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GetFocus General Privacy Policy
Effective date: March 31, 2023
Welcome to GetFocus!
Focus B.V. (“we” “us” or “our”) operates the GetFocus Platform, a globally accessible software as a service available at odin.getfocus.eu, housing a vast database of information about technologies. Insights are made available to customers who use this information to research technologies.
1. Applicability of this Privacy Policy
This General PrivacyPolicy (the “Privacy Policy”) explains how GetFocus collects, uses, processes and shares your information where:
● You are a Registered User of the GetFocus Platform the associated products and services (the “Services”).
● We meet you at a conference, trade show, or similar event (an “Event”).
● You sign up for or participate in a webinar presented by GetFocus(either alone or in partnership with a commercial partner, each a “Webinar”).
● You call us by telephone or contact us by email or through chat for customer support, training, and success purposes (a “Support Call”).
● Any other situation or circumstance where we collect your personal information. (see more in Section 3entitled What information do we collect about you below)
This Privacy Policy does not apply to:
● Any parts of the Serviceswhich are expresslyoffered under their own, separateor different privacy policy(ies) including when you link to otherwebsites and services from the Services. Such third-party websites will havetheir own privacy notices.
● Information in respectof which GetFocusacts purely as data processorand which is governed by the privacy policy(ies) ofthe data controller in such case.
● Collection of information by GetFocus which is expresslystated to be covered under other or different privacy notices.
We reserve the right to amend or update this information from time to time or as required.
2. GDPR and CCPA Notices
If you are resident of the EEA and/or Switzerland or theGDPR applies to you, GetFocus is the data controller in respect of the processing of your personalinformation. You can find out more specific information about yourrights and how to exercise them in the GDPRPrivacy Policy Supplement at Section 8 below.
If you are a resident of the State of California, you canfind out more about how your information is processedand how to exercise your rights under the California Consumer
Privacy Act (“CCPA”) by visiting the CaliforniaPrivacy Disclosure Notice at Section14 below.
3. What information do wecollect about you?
For the purposesof this PrivacyPolicy, reference to personal information includes anyinformation relating to an identifiable person.
We collect information about you in the following ways:
Where you are a Customer employee/representative (Registered User) We license our product to our customers (”Customer(s)”) who nominate certain employees and/or representatives to access the Services on the Customer’s behalf. If you are such an individual nominated by a Customer to access theServices, the Customer may provide us with information such as your name, title, and e-mail address in order to create a credentialed log-in for our Services. You will then become a Registered User (“User”). If you are a User, we also collect certain information directly from you such as your password information in order for you to access your user account.
After receiving log-in information, you may choose to use our Service for the purposes for which the license was granted. During your time using our Service as a User, we may collect some or all of the following additional data:
● Usage data, including logins,IP addresses, and user behavior
● Information you submit to GetFocus including through ourService or directly to one of our employees or Customer Success(CS) representatives when you communicate with them through theServices.
Under your organization’s license agreement, some individuals at your organization (or nominated by your organization) may have the right to access information for all Users at your organization for purposes of tracking usage patterns across the organization. If you have questions about who at your organization can see yourdata, please contact your organization’s point of contact for GetFocus. If you do not know your company’s point of contact, we can provide you with that information.
You otherwise submit the same to us.Including for example when you subscribe to GetFocus’ newsletter (or updates),request a demo from GetFocus or you engage in an instant message “chat” or communicate with one of our representatives you may provide us with your name and email address to enable us to contact you.
Through our support services,Webinars and/or Events. We may receive personal information from or about you such as your name and contact details such as your email address when we meet you at an Event, when you sign up for or participate in a Webinar, or when you contact us for a Support Call. If we receive a question for support, we collect and store the question as well as the answer to the question. We may also collect aggregated statistics connected to support issues.
From third parties or external sources. We may receive your contact information from commercial partners with whom we partner to presentWebinars. We may also directly
collect personal information about you that is publicly available from publicly available websites.
Cookies. We collect information through the Services using “cookies” and similar technologies As a User you accept that cookies we deploy are required in order that you may use the Services in a way that the Customer and you the User expect.The cookies that we deploy will allow you to access the Services and give you feedback about how you use the services to improve the same for your benefit.
LogFiles. We may also collect information through our Internet log files, which record data such as user IP addresses, browser types, and other statistical data involving the use of theServices This information may be used to analyze trends, administer the Services, monitor the use of the Services and to gather general demographic information. We may link this information to personal information for these and other purposes such as personalizing your experience and evaluating and improving the Services in general.
From and through our affiliates. Where your information comes to us directly from or via an affiliate
4. Children’s Information
We are committed to protecting the privacy of children. The Services are not designed for or directed to children under the age of 13. We do not knowingly collect personal information from any person under the age of 13.
5. How do we use your information? (Purpose):
We use the information collected in the following ways and for the following purposes:
To provide the Services to you. including giving Users access to the GetFocus Platform and the Services through each user account.
To enhance, provide support and maintain our Services. We use your information to support the delivery of the Services, address service errors or technical issues, to contact you for customer service and forSupport Call purposes.
For analytics purposes to improve your experience to help us understand who uses the Services (and how). for internal operations such as operating and improving your user experience. We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Services.
To provide you access to particular features. such as a Webinar that you sign up for or participate in
To communicate with you. If you identify yourself to us by sending us an e-mail with questions, comments,or requests for customer service or using a chat function, we may use your personal information to respond to your questions or comments, and we may file your questions or comments for future reference.
To tell you about changes to applicable terms and policies technical or other important updates. We may also use your information to let you know about changes to this Privacy Policy or other legal terms of relevance. We may contact you through email, by notices messages and other ways through the Services (or as we see fit) to informyou about technical updates; service-related issues; important changes to, and/or availability of ourservices. We can also contact you in this way regarding your safety and security when using
the Services and send you important security notices about potential fraud or security breaches.We may also reach out to you to find out more about your user experience and to improve our products These communications are part of the Services and you may not opt out of them.
To send you alerts. If you are aUser, we use your information (including your email address) to send you alerts about updates, and new information added to the GetFocusPlatform which may be of benefit or interest to you.
To facilitate our marketingactivities. and, unless youopt out (to the extent permitted by applicable law, so that we (and whereapplicable, third parties acting on our behalf) can contact you about productsand services that may be of interest to you: In particular, unless you opt out(to the extent permitted by applicable law), we and third parties acting on ourbehalf may send you electronic newsletters, contact you about particularproducts, services, information and news that may be of interest to you, and provide you with targetedfeedback. Some of this information may be tailored to you based on yourusage of the Services.
6. How do we share your information?
We generally disclose information we gather under this Privacy Policy to the following categories of third parties and/or as other wise set forth in this PrivacyPolicy and/or as specifically authorized by you.
Where required by Law. We may disclose your information (including personal information)if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose personal information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our Users, the GetFocus Platform, theServices or the general public.
Analytics Service Providers. When you use our Services third-party providers of analytics products for example analytics cookies deployed as part of the Services may directly collect information about your activities over time
ServiceProviders. We may employ third party independent contractors, vendors and suppliers (collectively, “Service Providers”) to provide specific services and products, such as hosting and maintaining the Services, providing fraud screening, and developing applications for the Services. In the course of providing products or services to us, these third-party ServiceProviders may have access to information we collect about you. While we may seek to require Service Providers to follow appropriate privacy policies and will not authorize them to use your personal information except for the express purpose for which it is provided, we cannot control the actions of such third parties.
Toour marketing service providers.We may share your personal information with our marketing vendorsand partners to send emails on our behalf, and/or for co-branded and/or co-sponsored marketing and promotional events (such asconference events) offered in conjunction with another company or companies. Ifyou register for or participate in such marketing and promotional events, weand the relevant partner companies may receive
informationcollected in conjunction with the co-branded and/or co-sponsored marketing and promotional events.
Sale of Business. If applicable, we reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets ofGetFocus or any of its affiliates (as defined below), or that portion ofGetFocus or any of its affiliates to which the Services relate or to which any other activities of GetFocus that are subject to this Privacy Policy relate, orin connection with a strategic investment by a third party in GetFocus, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, re organization or similar proceeding.
Affiliates. We may disclose information (including personal information) about you to our affiliate companies as required.
Where you consent. To any other party should you consent to the disclosure.
7. How do we keep yourinformation secure?
GetFocus takes the security of your information seriously. We invest considerable resources in implementing technical and organizational measures to secure your information. We value your trust in providing us with your personal information and strive to use commercially acceptable means of protecting it. GetFocus takes reasonable steps to ensure that personal information is reliable for its intended use and all such information is up-to-date, accurate, and complete, and we remind you however, that no method of electronic transmission or electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
8. GDPR Privacy Policy Supplement
To the extent you are located in the European Economic Area or Switzerland this section of thePrivacy Policy sets out our practices and obligations under the General Data ProtectionRegulation 2016/679 (the “GDPR”).
DataController. If processing ofyour personal information is subject to the GDPR, GetFocus is the data controller (as defined in the GDPR)in respect of the processing of your personalinformation to which this Privacy Policy applies.
If you wish to contact the data controller to exercise your rights underthe GDPR you can do so using the contact information in Section 13 Contact us below.
Sensitive personal information. We don ot request personal information relating to your race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation or criminal record (which is defined as "SensitivePersonal Information" under the GDPR.)
Legal Grounds for processing. Pursuant to the GDPR, legal bases for our processing your personal information may include(without limitation):
● Where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal.
● Where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Services and/or access
to the GetFocusPlatform if you are a Registered User, Support Calls, or otherwise).and/or
● Where it is necessary for the purposes of our legitimate interests for example in providing or marketingthe Site and your fundamental rights and freedoms do not override those legitimate interests.
Your rights under the GDPR. Please see the section Your Privacy Rights below. If you want to contact the data controller to exercise any of your rights under the GDPR or need further information concerning the lawful basis on which we collect and use your personal information, please contact us using the information at Section 13 Contact us below.
9. Overseas transfers.
In certain circumstances, personal information collected under this Privacy Policy may be transferred from time to time to our affiliate offices, personnel, and/or to Service Providers who may be located in various places throughout the world. In addition, the GetFocus Platform may be viewed and hosted anywhere in the world, including in countries that may not have laws of general applicability regulating the use and transfer of such information or which may not provide the same degree of protection as the country in which you are resident. Without limitation of the foregoing, you hereby expressly grant consent to GetFocus to: (a) process and disclose such information in accordance with this PrivacyPolicy; (b) transfer such information throughout the world, including to theUnited States or other countries that do not ensure adequate protection for personally identifiable information (as determined by the European Commission, each, an “Inadequate Jurisdiction”) and/or countries that may not have laws of general applicability regulating the use and transfer of such information as necessary and required; and (c) disclose such information to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you are located in the EEA Switzerland or if the GDPR applies to you, should it be absolutely necessary for us to transfer your personal information to an Inadequate Jurisdiction, we will rely on legally provided mechanisms designed to ensure a similar degree of protection is afforded to your personal information including (but not limited to) where applicable implementation or use of European Commission-approvedStandard Contractual Clauses. If you require further information on the specific mechanisms used by us or have any concerns in this regard, please get in touch using the information in Section 13 Contact us below
10. How long do we retain your information?
We endeavour to retain your personal information only for as long as necessary to fulfil the purposes for which we collected it. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. If you have any questions about our data retention processes, please contact us.
11. Your privacy rights
We generally use personal information as described in this Privacy Policy as authorized by you or as otherwise disclosed at the time, we request such information from you. In certain other circumstances, you “opt in” and/or give us permission to use your personal information. You may in such a case exercise your opt out rights as for example in the case of marketing communications either by following the directions provided in association with the communication or such other directions we may provide or by contacting us.
You may have certain rights related to your personal information, subject to local applicable data protection laws in your country. Please note your rights and choices may vary depending upon your location. Certain personal information may be exempt from such requests under applicable law.
If you are a resident of the State of California please see the CCPA Privacy Notice at Section 14 below to find out about your rights and how to exercise them.
If the GDPR applies to you, you may have the following specified rights:
Request access to your personal information (commonly known as ‘subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request the erasure of your personal information. This enables you to ask us to delete or remove your personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your personal information in certain circumstances.
Object to processing of your personal information where we are relying on a legitimate interest(or that of a third party) and there is something about your particular situation that makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing the same.
Request the transfer of your personal information to an other party.
Lodge a complaint with the relevant supervisory authority (as defined in the GDPR). See details of our lead supervisory authority in Section13 “Contact us” below. If you have any complaints about the way we process your personal information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.
Please note that GetFocus’ lead supervisory authority in the EU is:
The Dutch Data Protection Authority (Autoriteit persoonsgegevens)
Postbus 93374 2509 AJ, Den Haag
Dutch Phone number: +31 881805250
Similar rights as above may be afforded to you under other globally applicable data protection laws and regardless of your location.If you wish to review, verify, correct or request the erasure of your personal information, object to the processing of same, or request that we transfer a copy of your personal information to another party you can contact us using the information at Section 13 Contact Us below.
Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with thisPrivacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps to verify your identity before granting you access or making corrections.
You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personal information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personal information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.
To protect your privacy and security, we may take reasonable stepsto verify your identitybefore granting you access, making corrections, or otherwise processing yourrequest.
12. Changes to this Privacy Policy
We reserve the right to modify or revise this PrivacyPolicy from time to time. If we make material changes that result insignificant additional uses or disclosures of your personal information, we will provide you notice through the Services and/or by other means including if necessary, communication with you, to provide you the opportunity to review the changes before they become effective. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personal information, for which such communications/notices are not generally required. We encourage you to check this page periodically for any changes; the date for the latest updated version of this Privacy Policy is specified at the top of this PrivacyPolicy. If any changes to this Privacy Policy are unacceptable to you, you should stop using the Services Your continued use of the Services following the posting of changes to this Privacy Policy constitutes your full acceptance of those changes.
13. Contact us
If you wish to exercise your privacy rights and/or if you have questions or concerns about our data use practices, or this notice, please contact us as follows:
Residents of all jurisdictions/locations may contact us as follows:
By e-mail: jardvaningen@getfocus.eu
By postal mail or courier: Attn:
Jard van Ingen Focus BV
Marconistraat 16 3029AK, Rotterdam The Netherlands