PRIVACY POLICY – TRUST & TRANSPARENCY

1. What our policy covers

Your privacy and the integrity of your personal data is very important to PYCOGROUP, and so is being transparent about how we may receive, collect, use, and share information about you. This policy is intended to help you understand PYCOGROUP’s Privacy Policies.

This Privacy Policy covers the information we receive from you or collect about you when you use our Site or Services, or otherwise interact with us (for example, by attending our events), unless a different policy is displayed.  PYCOGROUP, we and us refers to Pyramid Consulting SA and any of our corporate affiliates.  PYCOGROUP’s mission is to help its clients “build Digital teams and solutions” in doing so we offer web and software development services as well as staffing and recruitment services, we refer to these as "Services" in this policy.

If you do not agree with this Privacy Policy, do not access or use our Site or Services or interact with any other aspect of our business.

Where we provide the Services under contract with an organization or yourself that contract may further control the information processed by PYCOGROUP.

2. What information we collect about you

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

Information you provide to us: We collect information about you when you input it into the Services or otherwise provide it directly to us.

Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you may provide content to us when you apply to online job openings, spontaneously send us your résumé, use our contact form to make business or Services enquiries, provide feedback or when you participate in any interactive features, surveys, contests, promotions, activities or events.

Device and Connection Information: We may collect information about your computer, phone, tablet, or other devices you use to access the Site. This device information includes your connection type and settings when you install, access, update, or use of our Services. We may also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience.  How much of this information we collect depends on the type and settings of the device you use to access the Services.  Server and data center Service administrators can disable collection of this information via the administrator settings or prevent this information from being shared with us by blocking transmission at the local network level.

Cookies and Other Tracking Technologies: PYCOGROUP and our third-party partners, such as Google analytics, may use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. A cookie disclaimer and acceptance banner conditions usage of our Site.

3. How we use information we receive and/or collect

Below are the specific purposes for which we use the information we receive or collect about you.

To communicate with you about the Services: We may use your contact information and information to communicate about our Services, offer you to engage into a Services Contract, enter into a partnership with PYCOGROUP relating to the Services.

To market, promote and drive engagement with the Services:  We may use your contact information and information to send promotional communications that may be of specific interest to you, including by email and by displaying PYCOGROUP ads on other companies' websites and applications, as well as on platforms like Linked-In, Facebook and Google, etc.  These communications are aimed at driving, including information about new services, survey requests, newsletters, and events we think may be of interest to you.  You can control whether you receive these communications as described below under "Opt-out of communications."

To power our customer relationship management (CRM) database: Our CRM database may store personal data and information relating to individuals and/or companies with whom we already have a Services relationship or want to develop one. The information used for these purposes include relevant business information, such as: contact data, publicly available information (e.g. your public posts, information, publications on social media sites if relevant for business purpose), your responses to targeted e-mail. If you wish to be excluded from our CRM databases, please contact us at DPO@pycogroup.com

For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.

To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

Special Legal bases for collecting and processing information of EEA residents: If you are an individual residing in the European Economic Area (EEA), we may only collect and process information about you (i.e. “personal data” as defined in the General Data Protection Regulation 2016/679) where we have legal bases for doing so and under the strict respect of applicable EU laws and regulations.

This means we may collect and use your information only where:


If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, you also have the right to access personal information we may hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us at the following email address DPO@pycogroup.com.

4. How does PYCOGROUP share information it receives and/or collects

We share information we receive and collect about you in the ways discussed below, including in connection with the Services, but we are not in the business of selling information about you to advertisers or other third parties.

Sharing with other Service users: When you accept to use the Services, we share certain information about you with other Service users.
If another Services user needs to access information about you for us to perform the Services, they do so under the obligation, to observe all policies and procedures designed to protect your information hereunder.

Links to Third Party Sites: The Site may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

With your consent: We share information about you with third parties when you give us consent to do so.  For example, we may display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial. 

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect PYCOGROUP, our customers or the public from harm or illegal activities.

Sharing with PYCOGROUP companies: We share information we receive or collect with affiliated companies.  Affiliated companies are companies owned by PYCOGROUP.  The protections of this privacy policy apply to the information we share in these circumstances.

Business Transfers: We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information.

5. How does PYCOGROUP store and secure information it receives and/or collects

Information storage and security: We use data hosting service providers in the United States, France, Vietnam, and Singapore, to host the information we receive and/or collect, and we use technical measures to secure your data (data encryption, data segregation, physical security processes, etc.).

While we implement safeguards designed to protect your information, no security system is impenetrable and in case of breach of your information we will implement the following Data Breach Policy (Hyperlink).

In our customer relationship management (CRM) database: Our CRM database may store personal data and information relating to individuals and/or companies with whom we already have a Services relationship or want to develop one. If you wish to be deleted from our CRM databases, please contact us at DPO@pycogroup.com

How long we keep information: How long we keep information we collect about you depends on the type of information, as described in further detail below.  After such time, we will either delete or anonymize your information.

Promotional information: If you have elected to receive information emails from us, we retain information about your promotional preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened or answered an email from us.  We retain possible information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

6. How can you access and control your information?

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.

Your Choices: You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format.  Below, we describe the tools and processes for making these requests.  If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so.  Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below.

Opt out of communications: You may opt out of receiving promotional communications from us by i) using the unsubscribe link within our email, or ii) requesting so by answering any of our emails in case it does not contain a direct unsubscribe link.

Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier).  Depending on the context, this applies to some of your information, but not to all of your information.  Should you request it, we will provide you with an electronic file of your basic personal information.

Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

Changes: We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Contact us: For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail DPO@pycogroup.com or mail to:

PYCOGROUP
Avenue Louise 523
1050 Brussels,
Belgium.

PERSONAL DATA BREACH NOTIFICATION POLICY

1. Introduction

  1. 1.1 This policy sets out the policies and procedures of Pyramid-Consulting SA and its subsidiaries (the "company") with respect to detection of personal data breaches, responding to personal data breaches and notification of personal data breaches to supervisory authorities, data controllers and data subjects.

  2. 1.2 When dealing with personal data breaches, the company and all company personnel must focus on protecting individuals and their personal data, as well as protecting the interests of the company.

2. Definitions

  1. 2.1 In this policy:

    1. (a) "appointed person" means the individual primarily responsible for dealing with personal data breaches affecting the company, being the data protection officer of the company;

    2. (b) "data controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

    3. (c) "data processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

    4. (d) "data subject" means an identified or identifiable natural person; 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

    5. (e) "personal data" means any information relating to a data subject;

    6. (f) "personal data breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed by the company (including any temporary or permanent loss of control of, or inability to access, personal data); and

    7. (g) "supervisory authority" means the National data protection authority (as formalized by the GDPR) where the breach occured.

3. Responding to personal data breaches

  1. 3.1 All personnel of the company must notify the appointed person immediately if they become aware of any actual or possible personal data breach.

  2. 3.2 The appointed person is primarily responsible for investigating possible and actual personal data breaches and for determining whether any notification obligations apply. Where notification obligations apply, the appointed person is responsible for notifying the relevant third parties in accordance with this policy.

  3. 3.3 All personnel of the company must cooperate with the appointed person in relation to the investigation and notification of personal data breaches.

  4. 3.4 The appointed person must determine whether the company is acting as a data controller and/or a data processor with respect to each category of personal data that is subject to a personal data breach.

  5. 3.5 The steps to be taken by the appointed person when responding to a personal data breach may include:

    1. (a) ensuring that the personal data breach is contained as soon as possible;

    2. (b) assessing the level of risk to data subjects as soon as possible;

    3. (c) gathering and collating information from all relevant sources;

    4. (d) considering relevant data protection impact assessments;

    5. (e) informing all interested persons within the company of the personal data breach and the investigation;

    6. (f) assessing the level of risk to the company; and

    7. (g) notifying supervisory authorities, data controllers, data subjects and others of the breach in accordance with this policy.

  6. 3.6 The appointed person shall keep a full record of the response of the company to a personal data breach, including the facts relating to the personal data breach, its effects and the remedial action taken. This record shall form part of the personal data breach register of the company.

4. Notification to supervisory authority

  1. 4.1 This section 4 applies to personal data breaches affecting personal data with respect to which the company is acting as a data controller.

  2. 4.2 The company must notify the supervisory authority of any personal data breach to which this section 4 applies without undue delay and, where feasible, not later than 72 hours after the company becomes aware of the breach, save as set out in subsection 4.4.

  3. 4.3 Personal data breach notifications to the supervisory authority must be made by the appointed person using the form set out in schedule 1 (Notification of personal data breach to supervisory authority). The completed form must be sent to the supervisory authority by secure and confidential means. The appointed person must keep a record of all notifications, and all other communications with the supervisory authority relating to the breach, as part of the personal data breach register of the company.

  4. 4.4 The company will not notify the supervisory authority of a personal data breach where it is unlikely to result in a risk to the rights and freedoms of natural persons. The appointed person shall be responsible for determining whether this subsection 4.4 applies, and the appointed person must create a record of any decision not to notify the supervisory authority. This record should include the appointed person's reasons for believing that the breach is unlikely to result in a risk to the rights and freedoms of natural person. This record shall be stored as part of the personal data breach register of the company.

  5. 4.5 To the extent that the company is not able to provide to the supervisory authority all the information specified in schedule 1 (Notification of personal data breach to supervisory authority) at the time of the initial notification to the supervisory authority, the company must make all reasonable efforts to ascertain the missing information. That information must be provided to the supervisory authority, by the appointed person, as and when it becomes available. The appointed person must create a record of the reasons for any delayed notification under this subsection 4.5. This record shall be stored as part of the personal data breach register of the company.

  6. 4.6 The company must keep the supervisory authority informed of changes in the facts ascertained by the company which affect any notification made under this section 4.

5. Notification to data controller

  1. 5.1 This section 5 applies to personal data breaches affecting personal data with respect to which the company is acting as a data processor.

  2. 5.2 The company must notify the affected data controller(s) of any personal data breach to which this section 5 applies without undue delay and, where feasible, not later than 72 hours after the company becomes aware of the breach. In addition, the company must comply with the provisions of the contract(s) with the affected data controller(s) relating to such notifications.

  3. 5.3 Personal data breach notifications to the affected data controller(s) must be made by the appointed person using the form set out in schedule 2 (Notification of personal data breach to data controller). The completed form must be sent to the affected data controller(s) by secure and confidential means. The appointed person must keep a record of all notifications, and all other communications with the affected data controller(s) relating to the breach, as part of the personal data breach register of the company.

  4. 5.4 To the extent that the company is not able to provide to the affected data controller(s) all the information specified in schedule 2 (Notification of personal data breach to data controller) at the time of the initial notification to the affected data controller(s), the company must make all reasonable efforts to ascertain the missing information. That information must be provided to the affected data controller(s), by the appointed person, as and when it becomes available.

6. Notification to data subjects

  1. 6.1 This section 6 applies to personal data breaches affecting personal data with respect to which the company is acting as a data controller.

  2. 6.2 The company must notify the affected data subjects of any personal data breach to which this section 6 applies if the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, save as set out in subsection 6.4.

  3. 6.3 Personal data breach notifications to the affected data subjects must be made by the appointed person in clear and plain language using the form set out in schedule 3 (Notification of personal data breach to data subject). The completed form must be sent to the affected data subjects by appropriate means. The appointed person must keep a record of all notifications, and all other communications with the affected data subjects relating to the breach, as part of the personal data breach register of the company.

  4. 6.4 The company has no obligation to notify the affected data subject of a personal data breach if:

    1. (a) the company has implemented appropriate technical and organisational protection measures (in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption), and those measures have been applied to the personal data affected by the personal data breach;

    2. (b) the company has taken subsequent measures which ensure that a high risk to the rights and freedoms of data subjects is no longer likely to materialise;

    3. (c) it would involve disproportionate effort (in which case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner), providing that the appointed person shall be responsible for determining whether this subsection 6.4 applies, and the appointed person must create a record of any decision not to notify the affected data subjects. This record should include the appointed person's reasons for believing that the breach does not need to be notified to the affected data subjects. This record shall be stored as part of the personal data breach register of the company.

  5. 6.5 If the company is not required by this section 6 to notify affected data subjects of a personal data breach, the company may nonetheless do so where such notification is in the interests of the company and/or the affected data subjects.

7. Other notifications

  1. 7.1 Without affecting the notification obligations set out elsewhere in this policy, the appointed person should also consider whether to notify any other third parties of a personal data breach. Notifications may be required under law or contract. Relevant third parties may include:

    1. (a) the police;

    2. (b) other law enforcement agencies;

    3. (c) insurance companies;

    4. (d) regulatory authorities;

    5. (e) financial institutions;

    6. (f) trade unions or other employee representatives; and/or

    7. (g) Leasing/Rental Companies.

8. Reviewing and updating this policy

  1. 8.1 The DPO shall be responsible for reviewing and updating this policy.

  2. 8.2 This policy must be reviewed and, if appropriate, updated annually on or around [date].

  3. 8.3 This policy must also be reviewed and updated on an ad hoc basis if reasonably necessary to ensure:

    1. (a) the compliance of the company with applicable law, codes of conduct or industry best practice;

    2. (b) the security of data stored and processed by the company; or

    3. (c) the protection of the reputation of the company.

  4. 8.4 The following matters must be considered as part of each review of this policy:

    1. (a) changes to the legal and regulatory environment;

    2. (b) changes to any codes of conduct to which the company subscribes;

    3. (c) developments in industry best practice;

    4. (d) any new data collected by the company;

    5. (e) any new data processing activities undertaken by the company; and

    6. (f) any security incidents affecting the company.