Privacy
Policy
Effective
Date: July 04, 2025
Virtual
Contact s.r.l. (“Virtual Contact”),
a corporation organized under the laws of Italy with a place of business at Via
Settembrini 9, Rome, 00195, ITALY, provides a cloud-based contact center
software-as-a-service (“Virtual Contact Services”) directly to customers
(“Customer(s)”, “You”) or through authorized partners.
At Virtual
Contact s.r.l. we take the protection of personal information provided to us by
our customers and website visitors very seriously. Virtual Contact regularly
reviews and updates its privacy policy, procedures, and guidelines to
strengthen its commitment to relevant Privacy and Data Protection legislation
and regulations, and better protect customers personal information when
processing personal data as a controller. Data subjects whose personal
information is processed by a customer of Virtual Contact as a data controller,
must consult that customer’s privacy policies.
Virtual
Contact must act as both a data processor and a data controller. Virtual
Contact stores and process personal information on behalf of its customers and
determines the purpose and means of the data processing (e.g. for billing
purposes).
Nothing in
this Policy has the effect of creating obligations for Virtual Contact beyond
those imposed by applicable laws and regulations pertaining to protection of
personal data.
1. Virtual
Contact as data controller
Virtual
Contact limits collection of information about Customers only to what is
relevant, proportional, adequate, and necessary for identified operating the Virtual
Contact Services. Virtual Contact considers the requirements of the
jurisdiction that govern the information collection and proceeds according to
applicable privacy & data protection legislation.
1.1
Data that Virtual Contact collects directly from Customers
Virtual
Contact collects personal information that You voluntarily provide when You
- register on the Virtual Contact
website for the Virtual Contact Services,
- request information about Virtual
Contact, Virtual Contact services and Virtual Contact products,
- request a demo of the Virtual
Contact Services,
- interact with Virtual Contact
social media campaigns via social networks,
- register
in Virtual Contact events,
- apply
for job offers,
- download Virtual Contact
software and documents, or use resources available in Virtual Contact
website or
- contact Virtual Contact using
the official contact channels available (phone, chat, email).
The
information that Virtual Contact collects is
- identification data (first
name, last name),
- contact data (business email
address, business phone number), and
- professional details
(functional role, company name, country).
When
applying for a job offer, Virtual Contact collects the information provided in
the resume, cover letter and LinkedIn profile. Virtual Contact also collects
the information that you choose to share when contacting us through our
official contact mechanisms.
1.2 Data
that Virtual Contact obtains from third-party sources
Virtual
Contact may use business contact information collected by third parties,
including your employer, reseller partners, trusted strategic alliances, and
acquired professional contacts databases. Appropriate privacy and security
assessments are performed to ensure compliance with applicable laws and
regulations and to ensure the collection of the data is lawful and uses fair
means, including the existence of notice and collection of consent for sharing
with third parties (Virtual Contact), when required by the applicable laws.
The information used is
- identification data (first
name, last name),
- contact data (business email
address, business phone number),
- professional details
(functional role, company name), and
- LinkedIn
Profile.
1.3 Data
that Virtual Contact obtains from public sources
Virtual
Contact may also collect data from publicly accessible sources such as
LinkedIn. The personal information collected is primarily identification and
contact data, and job and skills details to support recruitment processes.
1.4
Purposes of processing personal information
Some of the
purposes for processing personal information are:
- Be able to get in touch with
you to respond to your requests (information, demo, or services);
- Talent
recruitment;
- To support the sales effort,
including to getting feedback from the engagement process in a B2B
perspective;
- To send marketing information
on our products and services marketing (including telemarketing) in a B2B
perspective;
- Customer relationship and
contractual management which could include payment information;
- To provide support and
information to customers;
- Management of business
relationships with prospective customers, vendors, suppliers, resellers,
or partners;
- Events registrations (including
webinars, conferences, roundtables, and others);
- Access to our offices and
online resources for onsite or remote work;
- Provide access to Virtual
Contact training materials;
- Navigation and usage of Virtual
Contact website;
- Cookies usage (specific policy
shared on the site);
- To ensure compliance with
applicable laws and regulations, and to assert Virtual Contact’s rights or
to defend Virtual Contact against any legal claim.
Virtual
Contact collects the minimum amount of data needed for the purposes listed above.
The legal basis of each processing is to perform contractual obligations, the
advancement of a legitimate plan or interest, or with explicit consent.
Personal
data processing for the purpose of marketing or product awareness, may rely on
a legitimate interest of Virtual Contact or your consent. Virtual Contact
requires your consent according to the applicable laws but may rely on
legitimate interest when the applicable law allows and when you already have
shown Virtual Contact interest in the Virtual Contact products or Virtual
Contact Services. In communications related to marketing and/or product &
brand awareness purposes, Virtual Contact also provides a choice to opt-out of
further marketing and product awareness communications.
Virtual
Contact may conduct automated screenings against applicable sanctioned-party
lists with regard to Virtual Contact’s processing of personal data for the
purpose of export control and sanctions laws’ compliance. In case of a possible
match, Virtual Contact may ask for clarifications.
1.5
Personal information limited use, disclosure, and retention
Virtual
Contact does neither use nor process personal information for other purposes,
and does not sell or allow its sub-processors to sell personal information.
Personal information will not be processed for purposes other than those for
which it was collected, except with your consent or as required by law.
Except as
otherwise set out herein, Virtual Contact will not disclose, trade, rent, sell,
or otherwise transfer to a third person your personal information unless you
consent thereto, or such disclosure or use is provided for by law.
Virtual
Contact and its service providers may be compelled to disclose personal
information in response to a search warrant or any other legally-valid inquiry
or order, or to an investigative body in the case of a breach of an agreement
or breach of law, or as otherwise required by applicable law.
Personal
information may also be disclosed without your consent for research purposes if
the documents containing the data are not structured so as to allow retrieval
by reference to your name or identifying code or symbol and the personal
information cannot be retrieved by means of such a reference.
Any person
holding Personal Data on behalf of Virtual Contact may refer to the latter
every request for access or rectification received from an individual to whom
Personal Data relates.
Personal
information will be retained only as long as necessary for the fulfilment of
those purposes in a form which permits your identification for no longer than
is necessary for the purposes for which the personal information is processed.
1.6
Rights of data subjects
A data
subject has the following rights:
- Access data: Right to request and receive
confirmation of whether their personal data is held, and, where that is
the case, request and receive a copy of the data.
- Have data transferred: Right to receive the data
they have provided in a structured, commonly-used and machine readable
format.
- Have data rectified: Right to have their personal
data amended where it is inaccurate or added to where it is incomplete.
- Restrict processing: Right to restrict the
processing of the personal information to the extent permitted by law and
in accordance with Virtual Contact contractual and legal commitments.
- Have data erased: Right to the erasure of
personal information concerning the data subject.
- Objections: Right to object to the
processing of the data for particular reasons.
- Withdraw consent: Right to remove consent for
specific processing.
- Complaints: Right to send complaints to
the competent authority.
In
addition, data subjects have the right to opt-in to receive marketing
communication from Virtual Contact, and opt-out of email marketing messages by
clicking on the unsubscribe link in the email, and when using the Virtual
Contact website, data subjects can accept or decline cookies.
1.7
Exercise the rights
Data
subjects can exercise their rights by submitting a request to: info@virtualcontact.it
1.8
Personal information transfer
Virtual
Contact holds the right to share, transfer, or disclose personal information in
specific situations to particular categories of recipients:
- Virtual Contact’s trusted SaaS
third parties providers, acting as processors and according to Virtual
Contact instructions;
- Virtual Contact reseller
partners, trusted strategic alliances that may support Virtual Contact
sales effort and according to privacy laws and regulations;
- Virtual Contact affiliates and
according to Virtual Contact’s security and privacy policies and
applicable laws and regulation of each region;
- Government entities where the
transfer of information is legally required under local laws or required
to comply with legal requests;
- Potential buyers in connection
to a merger & acquisition or any form of transfer or sale.
Virtual
Contact does not sell and does not allow its sub-processors to sell personal
information. A list of Virtual Contact‘s processors can be requested by email
to: info@virtualcontact.it.
2 VIRTUAL
CONTACT AS DATA PROCESSOR/SUB-PROCESSOR
Virtual
Contact as a provider of a cloud-based contact center as a service solution
becomes a date processor, and occasionally a data sub-processor. At all times,
the data collected by Virtual Contact’s customers when using Virtual Contact
products is under the customer’s responsibility.
2.1
Collected Data
The
information being collected can include
- Contacts: These are usually the end
customers, or prospects, of Virtual Contact’s customers. The customer is
responsible for determining the types of contacts for which service is
provided using the Virtual Contact Services. Contacts can include the
name, phone number and email.
- Agents: These are employees of the
customer that uses Virtual Contact Services to handle incoming and
outgoing communications using different channels. Information on agents
can include the name, email address, phone number, and date of birth.
- Interactions metadata: Metadata such as a contact
phone number, agent ID and phone number, date and time, duration, and
context of the interaction.
- Interactions recordings: Audio recordings of all
audio/video calls, transcripts of all text-based interactions, files
attached and exchanged during a communication, and, when configured,
screen captures of the agent screen are collected.
- Content data: Audio recordings of all
audio/video calls, transcripts of all text-based interactions (chat,
email, SMS, WhatsApp, Facebook Messenger, Twitter, Telegram, and other
possible social media communication channels), files attached and
exchanged during a communication, screen captures of the agent screen when
configured, and call transcriptions when such functionality is used for a
customer, are collected.
Virtual
Contact restricts the collection of the information to the minimum amount
required to provide its services and it will be processed according to the
purposes for which it was collected.
2.2
Purposes of collecting personal information
Virtual
Contact collects some personal information to provide the service of Contact
Center as a Service and to support and troubleshoot issues reported by
customers.
2.3
Personal information limited use, disclosure, and retention
Virtual
Contact customers acting as data controllers define the retention period for
the information collected. On the other hand, when the contract between Virtual
Contact and a customer is terminated, the personal information is removed
according to the Master Subscription Agreement, or earlier if requested by the
customer. However, Virtual Contact may keep anonymized information (that will
not identify directly or indirectly any agent, contact, or customer) for longer
periods for analysis of how service is used and for the improvement of it.
2.4
Rights of data subjects
A data
subject has the following rights:
- Access data: Right to request and receive
confirmation of whether their personal data is held, and, where that is
the case, request and receive a copy of the data.
- Have data transferred: Right to receive the data
they have provided in a structured, commonly-used and machine readable
format.
- Have data rectified: Right to have their personal
data amended where it is inaccurate or added to where it is incomplete.
- Restrict processing: Right to restrict the
processing of the personal information to the extent permitted by law and
in accordance with Virtual Contact contractual and legal commitments.
- Have data erased: Right to the erasure of
personal information concerning the data subject.
- Objections: Right to object to the
processing of the data for particular reasons.
- Withdraw consent: Right to remove consent for
specific processing.
- Complaints: Right to send complaints to
the competent authority.
2.5
Exercise the rights
When Virtual
Contact processes information on behalf of a customer, all data subject rights
must be addressed directly to the customer.
2.6
Personal information transfer
As a
service provider/processor, Virtual Contact only uses data to provide the
service agreed and according to customer instructions and Virtual Contact does
not sell the information its customers collect while using Virtual Contact
Service.
Virtual
Contact holds the right to share, transfer, or disclose personal information in
specific situations to particular categories of recipients:
- Virtual Contact’s trusted SaaS
third parties’ providers, acting as processors and according to Virtual
Contact instructions;
- Virtual Contact reseller
partners, trusted strategic alliances that may support Virtual Contact
sales effort and according to privacy laws and regulations;
- Virtual Contact affiliates and
according to Virtual Contact’s security and privacy policies and
applicable laws and regulation of each region;
- Government entities where the
transfer of information is legally required under local laws or required
to comply with legal requests;
- Potential buyers in connection
to a merger & acquisition or any form of transfer or sale.
Virtual
Contact does not sell and does not allow its sub-processors to sell personal
information. A list of Virtual Contact‘s sub-processors can be requested by
email to: info@virtualcontact.it.
3
SAFEGUARDS
3.1
Security measures
Virtual
Contact will take the security measures necessary to ensure the protection of
the personal data processed and that are reasonable given the sensitivity of
the personal data, the purposes for which it is to be used, the quantity and
distribution of the personal data and the medium on which it is stored. The
security safeguards of Virtual Contact will protect personal data against loss
or theft, as well as unauthorized access, disclosure, copying, use, or
modification. The nature of the safeguards will vary depending on the
sensitivity of the personal data that has been collected, the amount, distribution
and format of the personal data and the method of storage.
The methods
of protection will include
- physical measures (such as
restricted access to offices);
- organizational measures (such
as security clearances); and
- technological measures (such as
the use of passwords).
Virtual
Contact provides access to personal data only to employees and authorized
intermediaries who require this personal data for the purposes described in
this policy. Virtual Contact will make its employees aware of the importance of
maintaining the confidentiality of personal data, and care will be used in the
disposal or destruction of personal data, to prevent unauthorized parties from
gaining access to the personal data.
Virtual
Contact will implement appropriate technical and organizational measures to
ensure and to be able to demonstrate that processing is performed in accordance
with applicable laws and regulations, considering the nature, scope, context,
and purposes of processing as well as the risks of varying likelihood and
severity for the rights and freedoms of natural persons. Those measures will be
reviewed and updated where necessary.
Considering
the state of the art, the costs of implementation and the nature, scope,
context and purposes of Processing as well as the risk of varying likelihood
and severity for the rights and freedoms of natural persons, Virtual Contact
will implement appropriate technical and organizational measures to ensure a
level of security appropriate to the risk, including inter alia as appropriate:
- the encryption of the databases
used by Virtual Contact service;
- the ability to ensure the
ongoing confidentiality, integrity, availability and resilience of
processing systems and services;
- the ability to restore the
availability and access to personal data in a timely manner in the event
of a physical or technical incident;
- a process for regularly
testing, assessing, and evaluating the effectiveness of technical and
organizational measures for ensuring the security of the processing.
All
personal data collected by Virtual Contact is stored on private servers which
are not accessible to the public. For increased security, authorized users must
protect access to their online accounts by selecting a password of their
choosing.
3.2
Intermediaries
Where
processing is to be carried out on behalf of Virtual Contact, Virtual Contact
will use only intermediaries providing sufficient guarantees regarding the
implementation of appropriate technical and organizational measures in such
manner that processing will meet the requirements of the applicable laws and
regulations and ensure the protection of customer’s rights. The intermediary
will not engage another intermediary without prior specific or general written
authorization of Virtual Contact. Processing by an intermediary will be
governed by a contract that is binding on the intermediary with regard to Virtual
Contact and that sets out the subject-matter and duration of the processing,
the nature and purpose of the processing, the type of personal data and
categories of individuals and the obligations and rights of Virtual Contact.
All Virtual Contact’s suppliers sign and consent to a non-disclosure agreement
regarding all the personal data. Our Virtual Contact’s suppliers agree not to
disclose any Virtual Contact or Virtual Contact’s clients’ protected
information, including personal data to any third party, whether directly or
indirectly. Where an intermediary engages another intermediary for carrying out
specific processing activities on behalf of Virtual Contact, the same data
protection obligations as set out in the contract between Virtual Contact and
the intermediary will be imposed on that other intermediary by way of a
contract. The intermediary and any person acting under the authority of Virtual
Contact or of the intermediary, who has access to personal data, will not
process those data except on instructions from Virtual Contact, unless legally
required to do so by a statutorily-empowered public authority. Virtual Contact
may transfer your personal data to intermediaries such as providers of payment
processing services. Processing of your personal data may take place in the
United States or in Italy by our affiliates and other third-party service
providers.
3.3
Notification of personal data Breach
No data
transmission over the Internet may be guaranteed to be entirely secure. As a
result, Virtual Contact does not represent, warrant or guarantee that personal
data will be protected against all loss, misuse or alteration and accepts no
liability for personal data submitted by you, nor for the use or misuse of such
personal data by you or by third parties.
Virtual
Contact will document any personal data breaches, comprising the facts relating
to the personal data breach, its effects and the remedial action taken without
undue delay and, where feasible, not later than seventy-two (72) hours after
having become aware of it, notify the personal data breach to the
statutorily-empowered public authority appropriate in accordance with
applicable laws and regulations, unless the personal data breach is unlikely to
result in a risk to the rights and freedoms of natural persons. Such
notification will at least:
- describe the nature of the
personal data breach including where possible, the categories and
approximate number of individuals concerned, and the categories and
approximate number of personal data records concerned;
- communicate the name and
contact details of the data protection officer or other contact point
where more information can be obtained;
- describe the likely
consequences of the personal data breach; and
- describe the measures taken or
proposed to be taken by Virtual Contact to address the personal data
breach, including, where appropriate, measures to mitigate its possible
adverse effects.
Virtual
Contact will communicate the personal data breach to customers without undue
delay when the personal data breach is likely to result in a high risk to the
rights and freedoms of natural persons. Such communication will describe in
clear and plain language the nature of the personal data breach, and contain at
least the information and measures referred to in points (b), (c) and (d)
above.
4 HOW TO
CONTACT VIRTUAL CONTACT
For
questions or complaints regarding this privacy policy, you can contact us:
by email
at: info@virtualcontact.it
or by mail at our address:
Virtual Contact s.r.l.
Via Luigi Settembrini, 9
00195 – Rome
ITALY
5
LANGUAGE
The parties
confirm that it is their wish that this policy be written in the Italian
language only.
Le parti confermano la loro volontà che la presente politica venga
redatta esclusivamente in lingua italiana
