Privacy Policy of Skillsbeam

Version 2.0. Effective Date: April 7th 2023

1. Who is the Data Controller and what this Policy is about

This Privacy Policy applies to our website https://cybersec.skillsbeam.io/, the global website developed jointly by Ataya & Partners and Hightech Partners, trading under the name of “Skillsbeam”, located Avenue Louise, 500 – 1050 Brussels, Belgium.

Hereafter commonly referred to as “Skillsbeam", “we,” “us” and “our” etc.

Ataya & Partners, the data controller for all processes of skillsbeam, is a consulting company in the domains of IT, digital management and governance, cybersecurity and data protection. And is registered at the Banque Carrefour des Entreprises under the number 0719.976.659.

With Skillsbeam, we provide you with the possibility to assess your digital skills. For additional information on our services, please visit https://www.skillsbeam.io.

We may collect personal information in the course of our business, including through your use of our website, when you contact us or request information from us or when you engage our services. When we require personal information from you in order to fulfill a requirement, we will inform you and indicate the consequences of failing to do so.

We respect the privacy of the visitors and users of our website and are committed to protect their personal data and information according to the applicable law. This privacy policy explains how, to what extent and for what purposes we are collecting and subsequently processing personal data and information collected through our website.

Our Data Protection Office can be contacted at admin@skillsbeam.io or via mail at Skillsbeam - Data Protection Office, Avenue Louise 500, 1050 Brussels, Belgium.

2. Personal data we collect and/or process

Registrations, subscriptions and forms

If you register with us via the website, sign up to receive news and information from us, or communicate with us through or related to the website (e.g. when you fill out a ‘Contact Us’ form, sign up for our mailing lists) or otherwise provide us information through the website, we may collect the following personal information:

• Contact information: first and last name, e-mail and phone number.
• Professional information: job title and company name, URL and size.
• Social media information: LinkedIn profile. (Optional)

Creation of a profile

If you chose to create a profile, we would collect the following personal information:

• First and last name
• Gender (optional)
• A photo (optional)
• Date of birth (optional)
• Marital status (optional)
• E-mail, private (mandatory) and professional (optional)
• Nationality (optional)
• Country of residence
• Address (optional)
• Phone number, private (mandatory) and professional (optional)
• Skype Name (optional)
• Company name
• Current job title
• Academic education details (optional)
• List of skills (optional)
• Copies of trainings and certifications (optional)

This list is non-exhaustive, which reflects the varied nature of the data we process.

3. Purpose and legal bases for our use of your personal data

Our processing of personal information is justified by a “legal basis.” We may use personal information for the following purposes, in each case justified by a legal basis:

Fulfilment of services

We use personal information to enable us:

• to perform and deliver the services, respond to your requests;
• to provide advice and related services;
• to verify your identity, and carry out requests made by you on the website or in relation to our services.

Legal basis: This processing is necessary for our compliance with our contractual obligations with you as a party (including our professional standards and ethical duties). Also, it is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others and comply with our professional and ethical duties, consistent with applicable law.

Client services

We use personal information:

• to provide and operate our website and the services;
• to communicate with you (e.g. about your use of the website and services);
• to respond to your inquiries, requests or complaints;
• to provide and operate our website;
• to provide technical support.

Legal basis: This processing is necessary to establish, exercise or defend our contractual rights and duties. It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you or others and comply with our professional and ethical duties, consistent with applicable law.

Business administration and legal compliance

We use personal information for the following business administration and legal compliance purposes:

• To comply with our legal obligations (where needed, based on GDPR, ePrivacy regulation, conflicts or similar obligations including, but without limitation, maintaining regulatory insurance).
• To investigate and/or settle inquiries or disputes.
• To comply with any applicable law, court order, other judicial process, law enforcement requests or the requirements of a regulator.
• To enforce our agreements with you.
• To protect the rights, property or safety of us or third parties, including our other clients and users of the website or our services.
• To maintain our records.
• When necessary to enforce, establish or defend our legal rights, or to protect the rights of third parties.
• Anonymous and de-identified information to assess, improve and develop our business, products and services, and for similar research and analytics purposes.

Legal basis: Such processing either necessary to comply with the legal and contractual obligations imposed upon us or in our legitimate interest or a third party’s legitimate interest to use your personal information for business administration and legal compliance purposes.

Marketing and promotions

We may use personal data for marketing and promotional purposes, such as:

• to send you news and newsletters, or to otherwise contact you about products or information we think may interest you, by e-mail. We may also use it to develop new services and determine how to market them.

We may also process your personal data to tailor content we may send or display on the website, including:

• to offer location customization and personalized help and instructions and to otherwise personalize your experiences.

Legal basis: It is in our legitimate interest to use your personal information for marketing purposes in order to develop and grow our business and Services and promote the reputation of our firm. We will, where required by applicable law, obtain your consent to send such communications.

For example, when we process your personal data for direct marketing purposes, which include sending you newsletters, client alerts and information we think may interest you, we will make sure to collect your consent.

Client development

We may use personal information in order to respond to Requests for Proposals, prepare for and present pitches and other proposals, and identify potential business opportunities. Largely, this involves our collection and use of non-personal business information about current, former and prospective corporate clients. However, we may also process limited personal information about individuals (name, current and former company, current and former title, contact information and similar information).

Legal basis: This processing is done based on our legitimate interest to use your personal information in order to develop and grow our business and Services and promote the reputation of our company. We also may process this information to respond to a Request for Proposal or a specific request in anticipation of a contract with you (i.e. engagement for services).

Client insight and analytics

We use personal information to better understand how you and others use our services, so that we can improve our website, develop new features, tools, offers, services, and for other research and analytical purposes. We also use the information we collect to measure the effectiveness of our online content and how visitors use our website. This allows us to learn what pages of our website are most attractive to our visitors, and what kind of offers our registered users like to see. We may use this data for marketing purposes (see the marketing section above for further details), or to make decisions about events, news and information that may be of interest to clients, prospective clients, website users and others.

Legal basis: It is in our legitimate interest to use your personal information in such a ay to ensure that we provide the very best Services to our clients and others in order to develop and grow our business and Services and promote the reputation of our company.

4. Sharing your personal data

Your data that we have is mainly processed by our employees, consultants and workers who are obliged to respect a certain level of confidentiality, applicable laws and any regulations regarding the processing of data.

We may share personal information with the following categories of third parties as necessary, in their capacity as sub-contractor data processors:

• Our professional advisers, such as lawyers, security consultants, auditors and accountants.
• Government and/or regulatory authorities.
• Third parties to whom we outsource certain services, such as, without limitation, document processing and translation services, confidential/personal data encryption, anonymization, pseudonymization and disposal, IT systems or software providers, IT Support service providers, and document and information storage providers.
• Third-party service providers to assist us with client insight analytics.

These data processors will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

Further, we may appoint external data controllers where necessary to deliver the services (for example, but without limitation, consultants and other third-party experts). When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including, putting appropriate safeguards in place.

We will normally not transfer personal information to countries outside the EEA unless they provide an adequate level of protection for your personal data.

If an exceptional transfer to other countries is required, that will only be done after a data sharing agreement is signed or a data processing, based on the EU standard contractual clauses, to provide appropriate safeguards and an adequate level of protection for personal data.

5. Our use of cookies and similar technologies

Our Site uses certain cookies, pixel tags, log files, local storage objects and other tracking technologies to operate and improve our website and our services, to collect information about how our website is accessed and used and about the website performance and security.

Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

6. Retention of personal data

The information of our users will be processed and maintained in our database as long as your account is active and until we receive from you a request to erase your data.

Other specific retention times, as imposed by law or based on a detailed privacy assessment done by us, may apply for some of the processing of personal data. If you have any questions in this regard, please do not hesitate to contact us.

7. Confidentiality and security of your personal data

We are committed to keep personal data secure, and we have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.

Please note that no transmission over the internet is completely secure or error-free, and that the information security policies, rules and technical measures used and maintained by us may be subject to compromise.

All of our partners, employees, consultants, workers and data processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of such personal data.

8. Your rights in relation to the personal data we hold

As data controller in regards to any process of Skillsbeam, Ataya & Partners  is committed to facilitate the exercise of individuals’ rights in accordance with the applicable regulations.

Here is a list of these rights:

The right of access

If you ask us, we will confirm whether we are processing your personal information and, if necessary, provide you with a copy of the data we have about you. If you require additional copies, we may need to charge a reasonable fee.

The right of rectification

If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it corrected. If you are entitled to have information corrected and if we have shared your personal information with others, we will let them know about the rectification if possible. If you ask us, we will also tell you, where it is possible and lawful to do so, with whom we have shared your personal information with, so that you can contact them directly.

The right to be forgotten (erasure)

You can ask us to delete or remove your personal information in some circumstances, such as when we no longer need it or if you withdraw your consent (if applicable). If you are entitled to erasure and if we have shared your personal information with others, we will let them know where possible. If you ask us, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your personal information with, so that you can contact them directly.

The right of restriction (limitation principle)

You can ask us to restrict the processing of your personal information in certain circumstances, if you contest the accuracy of that personal information or you object to the processing of your data. If you are entitled to restriction and if we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your personal information so that you can contact them directly.

The right to data portability

You have the right, in certain circumstances, to receive a copy of the data we have obtain from you in a structured, commonly used and machine-readable format, and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

The right not to be the subject of automated decisions and profiling

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary.

Withdrawal and opposition rights

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

The right to lodge a complaint

If you have a concern about any aspect of our privacy practices, including the way handle your data, you can report it to the relevant supervisory authority.

In Belgium, this is the :

Autorité de protection des données

Rue de la Presse, 35, 1000 Bruxelles

+32 (0)2 274 48 00

contact@apd-gba.be

Please note that some of these rights may be limited where we have an overriding legitimate interest or legal obligation to continue to process the personal information, or where the personal information may be exempt from disclosure due to applicable law, the applicable rules of professional conduct, other applicable privileges or professional secrecy obligations.

9. Collection of information by third-party websites and sponsors

Our website may contain links redirecting you to other websites whose information practices may be different than ours. Visitors should consult the other websites’ privacy policies as Skillsbeam has no control over information that is submitted to or collected by these third parties.

10. Children

The website is not to be used by children under the age of thirteen (13) years old, therefore we do not knowingly collect, store, share or use the personal information of children under 13. If you are under the age of 13, please do not provide any personal information, even if prompted by the website to do so. If you are under the age of 13 years old and you believe you have provided personal information to us, please ask your parent(s) or guardian(s) to notify us and we will delete all personal information.

11. Changes to this Policy

We may make changes to this policy from time to time, to reflect any modification in our practices. We may also make changes as required to comply with new applicable laws or regulatory requirements. We would make sure to notify you (such as posting a notice on the website or sending an e-mail) if this was to happen.

12. How to contact us

If you have any question regarding the processing of your data listed in this policy, you can contact us by e-mail at admin@skillsbeam.io or by post: Skillsbeam - Data Protection Office, Avenue Louise 500, 1050 Brussels, Belgium.