Protection of personal data

GOREX LUXURY CONCIERGE attaches paramount importance to the protection of privacy and the confidentiality of its members. This policy describes how your personal data is collected, used, retained and protected. It complies with the General Data Protection Regulation (GDPR — EU 2016/679) and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.

1. Data controller

The controller of the personal data collected via the GOREX LUXURY CONCIERGE application is:

2. Data collected

In providing its luxury concierge services, Gorex Group SA processes the following categories of data:

• Identity and contact details: surname, first name, address, email, phone, nationality.
• Professional data: company name, company number (BCE), VAT number, billing address.
• Service data: requests, bookings, itineraries, travel preferences, dietary preferences, interests.
• Financial data: invoices, quotations, payments, bank details.
• Connection data: identifier, access timestamp, activity log.
• Possible sensitive data (health, security): only where the service requires it, with explicit consent.

3. Purposes and legal bases

The data is processed for the following purposes, each based on a legal basis (Art. 6 GDPR):

• Performance of the concierge agreement — performance of a contract.
• Management of bookings, itineraries and requests — performance of a contract.
• Invoicing and accounting obligations — legal obligation (Belgian accounting law).
• Electronic invoicing via the Peppol network — legal obligation.
• Security, fraud prevention and access management — legitimate interest.
• Marketing communications and personalised offers — consent (withdrawable at any time).

4. Recipients and processors

Data may be disclosed, strictly to the extent necessary, to:

• Our authorised staff (concierges, managers, finance team) bound by confidentiality.
• Our partner providers (hotels, carriers, security, medical coordination) for performance of the service.
• Our technical processors (hosting, Peppol electronic invoicing, payment provider).
• Administrative or judicial authorities where a legal obligation requires it.

Every processor acts on documented instructions and provides guarantees compliant with Article 28 GDPR.

5. Transfers outside the European Union

Data is in principle hosted within the European Economic Area (EEA). Any transfer to a third country is framed by appropriate safeguards (European Commission standard contractual clauses, adequacy decision), in accordance with Chapter V of the GDPR.

6. Retention periods

• Account data: during the contractual relationship, then 5 years after it ends.
• Accounting documents and invoices: 7 years (Belgian legal obligation).
• Connection logs: maximum 12 months.
• Marketing data: until consent is withdrawn.

7. Your rights

In accordance with Articles 15 to 22 of the GDPR, you have the following rights:

• Right of access to your data.
• Right to rectification of inaccurate data.
• Right to erasure ("right to be forgotten").
• Right to restriction of processing.
• Right to object to processing.
• Right to data portability.
• Right to withdraw your consent at any time.

To exercise these rights, write to concierge@gorex.com. A response will be sent within one month.

8. Security

GOREX LUXURY CONCIERGE implements appropriate technical and organisational measures: encryption of transmissions, role-based access control, audit log, regular backups and an internal confidentiality policy. In the event of a data breach likely to result in a high risk, the Data Protection Authority and the data subjects are notified in accordance with Articles 33 and 34 of the GDPR.

9. Supervisory authority

You have the right to lodge a complaint with the Data Protection Authority (APD/GBA):

10. Cookies and local storage

The application uses local storage (shared preferences) for the session and your preferences. This data remains on your device and is not used for advertising purposes. No third-party advertising tracking cookies are set.

By using GOREX LUXURY CONCIERGE, you acknowledge having read this privacy policy.