Introduction – general information
InSites Consulting 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”).
Furthermore we are a member of the European Society for Opinion and Marketing Research (“ESOMAR”), an international organisation that focuses on developing better market research methods. In addition we adhere to the professional standards which ESOMAR sets out for its members.
This Privacy Statement explains how we process personal data at InSites Consulting, consisting of: (i) InSites Compages NV, with registered office at Evergemsesteenweg 195, 9032 Ghent (Belgium) and registered with the Crossroads Bank for Enterprises under the number BE0837.297.070; and (ii) its subsidiaries and affiliates (see contact details below or click here) (jointly and each hereafter “InSites Consulting”, “InSites Group”, “our”, “us” or “we”).
Who are we?
InSites Consulting is a group of consumer insight agencies that runs online communities and panels in which we invite consumers to share their view on our clients’ businesses, products and services. We offer our clients ancillary services to these communities such as analysis on global consumer trends.
At InSites Consulting we believe 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 provide our products and services to our clients, and more in general, to conduct our business as a group of market research companies. To this end, we have developed this Privacy Statement (hereafter “Statement”).
It should be clear that this Statement only applies to the processing of Personal Data by InSites Consulting (I) acting on behalf of our clients when carrying out our Market Research Activities as a data processor; and/or (II) acting on our own behalf when carrying out our Business Activities as a data controller.
All processing of Personal Data by InSites Consulting will be treated in accordance with applicable data protection legislation and this Privacy Statement.
Why this Statement?
This Statement sets out how InSites Consulting processes Personal Data collected via:
(I) the market research products and services we offer to our clients, e.g. the collection of information through surveys, panels, communities (such as “Square”), interviews or any other form of market research tools (hereafter “Market Research Activities”);
Some examples:
- your participation in one or several of our Market Research Activities (e.g. questionnaires, panels, surveys, polls, communities or any other market research tool);
- your participation in one or several of our prize competitions; and
- all information you actively provide us with during such participations.
- when you contact us via our Websites, by e-mail, post, telephone, by exchanging business cards, by submitting a request to exercise your rights,…;
- when you engage or maintain a contractual relationship with us;
- when you apply for a job with us;
- when you subscribe to our newsletter;
- when you leave a comment on our Websites;
- when you request a download;
- Via the use of strictly necessary cookies on our Websites, or non-strictly cookies with your consent.
(II) the different websites we use, such as http://www.insites-consulting.com/, https://www.futuretalkers.com/, http://www.howcoolbrandsstayhot.com/ (jointly and each hereafter “Websites”) and all activities and services relating to conducting our business in general (e.g. administrative, technical, financial or either commercial activities and services) (hereafter “Business Activities”).
If necessary a distinction will be made between our Market Research Activities and Business Activities.
This Statement addresses our practices regarding the use of such information, the steps we take to protect it, as well as the choices and rights that you, as data subjects (“you” or “your”) have regarding the processing of your Personal Data. Data subjects involved can vary from:
(I) consumers/participants when carrying out our Market Research Activities; and/or
(II) every user of our Websites, recruitment applicants, subscribers to our newsletters, 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 any other individuals who get in touch with us when carrying out our Business Activities.
What is our position?
Unless we may otherwise communicate to you, and depending on the specific situation, we act in the capacity of controller, processor or joint controller when processing your Personal Data.
This distinction is relevant because it determines our responsibilities towards you, as a data subject and our obligations towards possible other actors involved, such as our clients. Our qualification also determines to what extent this Statement applies to the activities we carry out when processing your Personal Data, as explained hereafter.
(I) Market Research Activities
Where we carry out our Market Research Activities and we obtain Personal Data of you as a participant involved in such activities, we process your Personal Data on behalf of our clients. Our clients always act as controller of your Personal Data.
InSites Consulting processes your Personal Data in accordance with the instructions of our clients in our principal position of processor of our clients. As regard this situation, our clients conclude a contract and data processing agreement under Article 28 GDPR with InSites Consulting.
Where InSites Consulting, together with our clients, exceptionally would determine the purposes and/or the essential means of the processing of your Personal Data in the course of carrying out the requested Market Research Activities, we will, together with our clients, qualify as joint controller with regard to your Personal Data. As regard this situation, our clients conclude a contract and together with our clients we concluded a so-called joint controller arrangement under Article 26 GDPR.
(viii) Information about the processing of Personal Data according to Articles 13 and 14 GDPR is provided jointly by both controllers to data subjects through privacy policies published on their official websites, and in particular this Statement.
(II) Business Activities
Where we carry out our Business Activities and we obtain Personal Data from you as a visitor to our Websites, an applicant, a subscriber to our newsletter, a client, a supplier, a business contact or as another individual who gets in touch with us, we process your Personal Data on behalf of the InSites Group. The entity of the InSites Group to who you initially disclose your Personal Data acts as (initial) controller of your Personal Data.
However, in general most of our administrative, technical, financial, commercial and/or legal processing activities and services are performed centrally, at the level of our ultimate parent company (InSites Compages NV) via so called centralized units. As regard this situation, InSites Compages NV and its subsidiaries and affiliates act as joint controller with regard to your Personal Data and within the InSites Group an Intra-Group Agreement is concluded of which a joint controller arrangement under Article 26 GDPR is part.
(viii) Information about the processing of Personal Data according to Articles 13 and 14 GDPR is provided jointly by both controllers to data subjects as per this Statement.
Furthermore it remains possible for an entity of the InSites Group to receive services directly or indirectly from one or more of the other entities of the InSites Group (other than the ultimate parent company) via so called project services units or client services units. This is specifically the case, but not necessarily limited to, the situation where a local entity is carrying out Market Research Activities on behalf of our clients and requests the help of another local entity with regard to such Market Research Activities. As regard this situation, the entity of the InSites Group providing its services to the other entity of the InSites Group acts as (sub)processor with regard to your Personal Data and within the InSites Group an Intra-Group Agreement is concluded of which a data processing agreement under Article 28 GDPR is part.
Who to contact?
In accordance with Articles 13 and 14 GDPR this Statement provides you with information about the processing of Personal Data by InSites Consulting on behalf of our clients (when carrying out Market Research Activities) and on behalf of the InSites Group (when carrying out Business Activities).
Should you have any comments or questions about this Statement, or the processing of your Personal Data related hereto, you can contact the InSites Consulting DPO via the contact information provided below in section 8.2 or click here.
In particular, with regard to our Market Research Activities, we provide the information as per this Statement on behalf of our clients and as part of our services to our clients. However, where InSites Consulting acts as processor, we cannot be held accountable if this information would not be sufficiently providing you with the necessary information. Our clients as controller remain individually responsible to inform you about their specific use of your Personal Data. Such information will be provided to you separately in so far this would deviate from the Market Research Purposes as set out hereunder.
We will identify our clients, in their capacity of controller, at the beginning of each Market Research Activity we carry out on behalf of our clients, and we will provide you with all relevant contact details of our clients. However, in the exceptional case where identifying our client at the beginning of a specific Market Research Activity would have significant consequences on the results of such Market Research Activity we can decide to name our client at the end of such activity. In such an event, and before processing your Personal Data, we will make clear to you that our client will be named at the end of the Market Research Activity and we will provide necessary assurances that your Personal Data will be deleted if at the point our client is revealed you object, wish to withdraw your consent and/or no longer wish to participate. In any case InSites Consulting, regardless of its qualification and as part of its services to our clients, is mandated to handle or respond all your privacy related questions, request and/or complaints on behalf of our clients.
If after reading this Statement you still have any questions about how our clients use your Personal Data (including via us), you can contact the InSites Consulting DPO via the contact information provided below in section 8.2 or click here. We will in any case forward all necessary information to our clients and make sure your questions, requests and/or complaints are handled and responded correctly.
Processing of Personal Data
A) Market Research Activities:
The Personal Data collected and processed by InSites Consulting is generally received from you voluntarily and directly. In relation to the Market Research Activities we carry out on behalf of our clients it is possible that we receive your Personal Data from other sources, such as our client’s database, list brokers, our panel website or via advertising.
Personal Data | Legal Grounds + Purpose | Retention Period |
Electronic identification data: Eg: IP address, user ID, unique identifier assigned to your device, geographic location, information derived from content of a web page. |
Legal grounds: explicit consent. Purpose: invitation, registration and participation in our activities (eg. Specific market, social and satisfaction research). Verification of your use of confidential material submitted by us. Operational purposes (managing our websites, systems and application). |
The term of the agreement with our client or until withdrawal of your consent afterwards the data will be held for maximum 2 years. |
Contact information: Eg. Name, e-mail address, phone number or any other relevant contact details. |
Legal grounds: explicit consent and legitimate interests. Purpose: invitation, registration and participation in our activities (eg. Specific market, social and satisfaction research). To inform and contact you. Direct marketing, advertising and raising brand awareness. |
The term of the agreement with our client or until withdrawal of your consent afterwards the data will be held for maximum 2 years. |
Personal identification details: Eg. Age, date of birth, place of birth, gender, civil status, nationality. |
Legal grounds: explicit consent. Purpose: for research and statistical goals, draw up collective profiles, profiling. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 2 years. |
Contact history. Eg. Sent and received communication. |
Legal grounds: explicit consent. Purpose: contact and inform you. Direct marketing, advertising and raising brand awareness. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 2 years. |
Educational and professional background information. Eg. CV, education, degree, certificates, professional skills and activities, |
Legal grounds: explicit consent. Purpose: for research and statistical goals, draw up collective profiles, profiling. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 2 years. |
Lifestyle, interest and preferences. Eg. Social activities, hobbies, personality, community involvement, habits. |
Legal grounds: explicit consent. Purpose: for research and statistical goals, draw up collective profiles, profiling, processing your answers to surveys and provide results to the client. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 2 years. |
Public information. Eg. Publicly available information, information on social networks. |
Legal grounds: legitimate interest. Purpose: for research and statistical goals, draw up collective profiles, profiling, processing your answers to surveys and provide results to the client. |
18 months as of any objection has been filled. |
Financial details. Eg. Bank details, (branch identifiers, sort code, IBAN, BIC, account number. |
Legal ground: explicit consent. Purpose: to send you your price money. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 7 years. |
Photos, images or sound recording. Eg. When participating in video recordings, by posting material in the community or uploading of photos. |
Legal ground: explicit consent. Purpose: for research and statistical goals, processing your answers to surveys and provide results to the client. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 2 years. |
Special categories of Personal Data: Eg. Information on race and origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sexual life or sexual orientation. |
Legal ground: explicit consent. Purpose: for research and statistical goals, draw up collective profiles, profiling, processing your answers to surveys and provide results to the client. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 2 years. |
Unique ID’s: Eg. Information that we collect in questionnaires or panels, participants unique identification number. |
Legal ground: explicit consent. Purpose: for research and statistical goals. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 2 years. |
Children’s Personal Data: Eg. We allow children under the age of 16 – or lower age depending on the applicable legislation. |
Legal ground: explicit consent of the child and explicit consent of an individual with parental responsibility for the child. Purpose: for research and statistical goals, draw up collective profiles, profiling, processing your answers to surveys and provide results to the client. |
The term of the agreement with our client or until withdrawal of your consent and afterwards the data will be held for maximum 2 years. |