I. Introduction
A. Why this Privacy Statement?
Jitsie undertakes to respect the applicable data protection legislation as specified in Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereafter "General Data Protection Regulation" or "GDPR").
Jitsie, with registered office at Steenweg 3, Berbroek Business Park, Unit 3.504, 3540 Herk-de-Stad, Belgium (hereafter "Jitsie", "we" or "our") believes in protecting the privacy and the confidentiality of the Personal Data we hold of you.
We acknowledge that you may have privacy and security concerns with respect to the Personal Data we collect, use, and possibly disclose to third parties for the purpose of allowing us to offer and provide our products and services. To this end, we have developed this Privacy Statement (hereafter "Statement").
B. When does this Privacy Statement apply?
This Statement only applies to the processing of Personal Data by Jitsie acting as a controller, meaning when Jitsie is the one determining the purpose and means (the "why" and "how") of such processing.
Personal Data is any combination of information, in the possession of or likely to come into the possession of Jitsie, that can be used to identify an individual (hereafter "Personal Data"). All processing of Personal Data by Jitsie will be treated in accordance with applicable data protection legislation and this Privacy Statement. Any information that cannot be used to identify a discrete individual is not Personal Data.
C. How does this Privacy Statement apply?
This Statement sets out how Jitsie processes information collected via its own website www.jitsie.com and all business activities or relationships relating to it.
These operating activities can involve the processing of Personal Data of the following individuals: every visitor to our website, recruitment applicants, personal or corporate clients (and individuals associated with our corporate clients), suppliers (including subcontractors and individuals associated with our suppliers and subcontractors), business contacts (existing and potential clients and/or individuals associated with them) or other individuals who get in touch with us, attend our events or visit our office.
This Statement sets out our practices regarding the use of Personal Data, the steps we take to protect it, as well as the choices and rights that data subjects ("you" or "your") have regarding on how we collect and process information about them.
Please note that this Statement should be read together with other legal information we provide, such as our and our Cookie Policy.
II. The processing of your Personal Data
A. When do we collect your Personal Data?
The Personal Data collected and processed by Jitsie is generally received from:
- You voluntarily, e.g.
- when you contact us via the website, by email, post, telephone, by exchanging business cards, by submitting a request to exercise your rights,…;
- when you apply for a job with us;
- when you subscribe to our newsletter, request an account or attend an event of us; or
- when you engage a contractual relationship with us.
- Through website navigation, e.g.
- when you navigate the website, we may collect limited Personal Data automatically via the use of cookies on our website. Please see our Cookie Policy for more information.
If Jitsie would receive Personal Data of you from third parties and we use this information for further processing as a controller, we will inform you about such processing at the latest at the moment of first contact with you.
B. Which Personal Data do we collect?
We may collect and process the following (non-exhaustive) data that can be considered Personal Data of you. Depending on the situation and the relationship we have with you we do not maintain all information mentioned hereafter.
- Electronic identification data, such as browser type, Internet Protocol (IP) address, user ID, unique identifier assigned to your device, geographic location, actions performed within a web page, information derived from content of a web page, … as a result of, for example, a visit to our website that uses cookies.
- Identification details, such as identity card details, scan or copy of your identity card,… which we will request, for example, before we can grant a request for the exercise of your rights.
- Contact information, such as your name, (email) address and any other contact details that you provide to us, for example, when you contact us or you are the contact person of our client or supplier.
- Contact history, such as sent and received communication (e.g. emails), … as a result of the communication we have with each other.
- Personal details, such as age, date of birth, place of birth, … when you provide it to us in the context of, for example, an application for a job with us.
- Work related details, such as CV, education, testimonials, language skills, employer (including history of former employers), professional activities, professional skills, publications, salary, assessment & development reports, interview report, reference research, social media profiles, ... when you provide it to us in the context of, for example, an application for a job with us.
In general, we will only collect Personal Data that is needed to provide our services to our clients and that is relevant for achieving the purposes as specified hereafter.
Jitsie does not process children's data nor sensitive information (e.g. race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sexual life or sexual orientation) or criminal information (e.g. information relating to criminal convictions and offences).
In any case, Jitsie will only process sensitive data when required by law or with your explicit consent.
C. Why and how do we use your Personal Data?
As mentioned above, we generally obtain information of you directly from you. We only collect the Personal Data necessary for agreed purposes as mentioned hereafter and we ask you to only share your Personal Data where it is strictly needed for those purposes.
Jitsie can use the Personal Data for the following purposes:
- Operational purposes, such as administering and managing our website, products and services; considering a job application, answering request for information or to exercise your rights, security, quality and risk management activities,….
- Business purposes, such as providing our products and services to our clients; administering, managing and developing our businesses, business relationships, contracts, products and services; providing information about us and our range of services; receiving services from our suppliers; complying with any requirement of law, regulation or a professional body of which we are a member,….
- Commercial purposes, such as direct marketing purposes (e.g. sending you our newsletter).
Jitsie will only use your Personal Data for these above mentioned purposes, unless you have specifically consented to it. If we intend to use your Personal Data for purposes other than communicated to you, we will inform you in advance. For example: we will not use your Personal Data for advertising purposes unless you have freely given your explicit and prior consent.
D. On which legal grounds do we collect your Personal Data?
Jitsie only processes the Personal Data for legitimate purposes. The use of Personal Data will also be justified on the basis of one or more legal "processing grounds" that are provided for in the General Data Protection Regulation (GDPR).
Jitsie processes the Personal Data on the following legal grounds:
- The processing is necessary for the performance of a contract to which, for example, our client or supplier is party, or in order to take steps at your request to entering into a contract with us.
- The processing is based upon your given consent. We rely on the following actions by you as indications of your consent to the processing of the Personal Data: your voluntary provision of Personal Data to us directly; your express consent or acknowledgement contained within a written, verbal or electronic application or claims process; your verbal consent solicited by Jitsie for a specified purpose. We will provide you with the opportunity to consent when the Personal Data in question is collected. You can withdraw your consent at any time. For more information please see section VI. Your Rights below.
- The processing is necessary for the purposes of our legitimate interests. We may also process the Personal Data when we have a legitimate interest to do so and provided specific conditions are met, such as to defend and prosecute legal claims and rights, and other business interests. Where we rely on this legal processing ground, we will mitigate the effect(s) this may have on your privacy by appropriately minimising our use and putting in place adequate access and security safeguards to prevent unauthorised use.
- The processing is based upon a legal obligation. As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We may therefore process your Personal Data for compliance reasons.
III. Retention of Personal Data
We retain Personal Data processed by us for as long as is considered necessary for the purpose for which it was collected. Considering the data retention period for which Personal Data can be held, depends on the purposes for which the information was collected, the data retention period can vary in each situation.
In some cases applicable law or regulation will require us to maintain Personal Data for a certain period.
In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for Personal Data is based upon the minimum legal requirements and a balancing of your rights, interests and expectations with what is considered useful and necessary for achieving the aforementioned purposes and providing our products and services (e.g. for as long as we have, or need to keep a record of, a relationship with you).
IV. Security of Personal Data
Jitsie takes the security of Personal Data we hold very seriously. We have therefore implemented appropriate technical and organisational measures to secure the processing of personal data. These safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Data, and include measures designed to keep Personal Data protected from unauthorized access. If appropriate, the safeguards include the encryption of communications via SSL, encryption of information during storage, firewalls, access controls, separation of duties, and similar security protocols. We restrict access to Personal Data to personnel and third parties that require access to such information for legitimate, relevant business purposes.
All our staff members, contractors and third parties who will have access to Personal Data on Jitsie instructions will be bound to confidentiality and we use access controls to limit access to individuals that require such access for the performance of their responsibilities and tasks.
V. Transfer of Personal Data
We will only share your Personal Data with others when we are legally permitted to do so and where necessary to fulfil the purposes related to those described above. When we share your Personal Data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our own data protection, confidentiality and security standards.
We store your Personal Data chiefly on IT systems in Belgium. Some of these IT systems are outsourced to third parties, whereby the data may be stored within the European Economic Area (EEA). We have also engaged IT service providers located outside of the EEA, which means that your personal data may also be stored outside of the aforementioned countries. All (IT) service providers, act as data processors on our behalf.
Where we transfer the Personal Data outside of the EEA, we have taken steps to ensure all Personal Data is provided with adequate protection and that all transfers of the Personal Data outside the EEA take place in accordance with applicable data protection legislation and that there will be an appropriate level of protection.
VI. Your rights
You have various rights concerning the Personal Data collected about you. If you would like to exercise one of the rights described below, please contact us via the contact details provided hereafter (by email, telephone or post).
You have the following rights:
- Right to access and copy. You have the right to be provided with access to any Personal Data held about you by Jitsie.
- Right to amendment or rectification. You can ask us to have inaccurate Personal Data corrected. For those who have an account on our website, we also provide the possibility to amend and correct your information yourself via the account settings.
- Right to erasure. You can ask us to erase Personal Data in certain circumstances and we will take reasonable steps to inform data processors that are processing your Personal Data on our behalf that you have requested the erasure of any links to, copies or replication of your Personal Data.
- Right to restriction. You can require certain Personal Data to be marked as restricted whilst complaints are resolved and also restrict processing in certain other circumstances.
- Right to portability. You can ask us to transmit the Personal Data that you have provided to us and we still hold about you to a third party electronically insofar as permitted under the GDPR.
In addition, under certain conditions, you have the right to:
- where processing is based on consent, withdraw your consent at any time;
- object to any processing of personal that Jitsie justifies on the "legitimate interests" legal ground, unless our reasons for undertaking that processing outweigh any prejudice to the individual's privacy rights; and
- object to direct marketing (including any profiling for such purposes) at any time.
When you submit a request to exercise your rights, we will first verify your identity by requesting a copy of your identity card. We do this in order to prevent your Personal Data from falling into the wrong hands.
Exercising your rights is in principle free of charge. If your request appears to be unfounded or frivolous, we may charge you a reasonable fee in order to cover our own administrative costs. In such cases, however, we may also simply opt to decline your request. You will then be notified of the reasons for this.
In any case, we will always notify you within a period of four weeks (for simple requests) or 3 months (for complex or multiple requests) of the response to your request.
VII. Your complaints
Despite all of our efforts to protect your privacy and to comply with the relevant legislation, it is possible that you may not agree with the way in which we collect, use and/or process your Personal Data.
Naturally, in that case you may always contact us, but you also have other possibilities for filing a complaint.
In first instance, you have the right to file a complaint with the supervisory authority, which you can contact via the contact details below:
- Via post: Jitsie, Steenweg 3, Berbroek Business Park, Unit 3.504, 3540 Herk-de-Stad, Belgium
- Via email: support@jitsie.com
- Via telephone: +3213554045
Subsequently, if you have incurred damages, you can also file a claim with the competent court.
For more information concerning complaints and legal recourse, we invite you to consult the website of the data protection authority: www.gegevensbeschermingsautoriteit.be/klacht-en-beroep.
VIII. Updates to this Statement
Jitsie reserves the right to revise and update this Statement at any time. However, the most recent version will always be made available on our website.
IX. Questions about this Statement
Should you have any comments or questions about this Privacy Statement or the processing of your Personal Data by Jitsie acting as a controller, you may contact us:
- Via post: Jitsie, Steenweg 3, Berbroek Business Park, Unit 3.504, 3540 Herk-de-Stad, Belgium
- Via email: support@jitsie.com
- Via telephone: +3213554045