Data Privacy Statement and Information pursuant to Article 13 GDPR

We at FOCUS-ON want you to know that we care about your privacy. We want you to know exactly how we use the information you provide to us in the course of using our Website. By accessing and using our Website, you agree to be bound by the terms of this Privacy Notice and the terms of our Internet Disclaimer and Statement. If you are not willing to agree to these terms, please do not use our Website.

You are not required to provide any personal information in order to visit our Website or to obtain the information that is freely available to all visitors. However, in order to fully utilise our services – i.e., to configure products to your specifications and to order our products from our e-shop – you must register with us.

We are committed to maintaining the trust of our users. If you have any questions or concerns about the privacy or security of any information that you have provided, please do not hesitate to contact us.

1. General information on data processing

1.1 Processing of personal data and its purpose

FOCUS-ON VoF (“FOCUS-ON ” or “we” in the following) processes personal user data only as far as it is necessary for providing a functioning website, our contents and services. The following data are processed when visiting our website:

  • User’s IP address
  • Information on the web browser used (type, version, language)
  • Operating system used
  • User’s Internet service provider
  • Date and time the user accessed our website
  • Files retrieved from our website
  • Web page from where the user got to our website
  • Web page(s) that the user retrieves on our website
  • Object (image, page) to be opened
  • Protocol (http/https)
  • Return codes (access successful/not successful)
  • Referrer (which link was opened)

The IP address needs to be processed and temporarily saved to supply the web page to the user’s computer. This means that the user’s IP address must be saved for the session. The log files created contain IP addresses or other data that make it possible to identify the user. The log files are saved to ensure the proper functioning of the web pages. Additionally, we use the data to optimize our site and ensure the security of our IT systems.

Personal data are exclusively processed for the mentioned purposes and to the extent necessary for fulfilling these purposes.

1.2 Legal grounds for the processing of personal data

As a rule, personal user data are processed after users have given their consent. An exception applies in such cases where prior consent cannot be requested for factual reasons and where laws and regulations permit the processing of personal data. The storage of personal data and log files is governed by Article 6(1) lit. f) of GDPR.

1.3 Data erasure and period for which the data are saved

We delete or block the personal data of the data subjects as soon as the purpose for storage has become void. When data are processed to provide web pages, the data are erased at the end of the session. Personal data saved in log files are deleted after seven days at the latest. Any further storage is possible if the user’s IP address has been deleted or depersonalized beforehand so that the accessing client cannot be identified any longer.

2. Cookies

We use cookies on several of our web pages. Cookies can be saved on the user’s operating system when he or she opens one of our web pages. Cookies contain a specific sequence of characters that allows web browsers of returning users to be clearly identified. The following data are saved in the cookie:

  • Language settings
  • Logon information

The purpose of cookies is to make our web page design user friendly. The processing of personal data using cookies is governed by Article 6(1) lit. f) of GDPR. Cookies are saved on the user’s computer and transmitted to our web pages from there. Users can change the cookie handling settings in their web browsers to deactivate or restrict the use of cookies. Cookies that have already been saved can be deleted at any time. When cookies have been deactivated for our website, users may no longer be able to use all functions provided on our pages.

3. Web analytics

The controller has integrated the component Google Analytics (with anonymisation function) on this website.

Google Analytics is a web analytics service. Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on which website a data subject has come to a website from (so-called referrers), which sub-pages of the website were accessed or how often and for which period of time a sub-page was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, USA.

Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google might transfer the personal information collected via this technical procedure to third parties.

As IP anonymisation is activated on our website, your IP address will be shortened by Google within Member States of the European Union or other states in agreement with the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by a Google server in the USA. On behalf of the operator of the website, Google will use this information to evaluate your use of the website, compile reports on website activity and to provide further services related to website and internet use to us. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google.

In addition, this website uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymised and encrypted and will not be linked with other data.

You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible.

In addition, you may prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics.

In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs. Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/ The following link provides a further explanation of Google Analytics https://marketingplatform.google.com/about/.

Our website also uses Google Analytics performance reports relating to demographics and interests and reports on Google Display Network impressions. You can disable Google Analytics for display advertising and customize the ads on the Google Display Network by visiting the ad settings at this link: https://adssettings.google.com.

4. Google Maps

We use the Google Maps API provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”), to illustrate map information on our website. When using Google Maps, Google also processes usage data by website users who utilize the map functions. The processing of personal data is governed by Article 6(1) lit. f) of GDPR. We have a legitimate interest in presenting attractive web pages and in making the locations specified on our pages easy to find. For further information on how Google processes personal data refer to the Google privacy policy available at https://policies.google.com/privacy?hl=de.

5. Form for applicants

Job applicants can enter their personal data on our website to apply for the posted vacancies. The data are entered in a form and transmitted to FOCUS-ON, where they are saved. We only record the personal data required for the application process. Applicants must provide information on their job history so that we can fully assess their application. The following data are collected:

  • Form of address
  • First name, last name
  • Street address including ZIP code and city
  • Nationality (voluntary information)
  • Phone number and times of availability
  • E-mail address
  • Date of birth (voluntary information)
  • Information on the current job situation including period of notice, salary before tax, number of employers in the previous five years (voluntary information)
  • Desired annual salary
  • Information on job qualifications including type of degree or vocational training diploma, grade in degree/diploma, grade average, field, name of university or vocational training institute (voluntary information)
  • Job experience (voluntary information)
  • Language skills (voluntary information)
  • Application documents (cover letter, CV, certificates)

The personal data provided by the applicants are only used by FOCUS-ON for the purpose of selecting suitable job candidates. When handling applications, we restrict ourselves to the data directly entered by the applicants. This may include data they entered on online business networks or employment websites. If we ask applicants for their sex by requesting them to enter the form of address, we only do so because we want to address them properly.

If users who have applied for a posted FOCUS-ON vacancy but were not considered suitable candidates for this opening are interested, we offer to check their suitability for other FOCUS-ON vacancies. However, we will contact the applicants before forwarding the submitted personal data to other areas within FOCUS-ON so that the applicants can decide whether they want to participate in this procedure.

The processing of personal data collected through the application form is governed by Article 88(1) of GDPR. We delete the collected personal data six months after an applicant has been rejected, unless he or she has given consent to his or her personal data being added to our pool of applicants.

Underage applicants who have not reached the age of 16 must send us, by ground mail, a declaration of consent signed by their parents having custody or their custodian. In this declaration, the parents or custodian must state that they consent to the underage applicant being added to our pool of applicants.

6. Newsletter

We offer a free newsletter on our website. We process the following personal data when users subscribe to it:

  • First name, last name
  • E-mail address
  • IP address of accessing client computer
  • Date and time of subscription

During the subscription process, users are asked to give their consent to the processing of data and reference is made to this privacy policy. The data processed for sending out the newsletter are not forwarded to third parties. The data are exclusively used for sending out the newsletter. The processing of personal data after subscribing to the newsletter is governed by Article 6(1) lit. a) of GDPR. We only save the user’s e-mail address while the newsletter subscription is active. Users can unsubscribe from the newsletter at any time by clicking on the link contained in every newsletter. The personal data are deleted immediately in this case.

7. Contact forms and e-mail contact

Our website includes several contact forms so that users can get in touch with us by electronic mail. If users choose to use this form of communication, the data entered in the form are transmitted to FOCUS-ON, where they are saved. This applies to the following data:

  • Form of address
  • First name, last name
  • Department
  • Company
  • Address
  • E-mail address
  • Phone number
  • User’s IP address
  • Date and time of sending

Depending on the contact form, it may be possible to enter additional data. Also depending on the contract form, data may be transferred to our subsidiaries located in third countries. In such cases, we ensure that appropriate safeguards pursuant to Art. 46 GDPR are observed. Alternatively, users can make first contact with us at the e-mail address provided on the website. In this case, we save the user’s personal data included in the e-mail. The processing of personal data is governed by Article 6(1) lit. f) of GDPR. The data are only used to handle the first communication and the resulting communication. If we use the personal data for other purposes, we will request the user’s consent beforehand. The personal data entered in the contact form and sent by e-mail are deleted when the communication with the user has been terminated, which means when the circumstances suggest that the issue in question has been settled. The additional data collected during the sending process are deleted after seven days at the latest.

8. Security

The use of certain features of our Website require you to select a user name and password. It is important for you to protect the confidentiality of your user name and password and to protect against any unauthorized use of your computer or network. We have no technical or other means to protect you from any unauthorized use of your user name and password.

While we have taken reasonable steps to protect the security of User Information, we cannot guarantee that your User Information will remain permanently secure. There is always a possibility that your User Information could be lost due to technical problems or stolen from our databases. We are not responsible for any such loss or theft or for any other unanticipated security breaches.

9. Server log-files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • Browser type and browser version
  • Used operating system
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request

These data cannot be assigned to specific persons. A merge of this data with other data sources will not be done. We reserve the right to check this data retrospectively, if we become aware of specific indications for illegal use.

10. Data security

FOCUS-ON has implemented technical and organizational security measures to protect the users’ personal data against accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security measures are continuously improved in line with technological development.

11. Rights of the data subjects

If FOCUS-ON processes your personal data, you are a data subject as defined in Article 4(1) of GDPR and have the rights mentioned in the following towards us: If you want to exercise a right, please contact our data protection officer at info@fon-p.com. Note that we may request additional information from you under certain conditions to verify your identity. For example, we may ensure that information is not revealed to unauthorized persons when exercising the right of access.

11.1 Right of access
Pursuant to Article 15 of GDPR, you are entitled to obtain access to the personal data we process concerning you. If possible, please make your access request as precise as possible as this will make it easier for us to compile the required data.

11.2 Right to rectification
Pursuant to Article 16 of GDPR, you have the right to obtain from us the rectification of inaccurate personal data concerning yourself and/or to have incomplete personal data completed.

11.3 Right to erasure
Pursuant to Article 17 of GDPR, you have the right to obtain from us the erasure of personal data concerning yourself without undue delay. Your right to erasure depends on certain factors, including whether we still need your processed personal data to fulfill our tasks.

11.4 Right to restriction of processing
Pursuant to Article 18 of GDPR, you have the right to obtain from us restriction of processing of your personal data.

11.5 Right of information
If you have requested from us the rectification or erasure of personal data or restriction of processing, we are obliged according to Article 19 GDPR to inform each recipient to whom we have disclosed your personal data of this request, unless this proves impossible or involves disproportionate effort. You are entitled to request information about those recipients from us.

11.6 Right to data portability
Pursuant to Article 20 of GDPR, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format to have them forwarded to a different officer, if applicable.

11.7 Right to object
Pursuant to Article 21 of GDPR, you have the right, on grounds relating to your particular situation, to object to the processing of personal data concerning yourself at any time. We no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

11.8 Right to withdraw the declaration of consent on privacy and data protection
If you have made your personal data available to us based on your consent, you could withdraw from your consent at any time with effect for the future, for example by e-mailing us to info@fon-p.com. The withdrawal of consent does not affect the lawfulness of processing based on consent granted before the withdrawal.

11.9 Automated individual decision-making, including profiling
Pursuant to Article 22 of GDPR, you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

11.10 Right to lodge a complaint with a supervisory authority
If you have a concern about the lawfulness of our processing of your personal data, you have the right to lodge a complaint with a data protection supervisory authority. The supervisory authority in charge of FOCUS-ON is the Dutch Data Protection Authority.

You are also entitled to file a complaint with the Dutch Data Protection Authority. That will be possible by using the hyperlink:

https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/gebruik-uw-privacyrechten/klacht-melden-bij-de-ap

12. TLS encryption

This site uses TLS encryption for security reasons and to protect the transmission of sensitive content, such as the requests you send to us as the site operator. You can recognize an encrypted connection by changing the address line of the browser from “http: //” to “https: //” and the lock symbol in your browser line. If TLS encryption is enabled, the data you submit to us cannot be read by third parties.

13. Inclusion and validity of the privacy policy

This privacy policy applies to the contents of our web pages. Other privacy, data protection and data security policies apply to the contents accessible by external link. Check the disclaimer or general terms that apply to the external links to see who is responsible for these contents.

It may be necessary to revise this privacy policy to further develop our website or implement new features. As a result, we reserve the right to change this privacy policy at any time with effect for the future. The version as amended and accessible at the time you visited our website is valid.

Last update: February 2020

Contact person for data protection

The controller according to the EU General Data Protection Regulation (GDPR) and other protection laws and regulations is:

FOCUS-ON VoF
Prins Hendrikstraat 63
3331XR Zwijndrecht
The Netherlands

Phone: +31 78 630 6356
E-mail: info@fon-p.com
Internet: www.focus-on-process.com

The data protection officer of FOCUS-ON VoF is:

Mr. Kavreet Bhangu
Kerkeplaat 12
3313LC Dordrecht
The Netherlands
E-mail: info@fon-p.com

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