Published using Google Docs
Privacy Policy - 20251127
Updated automatically every 5 minutes

Privacy Policy

Last updated: November 27th, 2025

At FBCPS we care deeply about the protection of your personal data and privacy.

This Policy informs you of our policies regarding the collection and process of Personal Data we receive from users of the Services and through the browsing of our website https://www.focus-bc.com/ (hereafter the “Website”).

What is personal data?

Personal data is any information of any nature and regardless of its support, including sound and image, concerning an identified or identifiable person.

An identifiable person is defined as a natural person which may, directly or indirectly, be identified by reference to a name, identification number, location data, electronic identifiers, or to one or more specific elements of his / her physical, physiological, genetic, mental, economic, cultural or social identity.

Who is the owner of personal data?

Any natural person to whom the data relate, inter alia in a client, prospect, collaborator, candidate, partner, contact or visitor role.

What is the processing of personal data?

The processing of personal data consists of an operation or set of operations carried out upon personal data or personal data bundles, through automated or non-automated means, including, but not limited to: collection, registration, organization, conservation, alteration, retrieval, consultation, use, disclosure, limitation, elimination, and / or destruction.

Who is responsible for processing your data?

FBCPS - Business Consulting and Professional Services, Lda with registered address at Pólo Tecnológico de Lisboa - Estrada do Paço do Lumiar, nº 44 - Edifício A, R/C Dto., Lisboa and legal entity number 510174132, (hereafter “FBCPS”, "us", "we", or "our")

We operate online content, features, functionality, tools, data, software applications and APIs (the ”Services”).

Legal Framework

Your personal data shall be processed in a way to ensure compliance with the applicable legislation, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 or General Data Protection Regulation (“GDPR”) and Law no. 58/2019 of 8 August, which ensures the execution of the GDPR in Portugal.

Data Collection

While using our Services, we may ask you to provide us with certain personally identifiable information that can be collected to contact or identify you. ("Identification Data"). The information we collect, and how we collect it, may vary depending on the services you use.

Data Collected

Data Collected from Visitors

If you are a Visitor, FBCPS collects information on your use of our Website, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, cookie information, and Internet Service Provider (“Usage Data”).

In addition to this, we only collect Personal data that is reasonable or necessary to accomplish the purpose of your interaction with Services as a Visitor. You may choose not to provide this information, but you need to understand that as a result, you may not be able to engage in certain activities on the Services. Hence, the categories of personal data we collect may include:

CATEGORY

SPECIFIC DATA

Identification data

Full name, date of birth, gender, photograph (for applications)

Contact details

Email address, phone number, address (for applications)

Usage data

Training history, preferences, feedback

Technical data

IP address, browser type, operating system

Professional data

CV, professional experience (for applications)

Data Collected from Customers

If you are a Customer, when you signed up for the Services, you entered into an agreement with FBCPS to accept FBCPS’s terms of use of the Services, which includes the obligations in this Privacy Policy and our Acceptable Use Policy (“Agreement”).

As part of your use of the Services, we collect the same data as that of a Visitor above and may ask you for additional information such as usage data in relation to the Services and other information we deem relevant for the purpose of providing the Services.

When you purchase the Services, we will also collect transaction data, which may include your billing and mailing address, and other payment-related information (“Payment Information”). We describe how Payment Information may be collected and processed.

FBCPS may process your information and data as agreed to in the Agreement and according to the “purposes your data is collected” below.

With your prior consent, we may post your personal testimonials along with those of other satisfied customers on our Site in addition to other endorsements.

The information we collect from a Customer is done strictly in accordance with the Agreement and this Privacy Policy and the Acceptable Use Policy, as well as in accordance with GDPR and all legal provisions applicable.

With whom we share your Data

In order to provide you with our services, we may hire third party individuals and organizations to help us make the Services better. These third parties include our web host provider, other SaaS providers, such as an email hosting service, payment processors or outside contractors we hire to perform maintenance or assist us in securing our Services. We may also hire third parties to operate, maintain, repair, or otherwise improve or preserve our Services or its underlying files or systems.

FBCPS may disclose Personal Data only to those of its employees and third party organizations that (1) need to know such information in order to process it on FBCPS’s behalf or to provide services as described above and (2) have agreed to comply with FBCPS’s instructions regarding its processing.

Why and for what purposes your data is collected:

PURPOSE

BASIS OF LAWFULNESS

STORAGE PERIOD

Management of the contractual relationship

Contract Execution

For the duration of the contract

Communication and customer support

Performance of contract

Legitimate interest (reply to our customers or potential customers)

For the duration of the contract

Until 2 years after collection of the personal data

Human Resource Management

Pre-contractual steps

Consent (to preserve applications for analysis and selection for future vacancies)

For the duration of the contract

Until 1 years after reception of the application

Direct marketing

Consent  

Legitimate interest (make our services and products known)

Until you withdraw your consent or until 2 years after collection of consent

Until you oppose to receive marketing

Management and improvement of the WEBSITE

Legitimate interest (development and improvement of our services and products)

Consent (cookies)

While you use our services and/or Website

Until you withdraw your consent

Administrative management

Legitimate interest (allow proof and tracking of interactions and contacts)

While you use our services and/or Website

Business analysis

Legitimate interest (knowledge and development of our business)

Consent

While you use our services and/or Website

Security and fraud prevention

Legitimate interest (prevent fraud and ensure system security)

While you use our services and/or Website

Compliance with legal obligations

Legal obligation

10 years after collection of the personal data

Establishment, exercise or defence of legal claims

Legitimate interest (preservation of evidence and allowing defense in legal proceedings or similar)

For the applicable limitation period

When the processing is based on consent, you have the right to withdraw it at any time, without compromising the lawfulness of the processing carried out on the basis of the consent previously given.

When we invoke legitimate interest, we carry out a balancing assessment to ensure that we comply with the applicable law, i.e. that we do not use our legitimate interest when the interests or fundamental rights and freedoms of the data subject prevail over our interests.

Right to Access, Edit, and Remove Your Information

You have a right to access personal data we hold about you. Whenever you use our Services, we strive to make sure that the Personal Information is correct. If that information is wrong, we give you ways to update it quickly or request to delete it – unless we have to keep that information for legitimate business or legal purposes.

When updating your Personal Information, we may ask you to verify your identity before making any changes. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).

Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. Because we protect information from accidental or malicious destruction, even after information is deleted from the Services, it may not be immediately deleted from FBCPS’s servers.

To request removal of your Personal Information from our Services, contact us at support@focus-bc.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

If a User interacts with one of our Customers and the User seeks to access, or correct, amend, or delete inaccurate data or no longer wants to be contacted by one of our Customers, the User should direct its inquiry to the Customer because the Customer is the data controller. If the Customer requests FBCPS to remove the Personal Information, we will respond to their request within 30 days.

Security Measures

We take measures to enhance the security of our Services. These measures include using SSL Certificates and two-factor authentication. It is important for you to protect against unauthorized access to your password and to your computer. No security measures are perfect and we cannot promise that the information about you will remain secure in all circumstances.

Your Choices Regarding Your Personal Data

We offer you choices regarding the collection, use, and sharing of your Personal Data.

We periodically may send you free newsletters and emails that directly promote the use of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). Should you decide to opt-out of receiving future mailings, we may share your email address with third parties to ensure that you do not receive further communications from third parties. Despite your indicated email preferences, we may send you notices of any updates to our Terms of Service or Privacy Policy.

You may change any of your Personal Data in your account by editing your profile within the registration portion of our Services or by sending an email to us at the e-mail address set forth below.

You may request deletion of your account information by sending us an email to support@focus-bc.com, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). We will respond to access to Personal Data within 30 days.

When we delete account information, it will be deleted from the active database, but may remain in our archives. We will otherwise retain your information for as long as your account is active or as needed to provide you services as well as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Cookies

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.

Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Cookies can be "persistent" or "session" cookies.

How FBCPS uses cookies

When you use and access the Service, we may place a number of cookies files in your web browser.

We use cookies for the following purposes: to enable certain functions of the Service, to provide analytics, to store your preferences.

We use both session and persistent cookies on the Service, and we use different types of cookies to run the Service:

Essential cookies

We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.

Third-party cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

We use the following Cookies:

First-Party Cookies

Purpose

Name

Purpose

Retention period

Access by third parties

Necessary

_cfuvid

Cloudflare session identifier used to maintain session consistency and security protection.

Session

No

Performance

_ga

Google Analytics cookie used to identify unique visitors and collect usage statistics.

1 year 1 month 4 days

Yes (Google)

Performance

ga*

Google Analytics cookie used to store and count page views.

1 year 1 month 4 days

Yes (Google)

Third-Party Cookies

Purpose

Third party

Name

Purpose

Retention period

Necessary

Cloudflare

cfuvid (from challenges.cloudflare.com)

Ensures session continuity and protects the site from malicious traffic

Session

Necessary

Google (reCAPTCHA)

Rc::a

Identifies bots and protects forms from spam/abuse

Never (persistent)

Necessary

Google (reCAPTCHA)

Rc::c

Identifies bots during a session to prevent malicious attacks

Session

Performance

Google Analytics

_ga

Stores and counts page views

1 year 1 month 4 days

Performance

Google Analytics

ga*

Stores and counts page views

1 year 1 month 4 days

Your choices regarding cookies

If you'd like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Where can you find more information about cookies

You can learn more about cookies and the following third-party websites:

AllAboutCookies: http://www.allaboutcookies.org/

Network Advertising Initiative: http://www.networkadvertising.org/

Changes To This Privacy Policy

This Privacy Policy is effective as of November 27th 2025 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Policy, please contact us to support@focus-bc.com.