Privacy Statement

Data controller

The data controller responsible for the processing of personal data described in this statement is:

This website

This website uses Umami, a privacy-focused, open-source web analytics tool, to collect anonymous usage statistics. Umami does not use cookies and does not collect any personally identifiable information. However, visitor IP addresses are processed to determine approximate geographic location and to count unique visitors. IP addresses are not stored in raw form and are not used for tracking individual users across sessions.

The analytics data collected includes: pages visited, referrer URLs, browser type, operating system, device type, screen resolution, and approximate geographic location derived from IP addresses. This data is used solely to understand how the website is used and to improve its content and performance.

Our web server also produces standard server logs as part of normal hosting operations. These logs may include your IP address, browser type, operating system, and the pages you accessed, along with timestamps. This data is retained for a short period for security and technical troubleshooting purposes only and is not shared with third parties.

Legal basis: Legitimate interests (Article 6(1)(f) GDPR) — specifically, maintaining the security and correct operation of the website and understanding aggregate usage patterns to improve our services.

News subscription service

We operate a news digest subscription service at subscriptions.almo-consulting.be. When you subscribe, you provide your name and email address and select your preferred news topics, sources, delivery schedule, and timezone. This data is used to curate and deliver personalised news digests to your inbox.

The personal data we process for this service includes:

• Account data — your name and email address, used to identify your subscription and deliver digests.
• Preferences — your selected topics (including any custom topics you define), news sources, delivery schedule (weekday and weekend times), and timezone, used to personalise the content and timing of your digests.
• Delivery records — a log of which digests were sent to you and which articles they contained, used to avoid sending duplicate content.

The service allows you to define custom topics using free-text fields. We ask that you do not enter personal data — whether your own or anyone else's — into these fields. Custom topics are used solely to match relevant news articles and are not designed for collecting personal information. ALMO Consulting BV does not monitor the content of custom topics for personal data and accepts no responsibility for personal data voluntarily entered into free-text fields beyond what is necessary to operate the service.

You can view and modify all of your personal data at any time through the subscription management portal. You can also unsubscribe at any time using the link included in every digest email or through the portal.

Authentication: The subscription service supports sign-in via Microsoft Entra ID (formerly Azure Active Directory) as an alternative to email-based verification. If you choose to sign in with Microsoft, your Microsoft account identifier is stored and linked to your subscription to enable seamless authentication. No other data from your Microsoft account is retained. Microsoft's processing of your data is governed by Microsoft's Privacy Statement.

Email delivery: Digest emails are sent from subscriptions@almo-consulting.be via Microsoft 365 SMTP infrastructure. Your email address is used solely for the purpose of delivering your subscribed digests, verification emails, and service communications.

Data retention: Your subscription data is retained for as long as your subscription is active. If you unsubscribe, your personal data — including your name, email address, preferences, and delivery history — is automatically and permanently deleted 30 days after unsubscription.

Legal basis: Consent (Article 6(1)(a) GDPR) — you actively subscribe to the service; and performance of a contract (Article 6(1)(b) GDPR) — processing your data is necessary to deliver the news digest service you requested.

Contact and enquiries

If you contact us by email or telephone, we will process the personal data you provide — such as your name, email address, and the content of your message — solely to respond to your enquiry.

This data is not shared with third parties and is retained only as long as necessary to handle your enquiry and any follow-up correspondence.

Legal basis: Legitimate interests (Article 6(1)(f) GDPR) — specifically, responding to unsolicited business enquiries; or, where a contractual relationship follows, performance of a contract (Article 6(1)(b) GDPR).

Project work

Where ALMO Consulting BV is engaged as a consultant or service provider by a client, the client is typically the data controller for any personal data processed in the context of that engagement. ALMO Consulting BV acts as a data processor in those circumstances and processes personal data only on the documented instructions of the client.

Where ALMO Consulting BV acts as a data controller in its own right — for example, in managing its own client relationships, contracts, and invoicing — personal data is processed strictly for those purposes and retained only for the duration required by the contract and applicable legal obligations.

Personal data processed in the context of project work is not shared with third parties unless this is explicitly required to deliver the agreed services, in which case the identity of the third party, the reason for sharing, and their role (recipient or processor) will be communicated to you.

Legal basis: Performance of a contract (Article 6(1)(b) GDPR); compliance with a legal obligation (Article 6(1)(c) GDPR); or legitimate interests (Article 6(1)(f) GDPR), depending on the nature of the processing activity.

Your rights

Under the General Data Protection Regulation (GDPR — Regulation 2016/679/EU), you have the following rights in relation to your personal data:

• Right of access — to obtain confirmation of whether we process your data and to receive a copy of it.
• Right to rectification — to have inaccurate data corrected or incomplete data completed.
• Right to erasure — to request deletion of your data where there is no longer a lawful basis for processing it.
• Right to restriction — to request that we limit processing of your data in certain circumstances.
• Right to object — to object to processing based on legitimate interests.
• Right to data portability — to receive your data in a structured, commonly used, machine-readable format where processing is based on consent or contract.
• Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at info@almo-consulting.be. We will respond within one month of receiving your request. For the news subscription service, you can exercise your rights to access, rectify, and delete your data directly through the subscription management portal.

Right to lodge a complaint

If you believe that the processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the competent supervisory authority. In Belgium, this is the Gegevensbeschermingsautoriteit (GBA) — the Belgian Data Protection Authority:

You may also lodge a complaint with the supervisory authority of the EU member state in which you habitually reside or work, or in which the alleged infringement took place.

Data security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures are reviewed and updated as necessary in line with best practices and applicable requirements.

All personal data is included in daily automated backups to ensure availability and recoverability in the event of a technical failure. Backups are stored securely and subject to the same access controls as the primary data.

Changes to this statement

We may update this privacy statement from time to time. The date at the top of this page reflects when it was last revised. We encourage you to review this page periodically.

For any questions about this statement or about how we handle your personal data, please contact us at info@almo-consulting.be.