ITP Agency NV, registered office at Sassevaartstraat 46 b 401, 9000 Ghent (Belgium) and with enterprise number 0825.170.684 (also referred to below as “In The Pocket”, “we” or “us”) takes your privacy very seriously and considers it important for your personal data (hereafter “your data”) to be treated with the necessary care and confidentiality at all times.
This Privacy Statement explains why we require your personal data and what we do with it. If you have any questions after reading this Privacy Statement, you are always welcome to contact us.
To avoid any misunderstandings, we would like to clarify that this Privacy Statement is applicable on the processing of personal data from:
In The Pocket is responsible for processing your data. This means that we determine the purposes and means (or the “why” and “how” questions) for processing your data. For questions concerning the processing of your data, you can always contact us via the following contact details:
Hereunder we clarify which data we can process about you depending on the relationship you have with In The Pocket. Depending on the situation, we will not necessarily process all of the data mentioned below.
In principle, we will not process special categories of data (such as medical data, political views, religious or philosophical beliefs and trade union membership) from any of the categories of persons mentioned above, unless you provide it to us with your explicit consent and for specified purposes.
We only process your data for legitimate purposes, and it will always be processed according to the grounds for processing as listed in the European General Data Protection Regulation (GDPR). Hereunder we clarify on which legal grounds we process your data depending on your relationship with In The Pocket.
When we process your data on the basis of your consent, you may withdraw this consent at any time by contacting us. We request that you always confirm an orally expressed withdrawal of consent in writing (by email or letter).
When we process your data on the basis of our legitimate interests, we will limit the effects that this may have on your privacy by minimizing our use and establishing appropriate access and security safeguards in order to prevent unauthorized use. Moreover, you have at any time the right to object against the processing of your data that is based on our legitimate interests.
We may process your data based on your prior consent. This is for example the case when you agree with the usage of marketing and tracking cookies.
We may process other data, such as data of essential cookies and functional cookies. The use of essential and functional cookies does not depend on your consent. Essential cookies are, for purely technical reasons, necessary to make the communication between your device and the Website possible. Functional cookies are necessary in order for the Website to function properly. More information can be found in our Cookie Statement.
When providing our products and services as a digital products studio, we process your data because this is necessary for the conclusion, performance or termination of a contract with our clients and business partners. In this case we always process your data in the context of offering and providing our products and services to you, or because you as our business partner assist us in providing these to our clients.
We also process your data when this is necessary for complying with our legal obligations, such as to comply with our accounting obligations.
Furthermore we may process your data based on your prior consent. This is for example the case when you fill in your email address in the ‘Subscribe’ form on our Website. In this event we use the provided email address to provide you with our newsletter so you can stay updated on trends, events and inspiring cases. You can withdraw your consent at any time by using the ‘Unsubscribe’ button that is included in each of these emails.
Finally, we may process your data on the basis of our legitimate interests which, in specific cases, may outweigh any potential harm to your rights. You have the right to object at any time against the processing of your data that is based on our legitimate interests. For example this may be the case when we engage you for our client customer satisfaction surveys.
When you are (our contact at) our client, we may rely on our legitimate interests to use your contact details to send you communications which we think might interest you. If you do not wish to receive such communications, you can unsubscribe by clicking the ‘Unsubscribe’ button that is included in each of these emails.
We may process your data based on your prior consent. In this case you can withdraw your consent at any time.
Furthermore, we may process your data on the basis of our legitimate interests which, in specific cases, may outweigh any potential harm to your rights. You have the right to object at any time against the processing of your data that is based on our legitimate interests.
We may process your data based on your prior consent. In this case you can withdraw your consent at any time.
In the context of an application procedure, we process your data because this is necessary for assessing whether In The Pocket wants to conclude an employment, internship or cooperation agreement with you. When we temporarily keep your data when we cannot immediately offer you a position within our company, we do so based on our legitimate interests. This allows us to inform you when new, interesting opportunities open up for you within In The Pocket.
We obtain your data directly from you, from our clients, third parties (such as a recruitment firms or data suppliers) or from public sources.
When our clients provide your data to us, they will do so because you are professionally connected to their company and we may need to contact you in the context of the provision of our products and services.
When we obtain your data from public sources, this concerns for example consulting the Crossroads Bank for Enterprises (e.g. to verify whether you can conclude a contract on behalf of your company), the website of your company, your profile on professional social networks (e.g. in the context of an application), or other publicly available information.
In The Pocket does not store your data for longer than is necessary in order to achieve the purpose for which the data has been collected or processed.
Sometimes specific legislation will require us to retain the data for a certain time period. In The Pocket will always comply with conditions for retention or storage of data imposed by specific legislation.
We mainly store your data on externally hosted IT systems. We partly outsource the storage of your data to specialised third parties. These external service providers act as “processors” on our behalf (see title 7).
We and our processors have taken the necessary physical and appropriate technical and organizational (precautionary) measures in order to secure your personal data against any form of unlawful processing.
We will not share your data with third parties (except our processors) for commercial reasons without your consent. Furthermore will can share your data with third parties if when we are required to do so by law, if this is necessary for the purposes for which the data was collected or when this is necessary for providing you with our products and services as a digital products studio.
As mentioned under title 6, we have engaged external service providers, so-called “processors”, to support our business operations. These external service providers perform certain processing activities on your data on our behalf. We will only share your data with these external service providers insofar this is necessary for the purposes for which it was collected. These “processors” cannot use your data for any other purposes. In addition, they are contractually bound to ensure the confidentiality of your data. To guarantee the aforementioned commitments, we have concluded so-called “data processing agreements” with these parties.
Your data might be processed outside the EEA. Your data will only be transferred to third parties located in countries outside of the EEA of which the European Commission has decided that they ensure an adequate level of protection of your data, or when other measures have been taken to ensure the lawful processing of your data in these third countries.
At any time you can manage your data that was collected by In The Pocket, by exercising your rights as a data subject.
You have the following rights:
Right of access and copy
You have the right to access your data and to obtain a copy of it.
Right to rectification
You have the right to obtain rectification of inaccurate data that concerns you.
Right to erasure (“right to be forgotten”)
You have the right to request that we erase your data without unreasonable delay.
Right to restriction of processing
You have the right to restrict the processing of your data. In this case the processing will be temporarily ceased until there is, for example, certainty about the correctness of the data.
Right to object
You have the right to object against the processing of your data that is based on our legitimate interests. You can exercise this right on grounds relating to your particular situation. In this case we need to cease the processing, unless we can demonstrate compelling legitimate grounds to continue processing your data.
You can, regardless of the legal basis upon which the processing is based, always object against the use of your data for direct marketing, after which we are obliged to stop processing for these purposes.
Right to data portability
You have the right to receive the data, which you provided to us, in a structured, commonly used and machine-readable format. This makes it easy for you to transfer your data to another organisation.
You also have the right to request us to directly transfer your data to another organisation.
However, the exercise of the above rights is subject to certain limitations, as provided in the GDPR and further specified in other applicable laws and regulations.
If you would like to exercise one of the rights described above, please contact us via the contact details provided under title 1 and repeated under title 9 (by mail, email or telephone).
When you submit a request to exercise your rights, we will first of all verify your identity by requesting a copy of your identity card. We do so in order to prevent your data from falling into the wrong hands. In this event we ask you to cross out the irrelevant information on your identity card, such as your citizen number and photo.
Exercising your rights is in principle free of charge. If your request appears to be manifestly unfounded or excessive (in particular because of its repetitive character), we may charge you a reasonable fee in order to cover our own administrative costs. In such cases, however, we may also simply refuse to act on your request. You will then be notified of the reasons for this refusal.
In each case, we will notify you within a period of 4 weeks (for simple requests), or 3 months (for complex or frequent requests) of the response to your request.
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 In The Pocket processes 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, we hereby repeat how we you can reach us:
In addition, you can always file a complaint with the supervisory authority, which you can contact via the contact details below:
Data Protection Authority
Drukpersstraat 35, 1000 Brussels
Tel: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
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 following web page of the Data Protection Authority: https://www.dataprotectionauthority.be/.
We reserve the right to unilaterally modify our Privacy Statement at any time. Each amended version will always be available on the Website and will apply immediately from the moment of publication. The date on which our Privacy Statement was last modified, can be found hereunder.
Last modified on: April 7, 2020