Privacy Policy
How we collect, use, and protect your personal data.
Last updated: 22 February 2026
1. Data Controller
GenioCT BV, registered in Belgium under enterprise number BE 1004.528.733. You can reach us at info@genioct.be.
2. What Data We Collect
We may collect the following personal data:
- Send a Message: Contact form submissions: your name, email address, company name (optional), and message.
- Analytics: Analytics data: anonymised usage data collected via Google Analytics (GA4), only with your consent.
- Server logs: Server logs: IP address, browser type, and access timestamps collected automatically by our hosting infrastructure.
3. Purposes and Legal Bases
We process your data for the following purposes:
- To respond to your enquiry (legitimate interest, Art. 6(1)(f) GDPR).
- To analyse website traffic and improve our services (consent, Art. 6(1)(a) GDPR).
- To ensure the security and proper functioning of our website (legitimate interest, Art. 6(1)(f) GDPR).
4. Recipients and Processors
Your data may be processed by the following third parties acting as data processors:
- AWS: Amazon Web Services (AWS): hosting (S3, CloudFront), email delivery (SES), and serverless functions (Lambda) in the eu-west-1 (Ireland) region.
- Google Analytics: Google Analytics: website analytics, only when you consent to analytics cookies.
- Microsoft Clarity: Microsoft Clarity: heatmaps and session recordings, only when you consent to analytics cookies.
- ip-api.com: ip-api.com: geographic lookup of your IP address for fraud prevention when submitting the contact form.
5. International Transfers
Our infrastructure is hosted within the EU (AWS eu-west-1, Ireland). Google Analytics may transfer data to the United States under the EU-U.S. Data Privacy Framework. We do not transfer your data outside the EEA without appropriate safeguards.
6. Retention Periods
- Contact form data: forwarded to us via email, not stored on our servers.
- Analytics data: retained for 14 months by Google Analytics.
- Server logs: retained for 30 days.
7. Your Rights
Under the GDPR, you have the right to:
- Access your personal data
- Rectify inaccurate data
- Request erasure of your data
- Restrict processing
- Data portability
- Object to processing
- Withdraw consent at any time (without affecting the lawfulness of prior processing)
8. How to Exercise Your Rights
To exercise any of these rights, please contact us at info@genioct.be. We will respond within 30 days.
9. Right to Complain
If you believe your rights have been violated, you may lodge a complaint with the Belgian Data Protection Authority (GBA/APD):
Drukpersstraat / Rue de la Presse 35, 1000 Brussels
www.dataprotectionauthority.be
10. Changes to This Policy
We may update this policy from time to time. The "last updated" date at the top indicates the most recent revision.