1. PURPOSE

This Data Protection Policy applies to the personal data that IT2GO S.A. collects and uses.

References made in this Data Protection Policy to either “IT2GO S.A.”, “we”, “us” or “our” mean IT2GO S.A. (a company registered in Luxembourg with registration no. B256656 and registered office at 4, rue Belair L-4514 Differdange) and references to “you,” “your,” or “yours” refer to any person using our website, our services, or interacting with us in any way.

We determine the ways your personal data are collected and the purposes for which your personal data are used by IT2GO S.A. when we are the “data controller” as well as when we are “data processor” for the purposes arising from Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter « the Regulation »).

All data protection-related terms used in this Privacy Policy shall have the meanings given to them under the Regulation.

2. AS DATA CONTROLLER

We are acting as a Data Controller, when we collect some personal data from you, for example, when you use our website, our services or contact us.

We process your personal data only when you have given your consent, when it is necessary for the performance of a demo you have requested, or for the fulfilment of a legal obligation to which we are subject. We may process personal data on the basis of our legitimate interest only if this interest is not overridden by your rights.

For more information on the parties who may share your personal data with us, please see section 9 “Sharing your personal data” below.

3. PERSONAL DATA WE COLLECT ABOUT YOU

3.1. DATA COLLECTION

When using the term “personal data” in our Data Protection Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your personal data may include for example your name, your contact details, or information on how you use our website and apps or how you interact with us.

3.2. CATEGORIES OF DATA WE COLLECT

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

We do not collect sensitive personal data.

4. HOW AND WHY WE USE YOUR PERSONAL DATA

We use your personal data for the following purposes:

• To communicate with you and manage our relationship with you

We may need to contact you by email and/or SMS for administrative or commercial reasons, for example in order to send you confirmation of a meeting for a demo.

We will use the communications you exchange with us and the feedback you may provide in order to manage our relationship with you as our customer and to improve our services and experiences for customers.

• To improve our services, fulfil our administrative purposes and protect our business interests

The business purposes for which we will use your information include accounting, billing and audit, credit or other payment card verification, fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development.

• To comply with our legal obligations        

For example, to comply with our obligation to provide your information to national authorities where necessary.

5. COOKIES OR OTHER TRACKING TECHNOLOGIES

In order to improve our services and to analyse how visitors use our website, we may use technologies, such as cookies, pixels or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.

For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website in order to enhance the experience of the visitors to our website.

We also use cookies in our website or in our emails. Cookies are small pieces of information stored by your browser on your computer’s hard drive. They enable you to navigate on our website or app and allow us to provide features such as remembering aspects of your last search to make subsequent searches faster. You can refuse and delete cookies if you wish; while certain cookies are necessary for viewing and navigating on our website or app, most of the features will still be accessible without cookies.

Category 1: Strictly Necessary / Essential Cookies

These Cookies enable services you have specifically asked for.

These Cookies are essential in order to enable you to move around Fleetlab Website. Without these Cookies, services you have asked for, such as request for demo, may not be provided.

Category 2: Marketing/Advertising Cookies

These Cookies use information about your browsing in order to display or suggest advertising that are relevant to you.

These Cookies are used to deliver adverts that are better tailored to your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of our digital advertising campaigns. They are placed by third-party advertising networks on our behalf and with IT2GO S.A.’s permission. They remember that you have visited the Fleetlab Website and this is shared with other organisations such as media owners.

These cookies are only activated with your prior consent. You can manage or withdraw your consent at any time through our cookie settings.

6. AS A DATA PROCESSOR

In certain cases, we may process your personal data in our capacity as a Data Processor, within the meaning of the Regulation. This means we process the data on behalf of, and under the documented instructions of, another entity—hereinafter referred to as “the client”—which acts as the Data Controller.

In such cases, we do not determine the purposes or means of the processing. We act solely on the client’s instructions and in accordance with a data processing agreement, as required under Article 28 of the Regulation.

In this context, IT2GO processes the personal data processed on the behalf of the client and under the instructions of the client. The categories of personal data processed may vary depending on the services provided to the client, and may include, but are not limited to, the following: surnames, first names, email address, postal address, telephone number, IP address, logs, etc. This data concerns the customer (where applicable) of the client.

In the course of their contractual relationship, IT2GO and the client agree to comply with the Regulation and all other applicable data protection laws. A legally binding data processing agreement will be established to ensure that personal data is processed lawfully, securely, and in accordance with the Data Controller’s instructions.

7. SECURITY OF YOUR PERSONAL DATA

We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data.

The information that you provide to us will be held in our systems, which are located on our premises or those of an appointed third party. We may also allow access to your information by other third parties who act for us for the purposes described in this Data Protection Policy or for other purposes approved by you. Your personal data may be accessed by and processed outside the European Economic Area (the European Economic Area being the European Union and Iceland, Liechtenstein and Norway, also referred to as the “EEA”). Where your personal data are transferred outside of the EEA, we require that appropriate safeguards under Chapter V of the Regulation are in place, such as the European Commission’s Standard contractual clauses or the adequacy decisions.

We will retain your personal data for as long as we need it in order to fulfil our purposes set out in this Data Protection Policy or in order to comply with the law. Further information about the specific retention periods is available upon request.

8. NOTIFICATION IN THE EVENT OF A BREACH OF YOUR PERSONAL DATA

In the unlikely event there is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data (such as sending personal data to an incorrect recipient, or loss of availability of personal data), we are committed to taking an informed decision on whether to notify the relevant supervisory authority within 72 hours and yourself in the event the personal data breach is likely to result in a high risk or risk to your rights and freedoms, without undue delay.

9. SHARING YOUR PERSONAL DATA

We may disclose your personal data when this is required by the law of any jurisdiction to which IT2GO S.A. may be subject. Through our website we provide links to third party websites, which are subject to separate privacy policies. Please be aware that this Data Protection Policy does not apply to such websites and IT2GO S.A. is not responsible for your information that third parties may collect through these websites.

10. YOUR RIGHTS

To summarise, you are entitled to the following rights granted to you by the Regulation, namely:

• right to access your personal data supplied and, where applicable, obtain a copy of these data
• right to request that your data is rectified or corrected if you find them incomplete or incorrect
• right to have your data deleted, unless there is a compelling legitimate reason to justify storing them
• right to object at any time to the processing of your data including the possibility to opt-out, unless a legitimate reason prevails over your interests and rights and freedoms
• right to request that the processing of your data be limited
• right to the portability of some data, i.e. the right to receive them in a structured format that is commonly used and machine readable so they may be sent to another “Data Controller”

We shall endeavour to respond to your request promptly and within one month of receipt of the request. Depending on the complexity of the request and the number of requests to handle, we have the ability to extend this response time by two months. You shall be notified of such an extension and of the reasons for the delay within one month of receipt of the request. We reserve the right to reject the request if, on the basis of said request, we are unable to identify you or if the request is deemed excessive or unfounded. You shall be notified of the reasons for refusal within one month of receipt of the request. We may also require the payment of reasonable fees in the case of unfounded or excessive requests, especially if they are repetitive.

You can exercise your rights (e.g. request the deletion of all your personal data from our database) by sending us an e-mail to the email address, which can be found in section 12 "Contact information" below.

If you are not satisfied with the handling of your request, you may file a complaint with the Commission Nationale pour la Protection des Données (information available on the website www.cnpd.public.lu).

11. UPDATES TO OUR DATA PROTECTION POLICY

We may periodically update this Data Protection Policy to reflect changes in our data protection practices or relevant laws.

This Data Protection Policy has last been updated on: 07/04/2025.

12. CONTACT INFORMATION

Questions, comments and requests regarding this Data Protection Policy shall be addressed to our Data Protection Officer at gdpr@fleetlab.com