Declaration of the privacy protection policy of the www.jitm.be Web site

1. Identification of the Web site and of the responsible organisation

Modern information and communication technologies play a fundamental part in the activities of an organisation such as JUST IN TIME MANAGEMENT GROUP.
Our main activities on the www.jitm.be Web site (hereafter called the Web site) are the marketing and provision of advisory services to business enterprises (hereafter called the Services).

Within this framework, JUST IN TIME MANAGEMENT GROUP undertakes to comply scrupulously with Belgian legislation on personal data protection. Full details of that legislation are available on the Web site of the Privacy Commission: www.privacycommission.be

Our privacy policy applies to JUST IN TIME MANAGEMENT GROUP and to the Web site. The organisation responsible for processing the data is:
JUST IN TIME MANAGEMENT GROUP
Avenue Louise 149/24, 1050 Brussels - Telephone: 00 32 2 29053 07

2. Anonymous access authorisation and agreement to our privacy policy

You may access our home page and consult the Web site without giving us any of your personal data.

By using the Web site, you explicitly declare that you agree to the JUST IN TIME MANAGEMENT GROUP policy regarding respect of privacy and you consent to our gathering and processing data about you according to the terms, conditions and principles described in this policy.

3. Identification of the Web site users

The Web site is visited and used by different categories of people, who may have different reasons for processing the data:

• Visitor: anyone consulting the Web site on an occasional basis, who is not registered on the system and who has access to the contents of the site;
• Customer: anyone who has registered, among other things, to receive information about the services of JUST IN TIME MANAGEMENT GROUP;
• Newsletter subscriber: anyone who has registered on the Web site, among other things, to receive the newsletter provided on the Web site;
• Potential partner: person who has expressed an interest in becoming a partner either by completing the details included on the Web site or by any other means.

4. Automatic collection of information

As is the case of a visit to any Internet Web site, the following information is collected automatically:

• IP address
• DNS address
• Browser
• Screen resolution
• Page before reaching the Website

We collect these data purely for the purposes of gathering statistics on use of the Web site. We do not link the data to any personal data collected from other sources.

5. Cookies

When you visit the Web site, a "cookie" may be stored on your hard disc (small file sent by an Internet server, which is stored on your computer hard disc, keeps track of the visited Web site and contains a certain amount of information about that visit which can be accessed only via that Web site). Please note that you can refuse these cookies by programming your Internet browser either to inform you of the existence of cookies or to always refuse them. This cookie makes it easier to surf on our Web site. JUST IN TIME MANAGEMENT GROUP does not make any connection between information that might be automatically recorded by cookies and personal data regarding visitors to our site.

6. Collected data and specification of purposes

We collect your personal data only if you give them to us voluntarily. We may also collect information about you from other sources (public bodies or private organisations which process personal data and have the right to pass them on to third parties).

The data that we collect when you register on the Web site are only those which are necessary to process your data according to the purpose for which you have entrusted them to us. You are not asked for any sensitive data, nor will such data be collected by means of other databases. You will be asked to complete a form on which some fields in bold or perhaps followed by an asterisk (*) are necessary to enable us to provide the requested service and on which others are optional. The latter are intended only to enable us to contact you quickly if it should prove necessary or to identify your interests as accurately as possible so that we can send you the relevant information.  

If you give us your postal address, this means that you agree to receive correspondence from us or from our partners. If you no longer wish to receive such correspondence, please contact us at the address given in point 1 above. If you give us your telephone number, this means that you agree to receive a telephone call from us or from our partners. If you no longer wish to receive such telephone calls, please contact us at the address given in point 1 above.
If you give us your e-mail address, this means that you agree to receive e-mails from us or from our partners. If you no longer wish to receive such e-mails, please contact us at the address given in point 1 above.

7. Purposes of data processing for all categories of users

We collect your data for the following purposes, either according to a simple visit to the Web site or to the form that you complete in order to receive a service provided by the site. The collected data will be only those that are strictly necessary for the processing purposes for which you will have given your express permission.

• Visitor:
  • Managing statistics on Web site use based on the automatically collected data;
  • Carrying out market research;
  • Managing a request for information;
• Customer:
  • Managing statistics on Web site use;
  • Managing statistics on customer visits;
  • Managing the customer file;
  • Carrying out market research;
  • Managing a request for information;
• Potential partner
  • Managing statistics on Web site use;
  • Managing the file of potential partners;
  • Managing a request for information.
• Newsletter subscriber:
  • Managing statistics on Web site use;
  • Managing the subscriber file;
  • Carrying out market research;
  • Managing a request for information;
  • Sending promotional information relevant to your interests from both JUST IN TIME MANAGEMENT GROUP and from its business partners. To this end, you will have the right to opt, at any time, not to receive any message containing direct marketing in the future, at no cost and without having to give a reason:
    • either by contacting the contact person mentioned in point 1 above;
    • or by replying directly to our partner if you no longer wish to receive commercial offers from that partner.

Should we wish to use your personal data for any new purpose, we will request your consent to do so prior to using it for that new purpose. This privacy policy shall not restrict the rights that JUST IN TIME MANAGEMENT GROUP may have in respect to any natural person under the terms of contracts or pursuant to other legislation.  

8. Disclosure of data to third parties

We do not disclose your personal data to any third parties. You will have the right to opt, at any time, not to receive direct marketing from us. We reserve the right to pass on personal data at the request of a judicial or administrative authority pursuant to the law.  

9. Period during which data is kept

The collected data are kept for an indefinite period until you wish to unsubscribe from the services for which you have subscribed. Your data will no longer be processed within the framework of these services as soon as you so request by contacting us at the address given in point 1 above.
Beyond that period, they will be kept exclusively for statistical purposes or within the framework of legal obligations such as accounting and will not give rise to any use of any kind whatsoever.

10. Confidentiality and security

We do not give visitors to our Web site the option of using a securitised method of transmission for sending personal data to us. Our Web site and our company adhere to a policy, rules and security measures aimed at protecting personal data.

JUST IN TIME MANAGEMENT GROUP:

• will ensure all due diligence in keeping the data up to date and correcting or deleting inaccurate, incomplete or irrelevant data;
• will ensure that, for the persons acting under its authority, access to the data and processing options are limited to what those persons need in order to carry out their work or to what is necessary for the requirements of the service;
• will inform the persons acting under its authority of the provisions of Belgian law and of its executory decrees, and of any relevant regulations relating to the protection of privacy in regard to processing data of a personal nature;
• will ensure that the programs used for the automated processing of data of a personal nature comply with the terms of the declaration to the Privacy Commission and will also ensure that they are applied in accordance with the law;
• will ensure that anyone acting under the authority of the organisation responsible for processing the data or under the authority of a subcontractor, and the subcontractor itself, which has access to data of a personal nature, can process that data only on the instructions of the organisation responsible for processing, except in the case of an obligation laid down by or pursuant to a law, decree or ruling;
• will take and will oblige its subcontractors and partners to take any technical and organisational measures required to protect data of a personal nature from accidental or unauthorised destruction, accidental loss and from amendment, access and any other unauthorised processing of data of a personal nature. These measures will provide an appropriate level of protection, taking into account, on the one hand, the latest technological developments in this field and the costs incurred by implementing these measures and, on the other hand, the nature of the data to be protected and the potential risks.

When the processing is entrusted to a subcontractor, JUST IN TIME MANAGEMENT GROUP:

• will choose a subcontractor which provides sufficient guarantees with regard to the technical security and organisational measures relating to the data-processing;
• will ensure that these measures are carried out among other things by stipulating contractual conditions;
• will lay down in the contract the subcontractor’s liability in respect to the organisation responsible for processing;
• will agree with the subcontractor that the latter shall act only on the sole instructions of the organisation responsible for processing and shall be bound by the same obligations as those by which the organisation responsible for processing is bound according to the law;
• will record in writing or on an electronic medium the details of the contract relating to data protection and the requirements relating to security measures;

11. Access to your personal data processed by JUST IN TIME MANAGEMENT GROUP

You may, by sending a letter to the aforementioned contact person, ask us if we hold personal information about you. We will ask you for proof of your identity (copy of your identity card or passport) so that we can be certain of safeguarding your personal data and not sending them to third parties. We will accept one demand a year per person. The information that we hold on you, or a notification stating that we do not hold any information on you, will be sent to you at no cost within two months of your request. You have the option of disputing any data that we hold on you and of having them deleted, corrected, amended or completed.

Any newsletters, e-mails, mailings and letters that you receive will always mention the option to choose not to receive any messages in the future and to amend your personal data if necessary.  

12. Contact points for protection of privacy

For any question or problem regarding our privacy protection policy, please contact the contact person whose details are given in point 1 above.
If you are not satisfied with our reply, you may contact the Privacy Commission. You can find all its details on its Web site www.privacycommission.be. JUST IN TIME MANAGEMENT GROUP has submitted the necessary declarations to this Commission.