Privacy Policy

1. Introduction

sharpfocusorium SARL ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website sharpfocusorium.world or use our services.

We are the data controller for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws. Our registered office is located at Place d'Armes 70, 9012 Ettelbruck, Diekirch, Luxembourg.

2. Data We Collect

We may collect and process the following categories of personal information about you:

• Contact Information: Name, email address, phone number, company name, and postal address
• Communication Data: Records of correspondence and communications with us
• Technical Data: IP address, browser type, device information, and website usage patterns
• Marketing Data: Your preferences regarding marketing communications
• Professional Information: Business requirements, industry sector, and project details

This data collection occurs when you contact us through our website forms, email, phone, or when you engage our services for retail customer data platform consulting.

3. How We Use Your Information

We use the personal information we collect for various legitimate business purposes, including how we use your data for the following purposes:

• Responding to your enquiries and providing customer support
• Delivering our retail customer data platform consulting services
• Processing and managing service agreements and contracts
• Improving our website functionality and user experience
• Sending relevant business communications and service updates
• Conducting market research and business development activities
• Ensuring compliance with legal and regulatory requirements

The legal basis for processing your personal data includes legitimate business interests, contract performance, and your consent where applicable.

4. Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

Our website uses various types of cookies including:

• Essential Cookies: Required for basic website functionality
• Analytics Cookies: Help us understand website usage patterns
• Marketing Cookies: Used for advertising and remarketing campaigns
• Functional Cookies: Remember your preferences and settings

For detailed information about our cookie usage, please refer to our Cookie Policy.

5. Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following limited circumstances:

• With trusted service providers who assist in our business operations
• When required by law or to comply with legal proceedings
• To protect our rights, property, or safety, or that of others
• In connection with a business transfer or acquisition

All third-party service providers are bound by confidentiality agreements and data protection requirements consistent with this Privacy Policy.

6. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including:

• Contact enquiries: 3 years from last communication
• Client data: 7 years after contract completion for legal compliance
• Marketing data: Until you withdraw consent or opt out
• Website analytics: 26 months as per Google Analytics settings

Data retention periods may be extended if required for legal, regulatory, or legitimate business purposes.

7. Your Rights

Under GDPR and applicable data protection laws, you have the following rights regarding your personal information:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate information
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for consent-based processing

To exercise any of these rights, please contact us using the details provided in the contact information section below.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication procedures
• Staff training on data protection requirements
• Secure backup and recovery procedures

While we strive to protect your personal information, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

9. International Data Transfers

Your personal information may be transferred to and processed in countries outside the European Economic Area (EEA) where our service providers are located. When such transfers occur, we ensure adequate protection through:

• European Commission adequacy decisions
• Standard contractual clauses approved by the European Commission
• Other appropriate safeguards as required by applicable law

10. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us using the following details:

You also have the right to lodge a complaint with your local data protection authority if you believe we have not handled your personal information in accordance with applicable law.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you of significant changes through our website or email
• Obtain your consent where required by applicable law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. Governing Law

This Privacy Policy is governed by the laws of Luxembourg and the European Union, including the General Data Protection Regulation (GDPR). Any disputes arising from this policy shall be subject to the exclusive jurisdiction of the courts of Luxembourg.