Privacy Policy

FOKUS is committed to the protection of personal data and privacy rights.

This FOKUS Privacy Policy consists of the FOKUS Personal Data Protection Basic Policy and the Policy for the Handling of Personal Data on FOKUS Websites. It describes how FOKUS processes personal data in compliance with applicable data protection and other laws and globally accepted data protection principles including the national data protection laws and the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, “GDPR”).

This Privacy Policy applies to all activities where FOKUS processes personal data of individuals excluding FOKUS’s personnel, which is governed by internal regulations. Data are personal, if the information contained therein relates to an identified individual or an individual that can be identified, directly or indirectly, by reference to an identifier or a combination of identifiers. Processing means any operation or set of operations on personal data whether or not by automated means and regardless whether electronically, physically in paper or any other form.

This Privacy Policy supplements the applicable data protection and other laws without replacing them. In case of a conflict or where an applicable law has stricter or additional requirements the law will take precedence over this Privacy Policy.

By accessing, browsing, or using FOKUS’s website, you agree to the Terms of Use of the FOKUS Website, this FOKUS Privacy Policy and the FOKUS Cookie Policy that supplements this Privacy Policy in respect of the use of Cookies on the FOKUS Website.

FOKUS Personal Data Protection Basic Policy

1. Scope of Application

This FOKUS Personal Data Protection Basic Policy is part of FOKUS’s Privacy Policy and describes the general rules how FOKUS processes personal data.

2. Personal Data Processing Principles

FOKUS processes personal data in accordance with the following principles:

(1) Lawfulness, Fairness and Transparency

Personal data are processed on basis of the applicable legal permission and in compliance with applicable laws (lawfulness), in consideration of the interests of the affected individual (fairness) and together with reasonable provision of information including the identity of the legal person that controls and is accountable for the processing of personal data (data controller), the purpose of the processing, associated risks, and necessary safeguards (transparency).

(2) Purpose Limitation

Personal data are processed for a specified, explicit and legitimate purpose and are no further processed in a manner that is incompatible with that purpose.

(3) Data Minimization

Personal data are adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed.

(4) Accuracy

Personal data are kept accurate and, where necessary, up to date; every reasonable step is taken to ensure that personal data that are inaccurate in respect to the purpose for which they are processed, are erased or rectified without delay.

(5) Storage Limitation

Personal data are kept in a form which permits identification of the affected individual for no longer than necessary for the purpose for which the personal data are processed.

(6) Integrity and Confidentiality

Personal data are processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. Personal data protection is taken into account when new processes are planned and implemented. Technical and organizational measures at FOKUS are continuously adjusted.

3. Business Partner Data

In course of its business operations, FOKUS processes data of its customers, suppliers, agents, providers, sub-contractors, consultants, advisors, journalists, users that access, browse or otherwise use FOKUS’s website or third party websites on which FOKUS has posted advertisements and other current and potential business partners (“Business Partners”). These data may also include personal data of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners.

3.1 Data Categories

Data processed include first, middle and last name, academic title, professional status, position, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the business relationship with FOKUS.

3.2 Data Sources

Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, e-mails, facsimiles, letters, surveys, data collected via active entries on FOKUS’s website and other electronic or non-electronic communication and interaction between FOKUS and an individual in course of a potential or existing business relationship. Indirect sources include publicly available data collected by FOKUS, data of users that access, browse or otherwise use FOKUS’s website or third party websites on which FOKUS has posted advertisements and data received from third parties in compliance with applicable laws.

3.3 Processing Purposes

Personal data are processed for FOKUS’s business operations, including Business Partner relationship management, research and development, manufacturing, enterprise resource planning, data analysis for supply, online and offline marketing and sales activities, market observance and orientation, provision of product and service information, making and answering requests and inquiries, making and accepting quotes, offers, and any communication, cooperation, and other activities reasonably related to FOKUS’s business operations.

Data analysis activities may comprise automated processing including the profiling of individuals affiliated with Business Partners. FOKUS may in particular combine data from the above-described direct and indirect online and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Business Partners and in case Business Partners are corporations, of individuals affiliated with Business Partners. FOKUS conducts such analysis activities to understand the needs of its Business Partners, in particular to enhance, develop, present and provide new products to them, online and offline.

Online activities include targeted advertisements on FOKUS’s website and in user accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to FOKUS’s business operations.

Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to FOKUS’s business operations.

3.4 Permission

Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular the initiation and performance of a contract, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which FOKUS is subject to and where the processing of personal data is in the legitimate interest of FOKUS. Legitimate interests are the development, nurturing and enhancement of existing and initiation of new business relationships and any activities related thereto to pursue FOKUS’s business operations.

4. Recruitment Data

In course of its business operations, FOKUS processes data related to the recruitment of new personnel. These data may also include personal data of individuals.

4.1 Data Categories

Data processed include first, middle and last name, academic title, professional status, position, birth date, personal status, work history, current position and former positions, education, postal address, e-mail address, telephone number, login-in data, online identifiers, IP addresses and other personal data reasonably related to the recruitment of new personnel.

4.2 Data Sources

Personal data are obtained through direct and indirect online and offline sources. Direct sources include business cards, job applications, e-mails, facsimiles, letters, meetings, entries on FOKUS’s website and other electronic or non-electronic communication and interaction between an individual and FOKUS in course of a job application. Indirect sources include publicly available data, data of users that access, browse or otherwise use FOKUS’s website or third party websites on which FOKUS has posted advertisements and data received in compliance with applicable laws from third parties.

4.3. Processing Purposes

Personal data are processed for searching and recruiting new personnel for FOKUS’s business operations including any activities reasonably related thereto.

4.4. Permission

Personal data are processed in compliance with applicable laws on basis of the applicable legal permission, in particular where necessary for the job application and the initiation of an employment relationship with FOKUS, where the individual has given consent to the processing, where the processing is necessary for compliance with a legal obligation to which FOKUS is subject and where the processing of personal data is in the legitimate interest of FOKUS. Legitimate interests are the processing of the job application to find and recruit skilled personnel for FOKUS.

5. Website Data and Cookies

For information about the processing of personal data on FOKUS’s website and third party websites, please refer to Policy for the Handling of Personal Data on FOKUS Websites and to the FOKUS Cookie Policy.

6. Retention Periods

Personal data will be removed from FOKUS’s systems and records and/or steps are taken to anonymize data if processing is no longer required for the original purpose unless it is necessary to keep personal data to comply with a legal obligation to which FOKUS is subject, e.g. statutory retention periods under applicable laws including commercial and tax laws or where FOKUS has a legitimate interest to retain information in compliance with applicable laws, e.g. for filing, enforcing or defending legal claims. FOKUS has installed and maintains retention policies in compliance with applicable data protection and other laws.

7. Transfer of Personal Data

FOKUS may transfer data including personal data to Business Partners, courts, law enforcement agencies, government authorities, other public bodies and other third parties, which may have access to and/or process personal data. Transfers are made on a need to know basis in compliance with applicable laws and agreements with Business Partners.

7.1 Transfer to Business Partners

Purpose of data transfers to Business Partners is to outsource internal functions and utilize external resources, e.g. IT services, HR, recruiting, marketing activities, marketing data analysis, administration of campaigns, offline and online advertisement, publishing, design, legal, tax, financial advisory services and other activities reasonably related to FOKUS’s business operations.

Business Partners that act as service providers for FOKUS are contractually bound to take appropriate technical and organizational security measures to safeguard and process personal data only as instructed by FOKUS. The same applies to any sub-providers of Business Partners’ service providers.

7.2 Transfer to government authorities, courts, law enforcement agencies

Purpose of data transfer to government authorities, courts, law enforcement agencies and other public bodies is to comply with obligations to which FOKUS is subject to under applicable laws, e.g. -transfer and disclosure obligations under social security law, civil procedure law, tax, import and export laws.

8. Transfer of Personal Data to other Countries

To the extent personal data are transferred to and processed in other countries than where FOKUS is established, FOKUS transfers personal data in compliance with applicable laws and has established appropriate safeguards by means of data processing and data transfer agreements that oblige the recipient in the other country to establish and adhere to an adequate level of data protection.

9. Information Obligations

In compliance with applicable laws, FOKUS informs individuals about its personal data processing activities as described in the FOKUS Privacy Policy and the FOKUS Cookie Policy. FOKUS provides amongst others on and offline references to the FOKUS Privacy Policy on FOKUS’s website, electronic or non-electronic communication with individuals and electronic or non-electronic business documents to promote its data privacy activities.

10. Consent and Withdrawal of Consent

Where required under applicable data protection and other laws, FOKUS processes any data only after consent. Providing consent and data is voluntary. Before obtaining consent, FOKUS will duly inform each individual about the respective processing activity. Without providing data, an individual may not be able to engage with FOKUS in respect of FOKUS’s business operations.

A consent can be withdrawn at any time with future effect by e-mail to info@naym.be or by sending a withdrawal notice to the contact stated under 12. below. A withdrawal will not affect the lawfulness of the processing prior to the withdrawal.

11. Rights of Individuals

Where FOKUS processes personal data of individuals, each individual may exercise its rights under applicable laws.

Any rights can be exercised by sending an e-mail to info@naym.be or to the contact details stated under 12. below.

In addition, each individual may lodge a complaint with a competent data protection supervisory authority.

Under the applicability of the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, “GDPR”) any individual may exercise towards FOKUS the following rights:

Right of Access,
Right of Rectification,
Right to Erasure,
Right to restriction of processing,
Right to object to processing,
Right to data portability,
Where FOKUS processes personal data for direct marketing purposes, each individual has the right to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling to the extent related to marketing purposes.

12. FOKUS Personal Data Protection Organization

FOKUS, Avenue Albert 161, 1190 Vorst, ondernemingsnr: 0899.378.060 controls and is accountable for the processing of personal data within its operations (data controller).

FOKUS maintains a personal data protection organization, which serves as point of contact for all inquiries regarding the processing of personal data by FOKUS.

13. Change Management

FOKUS may change the FOKUS Personal Data Protection Basic Policy, the Policy for the Handling of Personal Data on FOKUS Websites and the FOKUS Cookie Policy at any time and without explicit notice. The enactment date and the date of the last revision is shown in the respective document and any prior versions can be requested from FOKUS.

Policy for the Handling of Personal Data on FOKUS Websites

1. Scope of Application

This Policy for the Handling of Personal Data on FOKUS Websites is part of FOKUS’s Privacy Policy.

It describes how FOKUS processes data of users that access, browse or otherwise use FOKUS’s website or third party websites on which FOKUS has posted advertisements (“Users”). These data include also personal data that Users actively send, transmit or otherwise provide on FOKUS’s website and that FOKUS collects or otherwise obtains via cookies.

For detailed information about the use of cookies please refer to the FOKUS Cookie Policy.

2. Purposes

2.1 Services

FOKUS processes data including personal data for providing the following services in connection with its business operations (“Services”):

2.1.1 User Accounts

After registration, FOKUS offers personalized User accounts that allow access to product information and services and other information reasonably related to FOKUS’s business operations.

2.1.2 Inquiries and Requests

FOKUS offers the possibility to make online inquiries and requests regarding its products and services and strives to revert to the inquirer in due time.

2.1.3 Newsletters

After registration, FOKUS offers online newsletters by e-mail or other electronic means. Newsletter comprise information about FOKUS’s products, services, events, seminars, exhibitions, campaigns and other information reasonably related to FOKUS’s business operations.

2.1.4 Information Download

After registration, FOKUS offers information about products and services and other information reasonably related to FOKUS’s business operations.

2.1.5 Promotional Campaigns

FOKUS invites Users to take part in online promotional and other campaigns to bring FOKUS’s products and services and other information reasonably related to FOKUS’s business operations to the attention of current and potential customers and the wider public. FOKUS asks individuals to provide their comments and opinions about FOKUS’s products and services. FOKUS may also send materials and samples and other giveaways and information offline to Users participating in the campaigns.

2.1.6 Recruitment

FOKUS may offer information about job vacancies of any kind on its website and invite individuals to file applications via FOKUS’s website.

2.1.7 PC and Mobile Application Software

FOKUS offers software for specific services and functions alone or in together with FOKUS’s products, services and other activities reasonably related to FOKUS’s business operations. FOKUS provides certain support services like software and firmware support. Software applications may create crash reports that help FOKUS and third party software developers to resolve any issues with the software.

Where required under applicable data protection and other laws, FOKUS processes data only after the consent of the User. Providing consent and data is voluntary. Before obtaining any consent, FOKUS will duly inform each individual about the respective processing activity. Without providing data, a User may still access, browse or otherwise use FOKUS’s website but may not able to benefit from some or all of the Services.

Regarding the withdrawal of a consent and other rights of Users, please refer to the FOKUS Personal Data Protection Basic Policy.

2.2 Marketing

For its marketing activities FOKUS processes data that Users have actively sent, transmitted or otherwise provided on FOKUS’s website for Services (see 2.1 above) and that FOKUS has collected or otherwise obtained via cookies from its and third party websites where FOKUS has posted advertisements. For detailed information about the use of cookies please refer to the FOKUS Cookie Policy.

FOKUS analyses such data alone or in combination or together with other data including personal data FOKUS has lawfully received. Data analysis activities may comprise automated processing including profiling. FOKUS may in particular combine data from the above-described direct and indirect online sources and offline sources and analyze or predict preferences, interests, reliability, behavior, location, movements and other activities of Users. FOKUS conducts such analysis to understand the needs of the Users, in particular to enhance, develop, present and provide new products to them, online and offline.

Online activities include targeted advertisements on FOKUS’s website and in User accounts, online newsletters by e-mail or other electronic means, promotional campaigns and other activities reasonably related to FOKUS’s business operations.

Offline activities include the delivery of marketing and other promotional material including samples by mail and other activities reasonably related to FOKUS’s business operations.

Regarding the withdrawal of a consent and further rights of Users, in particular to object at any time to the processing of its personal data for direct marketing purposes, which includes profiling, please refer to the FOKUS Personal Data Protection Basic Policy.

FOKUS Cookie Policy

1. Scope of Application

This FOKUS Cookie Policy describes how FOKUS collects or otherwise obtains, via Cookies, data of users that access, browse or otherwise use FOKUS’s website or third party websites on which FOKUS has posted advertisements (“Users”). These data may include also personal data.

This FOKUS Cookie Policy supplements the FOKUS Privacy Policy in respect of the use of Cookies on the FOKUS Website.

2. Cookies

Cookies are small files, usually composed of alphanumeric characters, issued by FOKUS’s website or third party providers (“Cookies”) and stored on computers, tablets, smart phones and other devices (“Devices”) of Users that access, browse or otherwise use FOKUS’s website or third party websites on which FOKUS has posted advertisements.

3. Types of Cookies

Cookies are usually classified into (i) Session Cookies and Persistent Cookies, and (ii) in First Party Cookies and Third Party Cookies, which will be explained in the following.

3.1 Session Cookies

Session Cookies ensure that a User can use functions and refer to information on the FOKUS website in an efficient way. For example, they ensure that a User is not required to enter the same information repeatedly while using the FOKUS website. They are stored in temporary memory and deleted when the web browser is closed.

3.2 Persistent Cookies

Persistent Cookies are stored on the hard disk of the User’s device and are not deleted if the web browser is closed. For example, they are used to save a setting that ensures a User can use the same language when he/she visits next time and to record the number of visits. The period these Cookies are stored varies from Cookie to Cookie.

3.3 First Party and Third Party Cookies

First Party Cookies are issued by FOKUS. Third Party Cookies are issued by third party service providers, which FOKUS uses, e.g. to embed certain functionalities on its website for social media content. In some cases, third party providers use further sub-providers that issue so called Fourth Party Cookies that come along with their service applications. Under this Cookie Policy and FOKUS’s Cookie management system, Fourth Party Cookies are treated as Third Party Cookies. This means that any setting a User applies to Third Party Cookies will also apply to any Fourth Party Cookies associated therewith.

4. Cookies used on the FOKUS Website

FOKUS uses Cookies for the following purposes:

Strictly Necessary Cookies: These Cookies ensure that the FOKUS website operates properly. They are technically necessary and FOKUS cannot switch off these Cookies in its systems without losing the operability of its website. They are usually only set in response to actions of Users on the FOKUS website, such as setting privacy preferences, logging in or filling in forms. You can set your browser to alert you about these Cookies and block them, but some parts of the FOKUS website may then not work and you may not be able to use some or all of the functions and services offered by FOKUS.

These Cookies do not store any personally identifiable data.

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FOKUS uses Google Analytics, third-party cookies for the purposes described above. Please refer to the terms of such service providers to understand how your data is handled by them. http://www.google.com/policies/privacy/partners/

Performance Cookies: These Cookies allow FOKUS to measure and analyze User activities on FOKUS’s website to improve its performance. They usually measure traffic data including the number of Users that visit FOKUS’s website, number of visits, pages Users view and website and location from which the visit originates. They help FOKUS to know which pages are the most and least popular, see where Users come from and how they move around on the FOKUS website. You can set your browser to alert you about these Cookies and block them, but FOKUS will not be able to monitor and improve the performance of its website for the benefit of Users.

These Cookies do not store any personally identifiable data; any data collected is aggregated and anonymous.

Google Analytics

Marketing Cookies: These Cookies allow FOKUS to personalize the experience of Users on FOKUS’s website and communicate with Users in the most relevant way possible. They usually record on-line activities, including websites Users visit, pages on the FOKUS website users view, and link information that Users submit on FOKUS’s website pages including web forms, to the information stored on the Cookie. FOKUS uses Cookies from third parties to recognize users when they return to FOKUS’s websites and to understand which pages Users visit. You can set your browser to alert you about these Cookies and block them, but FOKUS will not be able to personalize your experience on FOKUS’s website and to communicate with you in the most relevant way possible.

These Cookies may store personally identifiable data.

Social Media Cookies: These Cookies allow FOKUS to add and embed social media services of third party service providers on its website for sharing FOKUS’s content. Each social media service provider may collect data including personal data through Cookies. These social media providers are capable of tracking your browser across other sites and building up a profile of your interests. This may affect the content and messages you see on other websites you visit. You can set your browser to alert you about these Cookies and block them, but you may not be able to see the social media embedded on FOKUS’s website.

These Cookies may store personally identifiable data.

Please see here for a detailed list of the Social Media Cookies used. For more details than the information provided by FOKUS regarding the purpose and retention period of the Social Media Cookies used by third party providers, please kindly refer to the privacy and cookie policies of the providers.

5. How to manage Cookies

In most web browsers, it is possible to make a setting to notify receipt of Cookies being sent; that is, to select whether or not to receive Cookies. It is also possible to make a setting to render the Cookie function inoperable. You may use the FOKUS Website even if you make a Cookie function inoperable. However, blocking some types of Cookies may affect your experience of the FOKUS website and its functions and services.