Privacy

Privacy Policy

Data protection is a particularly high priority for the Bright Focus BV management. The use of the Internet pages of the Bright Focus BV is possible without any indication of personal data; however, if a data subject wants to use special enterprise services through our website, processing or personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection. regulations applicable to the Bright Focus BV. By means of this data protection declaration, we will collect, use and process the enterprise, the nature, scope, and purpose of the personal data. Furthermore, data subjects are informed, by means of this data protection declaration, or the rights to which they are entitled.

Bright Focus BV has implemented the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, eg by telephone.

1. Definitions

The data protection declaration of Bright Focus BV is based on the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

• a) Personal data

  Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier. genetic, mental, economic, cultural or social identity or that natural person.

• b) Data subject

  Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

• c) Processing

  Processing is any operation or set of operations that is performed on personal data or on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• d) Restriction of processing

  Restriction of processing is the marking of personal data with the aim of limiting their processing in the future.

• e) Profiling

  Profiling means any form of personal processing, in particular to analyze or predict aspects concerning natural person’s performance at work, economic situation, health, personal preferences , interests, reliability, behavior, location or movements.

• f) Pseudonymisation

  Pseudonymisation is the processing of personal data in a specific way. that the personal data are not attributed to an identified or identifiable natural person.

• g) Controller or controller responsible for the processing

  Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, provides for the processing of personal data; the state of law, the controller or the specific criteria for its nomination may be provided by Union or Member State law.

• h) Processor

  Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

• i) Recipient

  Recipient is a natural or legal person, public authority, agency or other body, to which the personal data are disclosed, or a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State; the processing of these data in accordance with the applicable data protection rules in accordance with the purposes of the processing.

• j) Third party

  Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

• k) Consent

  Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes, by a clear affirmative action, or by a clear affirmative action. .

2. Name and Address of the controller

General Data Protection Regulation (GDPR), other data protection laws applicable in Member States of the European Union and other provisions related to data protection:

Bright Focus BV

Oosteinde 30

1151 BW Broek in waterland

the Netherlands

Phone: +31 20 737 0607

Email: [email protected]

Website: www.brightfocusconsult.com

3. Collection of general data and information

The website of the Bright Focus B.V. collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Bright Focus B.V. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Bright Focus B.V. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

4. Registration on our website

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

5. Contact possibility via the website

The website of the Bright Focus B.V. contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

6. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

7. Rights of the data subject

• a) Right of confirmation

  Each data subject has been granted by the European legislator. If any data subject, please contact him or her at any time, contact any employee of the controller.

• b) Right of access

  Each data subject is provided by the European legislator. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request rectification or erasure or personal data, or restriction of processing or personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

  Furthermore, the data subject will be transferred to the international organization. Where this is the case, the data subject is to be informed of the relevant safeguards relating to the transfer.

  If any data subject, please contact any employee of the controller.

• c) Right to rectification

  Each data subject has been granted by the European legislator without any delay in the correction of personal data concerning him or her. Taking into account the personal data, including by means of providing a supplementary statement.

  If any data subject to rectification, right at any time, contact any employee of the controller.

• d) Right to erasure

  Each data subject has been granted by the European legislator, with the personal data concerning him or her, without any undue delay. applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject shall be based on the data subject (s) or Article 6 (1) of the GDPR, or point (a) or Article 9 (2) of the GDPR, and where there is no other legal ground. for the processing.
  • The data subject for the processing subject to Article 21 (1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects.
  • The personal data has been processed unlawfully.
  • The personal data must be established for compliance with a legal obligation in Union or Member.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8 (1) of the GDPR.

  If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Bright Focus B.V., he or she may, at any time, contact any employee of the controller. An employee of Bright Focus B.V. shall promptly ensure that the erasure request is complied with immediately.

  Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Bright Focus B.V. will arrange the necessary measures in individual cases.

• e) Right of restriction of processing

  Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

  If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Bright Focus B.V., he or she may at any time contact any employee of the controller. The employee of the Bright Focus B.V. will arrange the restriction of the processing.

• f) Right to data portability

  Each data subject is provided by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she will have the right to transmit the data and have access to a data controller on a personal basis. the GDPR or point (a) or Article 9 (2) of the GDPR, or on a contract to a point (b) of Article 6 (1) of the GDPR; the processing is not necessary for the performance of a task carried out in the public interest or vested in the controller.

  Furthermore, in exercising the GDPR, the data subject is no longer necessary. adversely affect the rights and freedoms of others.

  In order to assert the right to data portability, the data subject may at any time contact any employee of the Bright Focus BV.

• g) Right to object

  All data subject is assigned by the European legislator to object, on grounds of his or her particular situation, at any time, to processing or personal data concerning him or her, which is based on point (e) or ) or Article 6 (1) of the GDPR. This also applies to profiling based on these provisions.

  The Bright Focus BV is no longer the personal data in the event of the objection, unless we can demonstrate the legitimate grounds for the processing of the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense. legal claims.

  If the Bright Focus BV processes personal data for direct marketing purposes, the data subject shall be the object of processing for personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to direct marketing. If the data subject objects the Bright Focus BV to the processing for direct marketing purposes, the Bright Focus BV will no longer process the personal data for these purposes.

  In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing or personal data concerning him or her. 89 (1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

  In order to exercise the right object, the data subject may contact any employee of Bright Focus BV. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58 / EC, to use the right to object by automated means using technical specifications.

• h) Automated individual decision-making, including profiling

  All data subject is not covered by the European legislator. (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member. the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

  If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the Bright Focus B.V. shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

  If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Bright Focus B.V..

• i) Right to withdraw data protection consent

  Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

  If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Bright Focus B.V..

8. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

9. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6 (1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

10. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the same statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

11. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (eg tax regulations) or can also result from contractual provisions (eg information on the contractual partner).

Sometimes it is necessary to conclude that the data subject provides us with personal data, which must be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.

Before personal data is provided by the data subject, the data subject must be contact any employee. The employee is obliged to the data subject if the provision of the personal data is required by law or contract or is not required for the conclusion of the contract. data.

12. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.