Privacy policy
This policy is published by Focusring B.V. (KvK 98468359), the controller for the personal data described here. You can reach us at hello@focusring.io.
focusring.io may collect and utilize the following types of personal information:
- Information you provide to us for the purpose of processing a business transaction.
- Information you provide through contact forms or external downloads, such as name, email address, phone number, postal address, and company information to request details about our software or services.
- Information you provide when you order an audit online, described in the next section.
Where permitted, focusring.io may collect information about certain individuals and companies obtained from third parties. This helps us keep our records up to date, expand and analyze our database, identify new clients, and offer products and services that may interest you.
Use of Personal Data
focusring.io may use your personal data to:
- Process your request regarding our software or services, including the downloading of white papers.
- Collect or send you statements, invoices, or payments.
- Provide you with relevant marketing communications such as email newsletters, marketing information, and service offers, in compliance with applicable laws or as requested by you.
Audit orders
When you order an audit through focusring.io, we process:
- your contact details: name, email address, optional phone number, and an optional separate invoice email address;
- your company details: legal name, address, country, VAT number or company registration number, and an optional purchase order number;
- your order: the product to test, its addresses, the scope, the package, the turnaround, how we get access (login address, test username, multi-factor setup, roles), which actions we may and may not perform, and any test data you give us;
- test passwords and other secrets for a login-protected product. You enter these on your private audit page after payment. They are encrypted as soon as they reach us, so that only the machine performing the audit can read them, and they are deleted 30 days after delivery;
- your payments: amounts, currency, payment method, the payment provider's references and the payment authorisation for the balance. We never see or store full card or bank account numbers;
- your private audit page: a hash of its secret link, a hash of the password you may set on it, and a record of failed unlock attempts to block guessing;
- if you arrived through an ad and accepted marketing cookies: the ad click identifier and your consent choice.
We use this data to perform the audit you ordered, to charge the agreed amounts and send invoices, to show you the progress and the report, and to keep our tax records. The legal basis is the performance of our agreement with your organisation and, for invoices and payment records, our legal obligation to keep them. The ad click identifier is processed only with your consent.
We keep invoices and payment records for 7 years, as Dutch tax law requires. We delete test passwords and secrets 30 days after delivery. We keep the order, the report and the private audit page for 2 years after delivery, so that you can still use the report and so that a re-audit can build on it; you can ask us to delete them earlier. If people who test for us may see personal data inside your product, we process that data on your behalf under a data processing agreement, and only as far as testing requires.
Security
All personal information you provide to us is kept secure and confidential. focusring.io shares personal data only with the processors listed below, under data processing agreements, and never sells it. We adhere to industry standards to protect the information you provide to us. We securely store your information during transmission and once received, safeguarding it against loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, we cannot guarantee the elimination of all risk of misuse of your personal data by others with malicious intent. Please keep your login details secure and contact us immediately if you notice any unauthorized use of your password or other security breaches.
We may disclose your personal and/or user information if requested by law enforcement or any other regulatory or government authority investigating suspected illegal activities.
Service providers
focusring.io uses the following processors, each bound by a data processing agreement:
- Postmark (United States, under Standard Contractual Clauses) delivers the confirmation and notification emails sent from the contact form and the emails about your audit order.
- Mollie (Netherlands) processes your payments, stores the payment authorisation for the balance, and sends your invoices. As a licensed payment institution, Mollie is also responsible for some payment data under its own privacy statement.
- Railway (United States, with our database hosted in its European region, under Standard Contractual Clauses) hosts the database with your orders and your private audit page.
- Vercel (United States, under Standard Contractual Clauses) hosts this website and your private audit page.
- Cloudflare Turnstile (United States, under Standard Contractual Clauses) checks that the order form is not submitted by a bot, without a puzzle.
- Laposta (Netherlands) stores newsletter subscriptions together with the consent given on the form. For the newsletter we process your email address, language, IP address and the time of the request. You can withdraw your consent at any time through the unsubscribe link in every newsletter or by emailing hello@focusring.io.
- Plausible Analytics provides aggregated, cookieless visitor statistics hosted in the European Union. It does not collect personal data or track visitors across websites.
- Google Analytics and Google Ads (United States, under the EU-US Data Privacy Framework) run on focusring.io only after you accept marketing cookies. They measure which ads lead to visits and orders. When an order is paid after you accepted, we report that conversion to Google Ads with the ad click identifier, the order value and your consent choice.
Cookies
focusring.io sets one functional cookie to remember your cookie choice for six months. Google Analytics and Google Ads set their cookies only after you accept, and you can change your choice at any time through "Cookie settings" at the bottom of every page. Your private audit page sets only a functional session cookie after you open it or unlock it with your password, and loads no analytics.
Your rights
You can ask us for access to, correction or deletion of your personal data, ask us to restrict its use, object to it, or ask for a copy in a portable format, by emailing hello@focusring.io. Where we rely on your consent, you can withdraw it at any time. If you think we handle your data wrongly, you can complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens (opens in a new tab)).
Policy Updates
focusring.io may update this privacy policy by posting a new version on our website. For the latest version of our policy, please visit our website.