Privacy Policy

1.1. The terms "we", "us" and "our" refer to RITA CUNHA PAVÃO, located avenue Edouard Lacomblé 8, 1040 Etterbeek, VAT number BE 0479.233.349 (JobYourself Coop). We are responsible for processing the personal data collected in accordance with the terms of this Privacy Policy.   

1.2 Our website, www.focusally.com, is owned by us and powered by Infomaniak. Our website is hosted by LP-PCL (Rue du Chien Marin 19, 1000 Brussels).    

1.3. Your privacy is one of our priorities, which is why we have created this Privacy Policy which sets out your rights and how we collect, disclose, transfer and use the personal data you share with us. Please take a moment to read this policy.   

1.4. If you have any questions, concerns or complaints about this Privacy Policy or our handling of your personal data, or if you wish to send us a request to exercise your rights as defined in Section 4, you may contact us: - (a) By post, using the above address for the attention of our Privacy Officer ; - (b) By sending an e-mail to our e-mail address dedicated to privacy issues: contact@focusally.com, for the attention of our Privacy Officer.   

1.5. This Privacy Policy was last revised on 1/12/2021.   

2. HOW WE USE AND COLLECT YOUR PERSONAL DATA   

2.1. Personal data means any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.) that can be used to identify you directly or indirectly (as a natural person).   

2.2. The personal data we collect is used for the purposes indicated below: - (a) If you are currently, or have been in the past, one of our customers or suppliers. In this case, we will use your personal data to communicate with you regarding the status of our services or your services (respectively). We may also use your personal data for the purposes indicated in section (b) or (c). - (b) If you are interested in our services. This is why we use your personal data for direct marketing purposes to send you communications and newsletters about our services and company, as well as upcoming events. - (c) If you are interested in working for or with us. This is why we use your personal data for direct marketing purposes or to discuss potential opportunities with you or to make requests for quotations. - (d) You can use the contact form on our website to ask us a specific question about our services, our website or any opportunities to work with us. You can also use our website to subscribe to our newsletter. In this case, we will use your personal data to respond to your request and possibly for the purposes described in section (b) or (c). - (e) We collect and process your personal data in order to support our website and improve your user experience, in particular with regard to the security, availability, performance, capacity and health of the site. - (f) We may use your personal data to assert or exercise any rights we may have under applicable law, such as using the data to establish, exercise or defend legal claims. We may also use your personal data to fulfil our obligations as set out in the applicable law.   

2.3. You may choose at any time to opt-out of communications as set out in section 2.2(b) or 2.2(c) (for direct marketing) by following the procedure set out in our communications.   

2.4. The following categories of personal data are distinguished: - (a) Contact data (provided by you directly): You may send us your personal data directly when (i) you request information from us (other than through our contact form) to investigate the possibility of using our services , (ii) to hire us for our services, (iii) we request your information in the event of hiring your services or (iv) when we hire you for your services. In this case, the personal data we receive and process are the following: your name, telephone number, e-mail address, postal address and other personal data we have requested from you. This personal data will be processed for the purposes described in sections 2.2(a), 2.2(b) and/or 2.2(c). The processing of such personal data is necessary for us to fulfil our obligations in relation to a potential or actual employment relationship and/or contract. - (b) Contact data (provided by a third party): We may receive your personal data(i) through a third party with whom we have contracted to receive your personal data or (ii) through Google statistics/reports. In this case, the personal data we receive and process is as follows: your name, telephone number, e-mail address, postal address and other personal data we have requested from you. This personal data will be processed for the purposes described in sections 2.2(b) and/or 2.2(c). Prior to any use (other than storage) of your personal data received by us from a third party, we will provide you with this Privacy Policy as soon as possible and ask for your permission to use your personal data. - (c) Information data: If you use (i) the contact form on our website to contact us for information about our company and our services or (ii) if you subscribe to our newsletter, we will collect the following personal data: (i) your name, telephone number, e-mail address and any personal data entered in the message area (please do not include bank account or credit card details, or any sensitive data such as health data) or (ii) your e-mail address. This is personal data that you have provided directly to us and which will be used for the purposes described in sections 2.2(b), 2.2(c) and/or 2.2(d). Your consent constitutes the legal basis for the processing of this personal data. - (d) Business cards: If you give us your business card at an event or meeting, we may process your following personal information: your name, telephone number, e-mail address, postal address and any other personal information on your business card. In this case, your personal data will be processed for the purposes described in sections 2.2(b) and/or 2.2(c). The legal basis for such processing is our legitimate interest, namely to strengthen your interest in us and our business relationship by keeping you up to date with relevant information about our services and our company. - (e) Usage data: We may collect personal data about your activities on our website: IP address, device ID and type, referral origin, language configurations, browser type, operating system, geographical location, duration of visit, pages viewed or information about the duration, frequency and pattern of use of the service. This information may be aggregated and used to help us provide more useful information about the use of our website. If usage data is completely anonymous (and therefore cannot be associated with you as an individual), it will not be considered personal data for the purposes of this Privacy Policy. Instead, it is personal data that we may record when you use your device and which will be used for the purposes set out in section 2.2(e). The legal basis for collecting this type of personal data is our legitimate interest in monitoring and improving our website, keeping in mind your preferred configurations in order to improve your user experience. If a cookie is used to collect such personal data, we will ask you to authorize us to use the cookie in question.   

2.5. We may also use your personal data for the purposes set out in section 2.2(f), which may be necessary for compliance with a legal obligation or our legitimate interest.   

2.6. If the legal basis for processing your personal data is your consent, you will have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out prior to the withdrawal of consent. In the event that the legal basis for the processing of your personal data is our legitimate interest, you will have the right to object to such processing, as defined in section 4.12 of this Privacy Policy.   

3. RETENTION AND DELETION OF YOUR DATA   

3.1. Your personal information will not be kept longer than is necessary for a specific purpose. However, as it is not possible for us to specify a duration in advance, the retention period will be determined as follows: - (a) Personal data used by us in connection with the performance of your services or those you provide to us in accordance with section 2.2(a), will be stored, retained and used for as long as necessary to provide the services, and will be stored and used for direct marketing purposes. - (b) Personal data used by us for direct marketing purposes as defined in article 2.2(b) or 2.2(c) will be stored, retained and used for as long as we deem that you can benefit from our communications. - (c) Personal data provided via the contact form will be retained, stored and used for as long as is necessary to respond to your request, and will be stored and used for direct marketing purposes. - (d) Usage data will be stored and retained for as long as it is required to support the website.   

3.2. In the event that you withdraw your consent or object to our use of your personal data, and such objection is accepted, we will delete your personal data from our databases. N. B.: We will retain personal data used to ensure that your preferences are respected in the future, solely to ensure that you do not receive any further communications from us.   

3.3 This will not, however, prevent us from retaining any information or content for legal purposes such as, but not limited to, exercising or defending a legal right, for evidential purposes, for safekeeping, accounting and compliance with other legal rights and obligations we have.   

4. YOUR RIGHTS   

4.1. This section sets out your main rights under the Data Protection Act. We have tried to summarize them in a clear and readable way.   

4.2. To exercise any of your rights, please send us a written request as set out in section 1 of this Privacy Policy. We will respond to your request as soon as possible but no later than one month after receipt of the request. If the response time is extended or if we do not respond to your request, we will inform you.   Right of access   

4.3. You have the right to confirm whether or not we may process your personal data and, if you consent, you have the right to access this personal data as well as certain additional information also set out in this Privacy Policy.   

4.4. You have the right to ask us for a copy of the personal data we hold about you, provided this does not infringe the rights and freedoms of third parties. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.   The right to rectification   

4.5. If the personal data we hold about you is inaccurate or incomplete, you have the right to request that it be rectified or completed (taking into account the reasons for processing the data).   The right to erasure (the right to be forgotten)   

4.6. In certain circumstances, you have the right to have your personal data erased as soon as possible. This is the case in particular when: - (a) Personal data is no longer required for the purposes for which it was collected or processed; - (b) You withdraw your consent and there are no other legitimate grounds; - (c) Processing is for direct marketing purposes; - (d) Personal data has been processed unlawfully; or, - (e) erasure is necessary to ensure compliance with European or Belgian legislation.   

4.7. There are certain exclusions to the right to erasure. These exclusions include situations where processing is necessary - (a) to exercise the right to freedom of expression and information; - (b) to ensure compliance with a legal obligation; or, - (c) to establish, exercise or defend legal claims.   The right to restrict processing;   

4.8 You have the right to restrict the processing of your personal data (which means that we can only store personal data and use it for specific purposes) if: - (a) You dispute the accuracy of certain personal data (and only for as long as is necessary to verify its accuracy); - (b) The processing is unlawful and you request its restriction (as opposed to exercising the right to erasure); - (c) We no longer need the personal data for processing purposes, but you request the personal data for the establishment, exercise or defense of legal claims; - (d) You have objected to the processing of your personal data and are awaiting verification of your objection.   

4.9. In addition to our right to store your personal data, we may also process it in another way, but only: - (a) if we have obtained your consent; - (b) to establish, exercise or defend legal claims; - (c) to protect the rights of another natural or legal person; - (d) for reasons of important public interest.   

4.10. We will inform you before lifting the processing restriction.   The right to data portability   

4.11. Insofar as the legal basis for the processing of your personal data is consent and such processing is carried out automatically, you have the right to request your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply if it infringes the rights and freedoms of third parties.   

4.12. You also have the right to have your personal data transferred directly to another company (if technically possible) and/or to store your personal data on a private device for other personal use. The right to object to the processing of personal data   

4.13. You have the right to object to the processing of your personal data for reasons related to your situation, but only to the extent that the legal basis for the processing is that the processing is necessary: - (a) For the performance of a task carried out in the public interest or in the exercise of any public authority vested in us; - (b) For the purposes of a legitimate interest pursued by us or a third party.   

4.14. If you make such an objection, we will stop processing your personal data, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves the establishment, exercise or defense of legal claims.   

4.15. You have the right to object to the processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will stop processing your personal data for this purpose.   The right to lodge a complaint with a supervisory authority   

4.16. If you consider that the processing of your personal data violates data protection laws, you have the legal right to lodge a complaint with a supervisory authority responsible for data protection. You can do this in the EU member state where you usually reside, at your place of work or where the alleged infringement took place. In Belgium, you can file a complaint with the Commission for the Protection of Privacy, Drukpersstraat 35, 1000 Brussels (commission@privacycommission.be), https://www.privacycommission.be/fr/contact.

5. PROVISION OF YOUR PERSONAL DATA TO THIRD PARTIES

5.1. In order to provide you with our services and to be able to maintain a database with your contact information, we use an intermediary service provider to process and store your personal information. We use the following intermediary service providers: (a) WeTransfer (WeTransfer B.V., Willem Fenengastraat 19, 1096 BL Amsterdam, the Netherlands) (b) Web site host: O2Switch (o2switch SARL Chemin des Pardiaux 63000 Clermont-Ferrand)

5.2. If you are one of our customers, we may provide your personal information to service providers who have a contract with us or with whom we intend to enter into a contract in order to provide our services to you. If you are one of our service providers, we may provide your personal data to our customers in order to propose you as a service provider or during the delivery of services.

5.3. We may also disclose your personal data if such disclosure is required or necessary to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests.   

5.4. To this end, we do not disclose your personal data to our social media partners. However, we do use social media plugins to direct you to our social media channels and allow you to interact with our content. These social media channels are: Facebook, Instagram, LinkedIn, Vimeo and Google. When you share an article via LinkedIn or Google+, such as an article using the Facebook "Like" plugin, view a video embedded in our website via Vimeo or click on a link to our profile on a social media channel, the social media service provider in question may collect personal data about you and link this information to your existing profile on these social media. In this case, the social media service provider will act as controller.   

5.5. We are not responsible for the use of your personal data by this type of social media service provider. Please take a moment to familiarize yourself with the privacy practices of the above companies. For information purposes only, we have included the relevant links (which may be modified from time to time by the service provider concerned):   - (a) Facebook: http://facebook.com/about/privacy; - (b) Instagram: https://help.instagram.com/155833707900388; - (c) LinkedIn: http://linkedin.com/legal/privacy-policy; - (d) Google+: https://www.google.com/intl/en/policies/privacy/; - (e) Vimeo: https://vimeo.com/privacy.   

6. INTERNATIONAL TRANSFERS   

6.1. We will ensure that any transfer of personal data to countries outside the European Economic Area complies with appropriate protection measures. As we use Google Services, it is possible that your personal data may be transferred outside the European Economic Area.   

6.2. At the time of publication of this Privacy Policy, Google has obtained Data Protection Shield certification. If the data protection shield is invalidated for any reason or if Google no longer complies with its data protection shield obligations, we will ensure that other protections, such as the standard contractual clauses provided by the European Commission, are in place to protect your personal data.   

6.3. You hereby authorize us to transfer your personal data outside the European Economic Area.   

7. COOKIES   

7.1. Our website uses "cookies". To learn more about our use of cookies, please see our Cookie Policy.   

8. CHANGES TO PRIVACY POLICY   

8.1. We reserve the right to make changes to this Privacy Policy. As any changes will affect you directly, we will resubmit the amended Privacy Policy to you and, if necessary, seek your consent.