contract-related data
requests submitted
decisions made
actions to be taken
comments or positions expressed by participants
any other information communicated during the exchange

Possible Use of Recordings

In certain cases, audio or video recordings may be made to enable the creation of a transcript.

When these recordings allow for the direct or indirect identification of individuals, they constitute personal data as defined by the GDPR.

Respace ensures that the retention period for recordings is limited to what is strictly necessary to:

generate the transcript
verify its accuracy
correct any errors

Unless otherwise required, the recordings are deleted after the transcript has been produced and verified.

Access to Transcripts

Transcripts and documentary archives are accessible only to authorized individuals who need to access them as part of their duties or assignments.

Legal Basis

This processing is primarily based on Respace’s legitimate interest in:

document its activities
monitoring decisions
preserving the organization’s memory
manage its records effectively
facilitate collaboration
improve the quality of its services
ensure the continuity of its operations

Respace considers this legitimate interest to be proportionate provided that:

the individuals concerned are properly informed
access to the data is limited
the data retained is relevant
appropriate retention periods are applied
records are retained for a limited period when they are used solely to produce a transcript

ARTICLE 5 – RETENTION PERIODS

Respace retains personal data for a period no longer than is necessary to fulfill the purposes for which it was collected.

Retention periods are determined, in particular, based on:

the nature of the processing
applicable legal obligations
contractual obligations
statutes of limitations
Respace’s operational needs
the recommendations of the competent authorities

5.1 Website and Requests for Information

Data is retained for the time necessary to process the request and then for a maximum of three years from the last contact, unless required by law or in the event of a dispute.

5.2 Prospects

Prospect data is retained for a maximum of three years from the last contact or interaction with Respace.

5.3 Clients and occupants

Data is retained for the entire duration of the contractual relationship.

It may then be archived for as long as necessary to defend Respace’s rights and to comply with accounting, tax, or legal obligations.

5.4 Events

Data is retained for as long as necessary to organize and follow up on the event.

Certain data may be retained for a longer period when it is related to a contractual matter or a legal obligation.

5.5 Accounting and Taxation

Data required for accounting and tax obligations is retained for the periods mandated by applicable law.

5.6 Suppliers and Partners

Data is retained for the duration of the contractual relationship and thereafter for as long as necessary to protect Respace’s legitimate interests and to comply with its legal obligations.

5.7 Marketing Communications

Data is retained until consent is withdrawn or the right to object is exercised.

5.8 Recruitment

Candidate data is retained for the period necessary to evaluate their application.

If the candidate has agreed to be included in a recruitment pool, the data may be retained for a maximum of two years from the date of that agreement.

5.9 Human Resources

Employee data is retained for the duration of the employment relationship and thereafter for the periods required by applicable legal obligations.

5.10 IT Security

Data related to IT security and access logs are retained for a period proportionate to the objectives pursued and the applicable security requirements.

5.11 Transcripts and Documentary Records

Transcripts are retained for as long as necessary to manage the relevant file, project, or activity.

When included in a contractual, administrative, or operational file, they may be retained for the entire lifespan of the relevant file as well as for the applicable archiving periods.

Audio or video recordings used to generate transcripts are deleted as soon as they are no longer necessary for the creation and verification of the transcript, unless there is a specific need justifying longer retention.

ARTICLE 6 – LEGAL BASES FOR DATA PROCESSING

The processing carried out by Respace is based on one or more of the legal bases provided for by the GDPR.

These legal bases include, in particular:

a) The performance of a contract

When processing is necessary for:

the conclusion of a contract
the performance of a contract
the management of a contractual relationship

b) Precontractual measures

When the data subject requests:

a quote
an offer
a reservation
commercial information
an application

c) Compliance with a legal obligation

When Respace must comply with:

tax obligations
accounting obligations
social security obligations
regulatory obligations
security obligations

d) Legitimate Interest

Legitimate interest constitutes the primary legal basis for several processing activities carried out by Respace, including:

system security
supplier management
internal organization
document management
meeting minutes
prevention of abuse
request management
defending Respace’s rights

e) Consent

Consent is used, in particular, for:

certain electronic communications
certain cookies
the creation of a talent pool
any other situation where regulations require prior consent

ARTICLE 7 – RECIPIENTS OF PERSONAL DATA

Respace ensures that access to personal data is limited solely to those individuals who need it to perform their duties.

Personal data may be disclosed to the categories of recipients described below.

Such disclosure occurs only when necessary to achieve Respace’s purposes, to comply with a legal obligation, or to protect its legitimate interests.

7.1 Authorized Respace Personnel

Personal data may be accessible to Respace staff to the extent necessary for the performance of their duties.

Depending on the situation, this may include, in particular:

management
operational managers
administrative teams
sales teams
marketing teams
finance teams
human resources teams
facilities management staff
document management staff
event planners
IT administrators

Respace staff members are subject to confidentiality obligations appropriate to their roles.

7.2 Service Providers and Subcontractors

Respace may engage various external service providers acting as subcontractors.

These subcontractors may be involved in the following areas, among others:

IT hosting
cloud services
email services
document management
management of collaborative workspaces
IT maintenance
IT security
CRM solutions
marketing solutions
HR tools
application management
accounting
billing
payment
website development and maintenance
event management

When these service providers access personal data on behalf of Respace, they are contractually bound to comply with strict confidentiality, security, and data protection obligations in accordance with applicable regulations.

7.3 Suppliers and Operational Partners

Certain personal data may be disclosed to partners or suppliers when such disclosure is necessary for the performance of the requested services.

This may be the case, in particular, for:

event organization
reception services
technical services
audiovisual services
catering services
security services
maintenance services
services related to the spaces provided

The data provided is limited to that which is strictly necessary for the performance of the relevant services.

7.4 External Consultants

Respace may disclose certain data to its external consultants when necessary for the management of its activities.

These recipients may include, in particular:

attorneys
auditors
auditors
certified public accountants
insurers
specialized consultants

These individuals are themselves subject to confidentiality obligations.

7.5 Public Authorities

Personal data may be disclosed to the competent authorities when:

required by law
an administrative authority is carrying out its legal duties
a judicial authority requests it
such disclosure is necessary to defend Respace’s rights

ARTICLE 8 – DATA TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA

In the course of its activities, Respace prioritizes, as much as possible, the use of services and infrastructure located within the European Economic Area.

However, certain technology providers, cloud services, or software vendors used by Respace may involve the transfer of personal data to countries outside the European Economic Area.

When such transfers take place, Respace ensures that they are carried out in accordance with the requirements of the GDPR.

8.1 Safeguards in Place

When a transfer to a third country is made, Respace ensures that at least one of the following safeguards applies:

an adequacy decision adopted by the European Commission
standard contractual clauses approved by the European Commission
binding corporate rules
any other safeguard recognized as valid under applicable regulations

8.2 Additional Information

Any data subject may request further information regarding international data transfers by contacting Respace in accordance with the procedures described in the section on the exercise of rights.

ARTICLE 9 – DATA SECURITY AND CONFIDENTIALITY

Respace implements appropriate technical and organizational measures to protect personal data against:

accidental or unlawful destruction
accidental loss
alteration
unauthorized disclosure
unauthorized access
any other form of unauthorized or unlawful processing

These measures are regularly reviewed and adapted in light of evolving risks and available technologies.

9.1 Organizational Measures

The organizational measures implemented may include, in particular:

restricting access to data
assigning individualized access rights
authorization management
staff awareness training
internal procedures regarding confidentiality
managing clearances
security incident management
supervision of subcontractors

9.2 Technical Measures

The technical measures implemented may include, in particular:

secure authentication
encryption of communications
regular backups
access logging
antivirus protection
firewalls
incident detection mechanisms
infrastructure security
access segmentation
data recovery mechanisms

9.3 Security of Document Repositories

The document repositories used by Respace to store data and meeting transcripts are subject to specific measures designed to:

control access
limit access
prevent unauthorized access
ensure the integrity of the documents
secure digital archives

9.4 Security Incident Management

Respace has implemented procedures to:

identify security incidents
document them
to limit their impact
to make the required notifications to the relevant authorities
to inform affected individuals when required by applicable regulations

ARTICLE 10 – PROCESSING BY THIRD PARTIES

When Respace engages a processor as defined by the GDPR, it ensures that the processor provides sufficient guarantees regarding the implementation of appropriate technical and organizational measures.

Processors may process personal data only upon documented instructions from Respace and in strict compliance with applicable obligations.

Agreements in accordance with Article 28 of the GDPR are put in place when required.

ARTICLE 11 – PRINCIPLE OF DATA MINIMIZATION

Respace ensures that it collects only personal data that is adequate, relevant, and limited to what is necessary in light of the purposes pursued.

Each new processing operation is subject to an analysis aimed at:

limit the volume of data collected
avoid the collection of unnecessary data
reduce retention periods
limit access
reduce risks to data subjects

ARTICLE 12 – ACCURACY OF DATA

Respace takes reasonable measures to ensure that the personal data processed is:

accurate
complete
updated when necessary

Data subjects are encouraged to notify Respace of any changes to their data.

ARTICLE 13 – ACCOUNTABILITY

In accordance with the principle of accountability set forth in the GDPR, Respace implements measures designed to demonstrate its compliance with applicable regulations.

To this end, Respace may, in particular:

maintain a record of processing activities
establish internal policies and procedures
train individuals who process personal data
document decisions related to data protection
conduct risk assessments
conduct internal or external audits

ARTICLE 14 – YOUR RIGHTS

In accordance with applicable data protection regulations, you have various rights regarding your personal data processed by Respace.

Subject to the conditions and limitations set forth in applicable regulations, you have the following rights, among others:

14.1 Right of Access

You have the right to obtain confirmation as to whether or not Respace is processing personal data concerning you.

If this is the case, you have the right to access this data as well as certain information relating in particular to:

the purposes of the processing
the categories of data concerned
the recipients
retention periods
the safeguards applicable in the event of an international transfer
the source of the data when it was not collected directly from you

14.2 Right to Rectification

You have the right to have inaccurate personal data about you corrected.

You also have the right to request that incomplete data be completed.

14.3 Right to erasure

You may request the erasure of your personal data when:

the data is no longer necessary
you withdraw your consent when it constitutes the legal basis for the processing
you validly object to the processing
the data has been processed unlawfully
a legal obligation requires its deletion

The exercise of this right remains subject to the limitations set forth in applicable regulations.

14.4 Right to Restriction of Processing

You may request the restriction of the processing of your personal data, particularly in the following situations:

when you contest the accuracy of the data
when the processing is unlawful but you do not wish to have the data erased
when Respace no longer needs the data but you still need it to exercise or defend your legal rights
while a request to object is being reviewed

14.5 Right to Object

When processing is based on Respace’s legitimate interest, you have the right to object to such processing for reasons related to your particular situation.

Respace will then cease the processing in question unless it demonstrates compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or where the processing is necessary for the establishment, exercise, or defense of legal claims.

14.6 Right to Object to Marketing Communications

You have the right at any time to object to receiving commercial communications or marketing messages.

This right is free of charge and may be exercised:

by using the unsubscribe link provided in the communications
by contacting Respace directly

14.7 Right to Data Portability

When processing is based on your consent or a contract and is carried out by automated means, you may request:

the disclosure of your personal data in a structured, commonly used, and machine-readable format
the direct transmission of this data to another data controller, where technically feasible

14.8 Right to Withdraw Your Consent

When processing is based on your consent, you may withdraw it at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

14.9 Right not to be subject to automated decision-making

You have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, except in cases provided for by applicable regulations.

ARTICLE 15 – EXERCISING YOUR RIGHTS

You may exercise your rights or ask any questions regarding the protection of your personal data by contacting Respace through one of the following methods:

By mail

RESPACE SA
Place Poelaert 6
1000 Brussels

By email

pierre.colaiacovo@respace.be

In order to process your request, Respace may need to verify your identity when necessary.

Respace will respond to your request within the timeframes set forth in applicable regulations.

ARTICLE 16 – COMPLAINTS TO THE SUPERVISORY AUTHORITY

If you believe that the processing of your personal data does not comply with applicable regulations, you have the right to file a complaint with the competent supervisory authority.

In Belgium, the competent authority is:

Data Protection Authority
Rue de la Presse 35, 1000 Brussels

Website: https://www.autoriteprotectiondonnees.be/

This right may be exercised without prejudice to any other administrative or judicial remedy.

ARTICLE 17 – COOKIES AND SIMILAR TECHNOLOGIES

17.1 Principle

The Respace website uses cookies and similar technologies to ensure it functions properly, to improve your user experience, and to ensure the security of its services.

A cookie is a small file stored on your device when you visit a website.

Cookies can be temporary or persistent and are used, among other things, to:

secure browsing
to remember certain preferences
to improve the website’s functionality
measuring website traffic
to ensure certain technical functions

17.2 Strictly Necessary Cookies

Certain cookies are essential for the website to function.

These cookies may, in particular, allow:

maintain the user’s session
to ensure the security of the site
to ensure pages display correctly
enable certain essential features

These cookies are used based on Respace’s legitimate interest or when they are strictly necessary to provide the requested service.

17.3 Audience Measurement Cookies

Respace may use cookies or statistical tools to:

analyze website traffic
understand how visitors use the site
improve the content offered
optimize functionality

When required by law, these cookies will only be placed after obtaining your prior consent.

17.4 Marketing Cookies

If Respace uses marketing or advertising cookies, they will be placed only after obtaining your consent when required by applicable regulations.

17.5 Managing Your Preferences

You may at any time:

accept cookies
reject certain cookies
withdraw your consent
change your preferences

You can also configure your browser to block or delete certain cookies.

However, blocking certain cookies may affect the website’s functionality.

17.6 Cookie declaration

The list below is automatically generated and updated by Cookiebot. It includes all cookies currently detected on our website:

ARTICLE 18 – USE OF GOOGLE reCAPTCHA

To protect its website against automated access, malicious bots, fraud attempts, and abuse, Respace uses Google reCAPTCHA v3. This use is expressly mentioned in the policy currently published on the Respace website.

Google reCAPTCHA may process certain technical data such as:

the IP address
browser characteristics
information about the device used
certain interactions performed on the website
information used to determine whether the observed behavior is that of a human or an automated program

The processing of this data is based on Respace’s legitimate interest in ensuring the security of its digital services and protecting its website against abuse.

For more information regarding Google’s processing of this data, please refer to Google’s published documentation on data protection.

ARTICLE 19 – CHANGES TO THE PRIVACY POLICY

Respace reserves the right to amend this Privacy Policy at any time to reflect, in particular:

changes in its business activities
changes in its services
changes in its IT tools
changes in laws or regulations
new recommendations from the relevant authorities

The most recent version of the Privacy Policy will always be available on the platforms provided by Respace.

In the event of a substantial change, Respace may take appropriate measures to notify the individuals concerned.

ARTICLE 20 – EFFECTIVE DATE

This Privacy Policy took effect on July 22, 2026.

It supersedes any previous version relating to the same subject matter.

ARTICLE 21 – CONTACT

If you have any questions regarding this Privacy Policy or how Respace processes your personal data, please contact:

RESPACE
Place Poelaert 6
1000 Brussels
pierre.colaiacovo@respace.be