Privacy Policy

1. Who We Are and What this Policy is

This Privacy Policy applies to our website https://www.stefanifrim.com, the global website of frimgle, trading under the name of "frimgle" & Stefan Ifrim Business Coaching – Boulevard Bischoffsheim 39/4 – 1000 Brussels, Belgium – VAT BE 0668.419.377 ("our Site"), hereafter commonly referred to as "frimgle," "we," "us" and "our".

We are a Business Coaching company. We help businesses and professionals improve their performance, develop strategic thinking, and achieve growth by providing personalized coaching, consulting, and training services.

For additional information on our Services please visit https://www.stefanifrim.com.

We may collect personal information in the course of our business, including through your use of our Site, when you contact us or request information from us, when you engage our Services, or as a result of your relationship with one or more of our staff and clients. When we require personal information from you in order to fulfill a statutory or contractual requirement, or where such information is necessary to enter into a contract or is otherwise an obligation, 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 ("you", "your") and are committed to protect their personal data and information according to the applicable law. This privacy policy ("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@stefanifrim.com or via mail at frimgle, Boulevard Bischoffsheim 39/4 – 1000 Brussels, Belgium.

2. Personal data we collect and/or process

Registrations, subscriptions and forms

If you register with us via the Site, sign up to receive news and information from us, or communicate with us through or related to the Site (e.g. when you fill out a 'Contact Us' form, sign up for our mailing lists), register for events we host or sponsor, submit information as part of certain online services, post comments on our blogs, or otherwise provide us information through the Sites, we may collect the following personal information:

• Your name, job title and company.
• Contact information for you, including the company you work for, email address and phone number.
• Demographic information, such as your address, preferences and interests.
• Other information relevant to the provision of Services or to your request or inquiry (such as contact preferences and interests, business affiliations).
• For events, it may include dietary restrictions, requested accommodations and other event-related preferences.

Client information

From individuals who are clients and prospective clients, or are representatives of clients and prospective clients, we may collect the following personal information:

• Your name, the named frimgle client, the name of the company you work for (if different) and your job title.
• Contact information for you, the named frimgle client, and the company you work for (if different), including address, phone number and email address.
• Relevant information as required by regulatory Know Your Client and/or Anti Money Laundering regulations and as part of our client intake procedures.
• Information you provide to us for the purposes of attending meetings and events, including dietary requirements, which may reveal information about your health or religious beliefs.
• Information that you provide to us as part of the provision of Services to you, which depends on the nature of your engagement with frimgle.
• Other information relevant to the provision of Services.

Related parties and client representatives

frimgle is primarily engaged by corporate entities and clients (i.e., legal entities), and those legal entities are not data subjects (i.e., natural persons to whom personal information relates).

However, as part of our engagement with these clients, we may receive personal information about individuals. For example, we may receive names, contact details and other information relating to:

• Officers, representatives and/or personnel of our corporate clients or prospective clients, as well as their affiliated and related entities.
• Adverse parties in a matter or potential matter, such as claimants, plaintiffs, defendants, public representatives, public servants, experts and other entities.
• Vendors and suppliers of our clients or prospective clients.
• Current and former consultants and other professional advisors or suppliers of our clients or prospective clients.
• Government and/or law enforcement entities and their representatives.

We might also need to process personal information in relation to other third parties instructed either by our own clients or other persons or companies involved in providing the Services to our client. These examples are non-exhaustive, which is reflective of the varied nature of the personal information we process as part of a professional management consulting company.

Mailings

For clients and prospects, we also collect information to enable us to market our Services and to organize events, which may be of interest to you. For this purpose, we collect:

• Name and contact details.
• Other business information, such as job title and the company you work for.
• Areas or topics that interest you.
• Additional information may be collected, such as events you attend and, if you provide it to us, dietary preferences which may indicate data about your health or religious beliefs.

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

Our processing of personal information is justified by a "legal basis", that is, a specific condition. We may use personal information for the following purposes, in each case as justified by a legal basis:

Fulfilment of Services

We use personal information to enable us to perform the Services, respond to your requests and deliver our Services, to provide growth hacking advice and related Services for which you have engaged us, and to verify your identity and carry out requests made by you on the Site or in relation to our Services.

Legal basis: This processing is necessary for our compliance with our contractual obligations with you as a Party. It is also in our 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 Site and the Services, to communicate with you about your use of the Site and Services, to respond to your inquiries, to provide troubleshooting, to fulfill your orders and requests, to bill you for our Services, and to provide other client service and support.

Legal basis: This processing is necessary to establish, exercise or defend our contractual rights and duties. It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can.

Business administration and legal compliance

We use personal information for the following business administration and legal compliance purposes: to perform conflicts of interest searches, to comply with our legal obligations, to enforce our legal rights, to investigate and/or settle inquiries or disputes, to comply with any applicable law or court order, to enforce our agreements with you, to protect the rights, property or safety of us or third parties, to maintain our records, and to process business transaction data.

Legal basis: Such processing is either necessary to comply with the legal and contractual obligations imposed upon us or in our legitimate interest.

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. We may also use it to develop new Services and determine how to market our Services.

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. We will, where required by applicable law, obtain your consent to send such communications.

Client development

We may use personal information in order to respond to Requests for Proposals ("RFPs"), prepare for and present pitches and other proposals, and identify potential business opportunities.

Legal basis: This processing is done based on our legitimate interest to develop and grow our business and Services and promote the reputation of our company.

Client insight and analytics

We use personal information to better understand how you and others use our Services, so that we can improve our Site and Services, develop new features, tools, offerings, and services, and for other research and analytical purposes.

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

Industry benchmarking and rankings

We may participate in industry surveys and reports, which clients use to assess management consulting firms. This may involve limited personal information about individuals such as referee name, title and contact.

Legal basis: It is in our legitimate interest to use your personal information in order to develop and grow our business and Services. Where required, we will obtain your consent.

Prevent misconduct, abuse and misuse

We use personal information where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our terms of engagement.

Legal basis: This processing is necessary to comply with legal obligations imposed upon us and to enforce, establish or defend our legal rights.

4. Sharing your personal data

frimgle is a management consulting company that is part of a larger network of partners and contractors. Any information that we collect or that you provide to us may be shared and processed by frimgle in the European Union.

We may also share personal information with a variety of 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.
• Professional indemnity insurers.
• Regulators, tax authorities and/or corporate registries.
• Third parties to whom we outsource certain services, such as document processing and translation services, IT systems or software providers, IT Support service providers, and document and information storage providers.
• Third parties engaged in connection with our Services, such as counsels, arbitrators, mediators, clerks, witnesses, court reporters, document review platforms and experts.
• Third party service providers to assist us with client insight analytics, such as Google Analytics.
• Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.

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 such entities have signed a data sharing agreement based on the EU standard contractual clauses.

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 Site and our Services and to collect information about how our Site is accessed and used.

The data collected is typically when users access or use the services or visit our Site, such as an IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider ("ISP"), referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked and features used.

Legal basis: It is necessary for us to perform our obligations in accordance with any contract or engagement that we may have with you. It is in our legitimate interest to use personal information in such a way to ensure that we provide the Services in the best way that we can.

6. Retention of personal data

In general, we will retain relevant personal information of Site visitors for at least two years from the date of our last interaction with you and in compliance with our obligations under applicable laws, or for longer if we are required to do so according to our regulatory obligations or professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.

We generally retain files and information regarding client engagements and matters for which we have been retained for at least seven years from the date of our last interaction with the relevant client, in compliance with our obligations under applicable laws, or for longer where required by our regulatory obligations or professional indemnity obligations.

As explained above, the Candidate Information will be processed and maintained in our records as long as your account is active and at the latest 24 months after the last contact, exchange of information or update of data.

7. Confidentiality and security of your personal data

We are committed to keeping 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.

All of our partners, employees, consultants, workers and data processors 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

You have the following rights in relation to the personal data we hold about you:

Your 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 that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to correction (rectification)

If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it corrected. If we have shared your personal information with others, we will let them know about the rectification where possible.

Your right to erasure

You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or if you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible.

Your right to restrict (block) processing

You can ask us to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If we have shared your personal information with others, we will let them know about the restriction where possible.

Your right to data portability

You have the right, in certain circumstances, to receive a copy of personal information we've obtained 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.

Your rights in relation to automated decision-making 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 for entering into, or the performance of, a contract between you and us.

Your right to withdraw consent

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.

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we've handled your personal information, 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.

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

Our Site may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites' privacy notices as frimgle has no control over information that is submitted to or collected by these third parties.

10. Children

The Site is not for use by children under the age of thirteen (13) years, and we do not knowingly collect, store, share or use the personal information of children under 13 years. If you are under the age of 13 years, please do not provide any personal information, even if prompted by the Site to do so. If you are under the age of 13 years 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 such personal information.

11. Changes to this Policy

We may make changes to this Policy from time to time, to reflect changes in our practices. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where we materially change this Policy, we will take steps to notify you (such as by posting a notice on the Site or via email), and where required by the applicable law to obtain your consent.