Date of last revision: 30 November 2024
Hi, welcome to Get in Touch! We offer a Solution that allows you to send automated and personalized messages to Authorized Users. As your privacy is our number one priority, we have drawn up a transparent and detailed privacy policy (“Privacy Policy“).
This Privacy Policy applies to all processing activities of Get in Touch (as defined below) as the data controller.
Please read this Privacy Policy together with our other supporting & legal documents, such as Cookie Policy and General Terms and Conditions. Get in Touch may update this Privacy Policy in the future: the latest version can always be found on our Website or via our Solution.
About this privacy policy
Get in Touch may collect, store, and process personal data related to you (“your Personal Data”) as a result of actions such as visiting our website (www.getintouch.group), recent interactions with us, or your commercial relationship with Get in Touch.
This Privacy Policy describes (i) how we collect, treat and store your Personal Data; (ii) the rights you can exercise in relation to your Personal Data; and (iii) the measures we take to protect and secure your Personal Data.
Get in Touch respects your privacy and we always strive to act in accordance with the applicable privacy legislation, such as (non-exhaustive): (i) the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”); (ii) the ePrivacy Directive 2002/58/EC of 12 July 2002, including future amendments and revisions thereof; and/or (iii) (future) national legislation regarding the implementation of the GDPR (together: “Privacy Legislation”).
Get in Touch as data controller
We are Get in Touch BV, a private limited company, incorporated and existing under the laws of Belgium, with registered office at Park Ter Linden 1, 9090 Melle with company number 1012.665.647 (“Get in Touch” or “we | us”).
Get in Touch is the developer and provider of the Get in Touch Web Application which integrates with the Business Accounts of Customers across various Communication Channels to allow Customers to send automated and personalized messages to its Authorized Users (“Solution”).
In light of Privacy Legislation, Get in Touch will act as the data controller of your personal data for the purposes described in this Privacy Policy. This entails that we are in control of (and therefore responsible for) your Personal Data.
Get in Touch’ processing activities
Which personal data we collect, store and otherwise process and the purpose for which we process this data may differ depending on your relationship with Get in Touch. In particular, we identify four different scenarios:
❑ You are browsing on our Website;
❑ You (wish to) receive updates and newsletters related to Get in Touch’ services and products;
❑ You use our Solution;
❑ we or one of our partners is providing support to you.
You are browsing on our Website
| Contacting Get in Touch via the Website | |||
| Purpose: | To answer any questions you may have and/or to initiate a conversation | ||
| Personal data: | ☐ First name☐ Last name☐ Email address | ☐ Nature of inquiry☐ Voluntarily provided information☐ Telephone number | |
| Legal basis: | Consent | ||
| Retention period: | Until one (1) year following your contact with Get in Touch, or as long as necessary to handle your inquiry | ||
| Cookies | |||
| When browsing on our Website and App, we may also collect your Personal Data through cookies stored on your device(s) in order to optimize the functioning of the Website and App. Please read this Privacy Policy in conjunction with Get in Touch’ Cookie Policy | |||
You (wish to) receive newsletters and updates related to Get in Touch’ services and products
| Get in Touch’ newsletter | update | ||
| Purpose: | Providing more information on (new features of) the Get in Touch Solution and Services | |
| Personal data: | ☐ Email address | |
| Legal basis: | Consent or legitimate interest | |
| Retention period: | Until you have objected to the processing of your personal data for this purpose (cfr. Section 8 – “Right to object”) | |
You use our Solution
| Customer and Authorized User onboarding and lifecycle management | ||
| Purpose: | Managing the account of the Customer and the Authorized Users on the Solution, from onboarding (creation of the account) on the Solution until offboarding. | |
| Personal data: | ☐ First name☐ (Business) email address☐ Home address☐ Date of birth☐ Phone Number☐ GPS Location | ☐ Last name☐ Company Name☐ Proof of address☐ Gender☐ ID data☐ Device OS☐ User IDs |
| Legal basis: | Necessary to enter into or perform an agreement | |
| Retention period: | For the duration of the Agreement. Retention up until six (6) months (max.) following termination of the Agreement. | |
| SupportBug fixesPurpose:To enable communication with & to provide support to Users via our service agentsPersonal data:☐ First name (if voluntary provided)☐ Last name (if voluntary provided)☐ Email address☐ Telephone number☐ Language☐ Voluntarily provided informationLegal basis:Necessary for the performance of the agreementRetention period:Until closure of the bug fix has been completed. Data may be further retained in anonymized / statistical format for development and service optimization purposes.User support |
| Purpose: | Analysing and fixing detected bugs in the Solution. | |
| Personal data: | ☐ Device / phone information (category, brand name, model name, marketing name, operating system (version)) | |
| Legal basis: | Necessary for the performance of the agreement | |
| Retention period: | Until closure of the bug fix has been completed. Data may be further retained in anonymized / statistical format for development and service optimization purposes. | |
Legal bases for processing
You can find more information on the applicable legal basis for each of the identified processing activities in Section 3 above.
In case the legal basis for processing happens to be legitimate interest, Get in Touch shall always (i) assess whether this is in proportion with the purpose for which your Personal Data was collected and used; and, (ii) take your reasonable expectations into account and ensure a balance with your fundamental rights and freedoms. If we cannot guarantee this, we will stop processing your Personal Data or justify processing on a different legal basis.
Retention period
You can find more information on the retention period of your Personal Data for each of the identified processing activities in Section 3 above.
We do not process your Personal Data any longer than necessary for the purposes set forth in this Privacy Policy. We do store your Personal Data as long as your account is active or when the processing of your Personal Data is necessary to allow you to make use of our Solution or App. If you want to receive a more detailed description of our different data retention periods, you can always contact info@getintouch.group.
Sharing of personal data with third parties
Get in Touch shall not disclose your Personal Data to other third parties, unless it is necessary to achieve the purposes described in this Privacy Policy. In this respect, (some of) your Personal Data may be disclosed to hosting companies (hosting our online platforms), technology / marketing tool companies (helping us manage our customers and deliver messages) and analytics companies (helping us improve your experience on our website) (“Sub-processors”).
Of course, we have made sure that the necessary agreements or similar legal binding acts are in place to ensure that these third parties treat your Personal Data in accordance with the Privacy Legislation (e.g. Article 28 GDPR).
In addition, Get in Touch may disclose your Personal Data:
- To the competent authorities: for instance (i) if Get in Touch is obliged to do so under the law or under legal or future legal proceedings, and (ii) to safeguard and defend our rights;
- In M&A context: meaning, if Get in Touch or the majority of its assets, is taken over by a third party, in which case your Personal Data – which Get in Touch has collected – may be one of the transferred assets on in the context of a material investment in Get in Touch or any of its affiliates.
Get in Touch shall not transfer, sell, hire out or pass on your Personal Data to third parties for purposes outside the purposes listed in this Privacy Policy, such as, but not limited to marketing purposes, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your Personal Data.
Transfers of personal data to third countries
In case any of the above-mentioned Sub-processors or other recipients are located in a country outside the European Economic Area, Get in Touch will ensure that one or more of the listed EU-approved safeguards are in place:
- European Commission adequacy decision;
- Data transfer agreement (cfr. the Standard Contractual Clauses as provided in the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, including the performance of a transfer impact assessment);
- Binding corporate rules; or,
- Certification mechanisms.
Every transfer to a third country, not recognized by an adequacy decision, is subject to an assessment by Get in Touch to determine if there is anything in the law and/or practices in force of said third country that may infringe on the effectiveness of the appropriate safeguards in place (as identified above).
Where required on the basis of aforementioned assessment, Get in Touch shall identify and implement appropriate supplementary measures to govern any data transfer to such international organization or a third country without an adequacy decision to ensure the level of data protection as required by EU law.
Furthermore, Get in Touch shall take all reasonable efforts to implement sufficient guarantees and measures to protect the Personal Data and ensure the effectiveness of the protection of the SCC’s, binding corporate rules and/or certification mechanisms.
Your privacy rights
The Privacy Legislation grants certain rights over your Personal Data in relation to Get in Touch. You can exercise these rights by contacting us at info@getintouch.group. In light of the processing of your Personal Data, you enjoy the following privacy rights:
| Access: | you can ask for confirmation of whether or not personal data that relates to you is being processed. If so, you can ask us to give you copies of your Personal Data in structured and commonly used, machine-readable format; |
| Rectification: | you can ask us to correct or complete any information you believe is inaccurate or incomplete; |
| Erasure: | you can ask us to erase your Personal Data, under certain conditions. Please be aware that in this context certain services will no longer be accessible and/or can no longer be provided; |
| Objection: | you can object to us processing your Personal Data, without any justification and/or the transmission of your Personal Data to third parties. We are not legally obliged to comply with your request if we can prove that we have compelling legitimate grounds which override your interests, rights and freedoms. When your Personal Data is used for direct marketing purposes, you have an absolute right to object to this processing activity. |
| Restriction of processing: | you can ask us to temporarily halt or “freeze” the processing of your Personal Data, e.g. when it is disputed whether your Persona Data was processed lawfully. |
| Data portability: | you can ask us to transfer your Personal Data to another controller, or directly to you in a commonly used structured format readable by automatic device, under certain conditions. |
Updates | Newsletters. If you no longer wish to receive any of our communications, you can object to these direct marketing communications by contacting us via email at info@getintouch.group or by clicking the unsubscribe link in the footer of the email. Upon receipt of your objection, we will stop processing your Personal Data for Get in Touch’ communications.
When submitting a request to exercise your rights, Get in Touch may ask for additional information to identify yourself.
If processing your request requires unreasonable measures (e.g. it is technically or organisationally almost impossible or extremely costly) then Get in Touch can charge you reasonable compensation in light of the administrative costs involved in fulfilling the request. Get in Touch can also refuse to process requests that are excessive, particularly due to their repetitive nature.
Security of personal data
The security and safety of your Personal Data is Get in Touch’ top priority. Get in Touch implements a variety of technical and organizational measures designed to protect your Personal Data from (i) unauthorized access or disclosure and (ii) loss, abuse or alteration. However, Get in Touch is not in a position to guarantee absolute security.
The security of your account will also partly depend on the confidentiality and complexity of your password. You may not disclose to or share with any third parties your account. Get in Touch therefore strongly advises you, if you observe that someone has accessed your account or if your account has the risks being hacked, to immediately change your password and contact us at info@getintouch.group.
Get in Touch uses its best efforts to protect the confidentiality and security of your Personal Data. In case of Personal Data breaches, Get in Touch undertakes to notify the Data Protection Authority without delay and, if possible, not later than 72 hours after becoming aware of such Personal Data breach (if required by the Privacy Legislation).
Get in Touch shall in no event be liable for any direct or indirect damages that result from a wrong or illegal handling by third parties.
Updates
We reserve the right to modify this Privacy Policy at any time. Any changes to the Privacy Policy will be published in the Solution and on the Website. In case of significant changes to the Privacy Policy that results in Get in Touch using your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a notice in the Solution and/or send you an email notification.
Notifications and questions
Notifications under this Privacy Policy (such as exercising your data subject rights) and/or questions or complaints about the implementation of this Privacy Policy should be directed at info@getintouch.group.
Complaints
Are you dissatisfied with how we collect, store or otherwise treat or secure your Personal Data? We are sorry to hear that and are prepared to take all measures to remedy this situation. Please contact us and we will try to help you to the best of our ability.
You also have the right to lodge a complaint with the authorized supervisory authority (i.e. the Belgian Data Protection Authority or the data protection authority of (i) your residence or (ii) your workplace) should you consider that the processing of your Personal Data infringes the Privacy Legislation. You can send an email to the Belgian Data Protection Authority at contact@apd-gba.be or contact them via regular mail at Drukpersstraat 35, 1000 Brussels, Belgium. You can also call the Belgian Data Protection Authority: +32 (0)2 274 48 00.
If you would like to receive more information on how to contact them, please visit this webpage: https://www.gegevensbeschermingsautoriteit.be/contact.
Relevant links to related documents
You can consult our Cookie Policy here.
You can consult our General Terms and Conditions here.
