Privacy Policy

1. Identity and contact details of the controller

This Privacy Policy applies to the personal data processing operations described below carried out by Horizon Holdco NV, with registered office at Leuvensesteenweg 643 bus 14, 1930 Zaventem, with company number BE 0474.087.795, which is the controller of this website (hereinafter also referred to as ‘Hypotheekwinkel’ or ‘we’).

We attach great importance to your privacy and therefore process your personal data in accordance with the European Regulation 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter “GDPR”) as well as any future or additional legislation implementing it, as applicable.

For further questions or comments regarding our handling of your personal data, please contact us at any time, either by e-mail to or by mail to the aforementioned mailing address.

Our DPO can also be reached through the same contact information (stating ‘tav the DPO’).

2. What does “process personal data” mean?

Processing personal data (hereinafter “data”) includes any processing of data that can identify you as a natural person. You can read about what data is involved in this Privacy Policy. The term “processing” is very broad and covers, among other things, collecting, storing, using, or sharing your data with third parties.

3. What data do we process?

Below we clarify what data we may process from you. Depending on the specific situation, your preferences and the way you contact us, we do not process all of the information below about you.


Of all our contacts, we may process the information below:

  • Electronic identification and usage data (e.g., IP address, browser type, location data);
  • Identification data (e.g. copy of your identity card as part of a GDPR request);
  • Contact information (e.g., name, first name, address, e-mail address, etc.);
  • Contact history (e.g., e-mail messages, messages sent through web forms, etc.).

Main activity

Of our customers, we may additionally process the following data, in particular for the purpose of providing our mortgage loan comparison and related consulting services:

  • Contractual data (e.g., scheduled appointments, signed client sheet/agreement, address, etc.);
  • Identity card information for the purpose of legally required identity verification in credit intermediation and lending;
  • Nationality, gender, country of legal residence, education level and marital status;
  • Bank and account number;
  • All relevant financial data in function of the desired credit as also explained in more detail on the relevant customer information sheets, which to a limited extent may possibly include special and criminal personal data (e.g. current income and debts and benefits enjoyed, current loans, family situation, benefits received, pension, overdue social contributions, state of bankruptcy, etc.);
  • Feedback, testimonials and promotional content such as photos and videos related to our services.

Business partners

Of our business partners, including members of our franchise network, lenders with whom we work and suppliers, we may additionally process the information below:

  • Contractual data (e.g. company name, address, VAT number, agreement, etc.);
  • Payment and billing information (e.g. payment card details, invoices, etc.);
    Account and usage data (especially for our application Hypodrome intended for use by members of our franchise network);
  • Feedback, testimonials and promotional content such as photos and videos related to our collaboration.

Staff Candidates

Of prospective employees, we may additionally process the following information. Of course, this will largely depend on what information you yourself wish to provide to us as a function of your application.

  • Personal details;
  • Work-related data;
  • Personality data;
  • Photos

4. For what purposes do we process your data?

We process your data for the purposes described below and do not collect and process more and no other types of data than those necessary for these purposes.

Operational purposes

We process data for the optimization of our website; statistical purposes and market research; to keep our services user-friendly; answering your contact request.

Business purposes

We process data within the scope of our main activity, such as to assist you as a customer-loan applicant in finding a suitable lender who can provide you with a mortgage loan tailored to your situation or to make preliminary simulation calculations in this regard; to consider the affiliation of business partners to become credit broker members of our franchise network; to communicate with you about our services or cooperation; to inform you about our policies, general terms and conditions of use; to develop and manage relationships with our potential and existing contacts and partners.

Business purposes

We process data for sending marketing communications by email or post; for sending newsletters; or to record your registration to one of the events we organize such as information sessions.

Commercial purposes

We process data for sending marketing communications by email or post; for sending newsletters; or to record your registration to one of the events we organize such as information sessions.

Legal or regulatory purposes

We process data for legal reasons and procedures; to comply with laws and government orders; or to meet our internal and external audit requirements, information security or to protect or enforce our rights, privacy, security or property or those of other persons.

5. On what grounds do we process your data?

We only process your data to the extent based on one of the processing grounds listed in the GDPR, as shown below.

Legal obligation

Certain data are processed by us to comply with legal or regulatory obligations imposed on us. In connection with our activities as an FSMA-approved broker in the field of home loans, insurance and consumer loans, our tax and accounting obligations, or our data protection obligations.

Necessary for the formation / performance of an agreement

Certain data are processed by us because it is necessary for entering into, performing or terminating a contract with you as a data subject. For contacting, scheduling, responding to a request or requesting information within the framework of entering into a contractual relationship including the provision of an appointment scheduler and preparatory information, simulation calculation and download forms on our website, as well as the effective execution of the contractual assignment within the framework of our main activity, in order to provide you with our services (guidance to consumers on taking out a mortgage loan and related insurance, training for professionals on home loans and insurance, …), or to receive them from you.

Legitimate interest

Certain data are processed by us based on our legitimate interests which in specific cases outweigh any potential harm to your rights. To promote our activities to existing customers-credit applicants and to business contacts; to improve the quality of our services; to provide information, simulation calculation and download forms on our website when their completion is outside of a (potential) agreement with us, to train employees and to evaluate and maintain data and statistics related to our activities, in the broadest sense; preserving and using evidence in the context of liability, litigation or disputes and for the purpose of archiving activities; and ensuring security, both online on this website and on our premises.

Commercial purposes

We process data for sending marketing communications by email or post; for sending newsletters; or to record your registration to one of the events we organize such as information sessions.


Certain data is processed by us based on your consent. For promoting activities to potential new contacts where required; using certain analytical or marketing cookies; posting photos or other publications containing personal data on our website and social media channels.

In those cases where we need to process special and/or criminal personal data in order to provide our services, we will rely on your explicit consent for this when the law does not provide a specific basis for this.

6. Origin of data?

We also obtained most of the data we process from you directly. Within the scope of our services, we may obtain data from you through our business partners, external service providers or public sources.

7. With whom do we share your data?

We do not disclose your data to third parties, except when strictly necessary in light of the above-mentioned purposes, or if we are required to do so by law.

Where necessary, we use external service providers (processors) to support our operational purposes such as managing our websites and IT systems. These external service providers, where appropriate, perform certain data processing operations on our behalf. We will share your data with these external service providers only to the extent necessary for the relevant purpose. The data may not be used by them for other purposes. In addition, these service providers are contractually bound to ensure the confidentiality of your data through a “processor agreement” signed with these parties.

Specifically, as relevant in your situation, we share your data with the following third parties for the following purposes, with these third parties acting as processors on our behalf in certain cases:

    • Postal, transportation and delivery companies if we need to send you something by mail;
    • Payment service providers if we receive payments from you, or vice versa;
      External representatives and consultants or any other parties involved in the context of our main or ancillary activities;
    • If you are a customer-loan applicant, to the relevant local mortgage store, which, either as a store in its own right or as an independent member of our franchise network at the local/regional level, will be responsible for servicing you and further handling your file, according to the applicable agreements in our franchise network;
    • If you are a customer-loan applicant, to lenders, with a view to presenting your file and obtaining a concrete proposal for a mortgage loan tailored to your situation, whereby if you accept it, you enter into a direct contractual relationship with the lender concerned;
    • The processors who assist us in IT to operate our organization for the purpose of secure and efficient digital data management within our organization;
    • Government agencies, judicial authorities and practitioners of regulated professions such as accountants and lawyers, for the purpose of complying with our legal obligations and defending our interests, as required.

8. How long do we keep your data?

We do not retain your data longer than necessary for the purpose for which the data was collected or processed. Since the period for which the data can be retained depends on the purposes for which the data were collected, the storage period may vary in each situation. Sometimes specific legislation will require us to keep the data for a certain period of time. Our retention periods are always based on legal requirements and a balancing of your rights and expectations with what is useful and necessary to fulfill the purposes. Upon expiration of the retention period, your data will be deleted or anonymized.

9. Where do we keep your data and how is it protected?

We provide appropriate security measures on a technical and organizational level, to avoid within the scope of our activities the destruction, loss, falsification, alteration, unauthorized access or unauthorized notification to third parties as well as any other unauthorized processing of this data.

We are also careful to ensure that the processors we rely on also take appropriate security measures to minimize risks of incidents as much as possible.

We aim to process the data we process as much as possible within the European Economic Area (EEA). If, when using specific services or software tools, your data is processed outside the European Economic Area (EEA), it will only be processed in/to countries that the European Commission has confirmed as providing an adequate level of protection for your data, or measures will be taken to ensure the lawful processing of your data in these third countries.

10.What are your rights?

You have several rights regarding the data we process about you, as listed below. If you wish to exercise these rights, please contact our internal GDPR Officer or DPO using the contact information included under the first title of this Privacy Policy.

Right of inspection and copy

You have the right to see your data and get a copy of it. This right also includes the possibility of requesting further information about the processing of your data, including the categories of data processed about you and for what purposes.

Right of adaptation or rectification

You have the right to have your data amended if you believe we have incorrect data.

Right of data sharing (right to oblivion).

You have the right to request that we delete your data without unreasonable delay. However, we will not always be able to fulfill such a request, including when we still need the data in function of an ongoing contract, or when keeping certain of your data for a certain period of time is required by law.

Right to restriction of processing

You have the right to restrict the processing of your data. In this way, the processing is temporarily stopped until, for example, there is certainty about its accuracy.

Right to withdraw your consent

If the processing is based on your consent (see above under titles 5 and 6), you have the right to withdraw this consent at any time by contacting us. For marketing messages you receive from us via e-mail based on your consent, you may easily withdraw such consent by clicking the unsubscribe link at the bottom of any such message.

Right to object

You have the right to object to the processing of your data based on legitimate interest. This should be based on reasons specific to your situation. You may also object to the use of your data for direct marketing purposes. Email marketing messages will always provide an opt-out.

Right to Transferability

You have the right to obtain in electronic form your data that you yourself have provided to us with your consent or in performance of a contract. That way, they can easily be transferred to another organization. You also have the right to ask us to transfer your data directly to another organization, if this is technically possible.

Right to complain to your supervisory authority

Should you believe that we are processing your data in an incorrect manner, you always have the right to lodge a complaint with your data protection supervisory authority.

Belgian Data Protection Authority, (GBA).

Printing Press Street 35,

1000 Brussels,

11. How can you exercise your rights?

You may exercise your rights by contacting us, either by e-mail to or by mail to Leuvensesteenweg 643 bus 14, 1930 Zaventem, provided that you enclose a copy of the front of your identity card or other document identifying you. The copy will only be used to identify you in accordance with the GDPR.

12. Changes

We reserve the right to change this Privacy Policy. The most recent version is available on our websites at all times. The date this Privacy Policy was last modified can be found at the top. In the event of a substantial change to the Privacy Policy, we will directly inform, if possible, those data subjects on whom it may have an impact.