AG Real Estate's Privacy Notice

In a visually oversaturated environment, A4 stickers announce to shoppers and passerbys the techniques that surveil them, and to which one is supposed to have agreed to by entering a certain space. These privacy notices are made mandatory by the European General Data Protection Regulation (GDPR). On and around place de la Monnaie, they feature QR codes that link to the privacy statement of AG Real Estate, the real estate agency that owns the shopping malls The Mint on the square, Gallerie Aanspach, on the other exit of the Brouckere Metro Station, and City2, few hundred meters down the Rue Neuve. In AG’s privacy policy, we can find the links to two different companies that provide people counting services in an around their retail spaces: PFM and Fidzup.

Systems involved in Footfall analysis, such as those tracking smartphones through probe-requests, present themselves as a seemingly innocuous activity of counting pedestrians in a shopping street. Their privacy statements will mention that no private data is being collected, personal identifyers are pseudomymized, opting-out is always an option, and so on. One of the two companies hired by AG real estate to do Footfall analysis, Fidzup, has been first convicted in France for missuse of personal data, while the other one, PFM Footfall, has invested in ways to comply with the GDPR.