Privacy Policy
Last updated: February 14, 2026
1. Data Controller
BUSINESS BOOSTER ITALIA S.R.L.
Via Fabio Filzi 20, 66034 Lanciano (CH), Italy
Email: privacy@getcloser.chat
This privacy policy describes how personal data is processed for users who use the GetCloser platform (hereinafter the "Service"), accessible at app.getcloser.chat, in compliance with Regulation (EU) 2016/679 (GDPR) and applicable Italian data protection legislation.
2. Definitions
GetCloser is a CRM (Customer Relationship Management) platform that enables businesses to manage communications with their customers through WhatsApp Business API, email, and artificial intelligence tools.
For the purposes of this privacy policy:
- User: the natural person who accesses and uses the GetCloser platform (business owner, administrator, or team operator).
- User's Customer: the natural person whose contact data is managed by the User within the platform (CRM contacts).
3. Roles in Data Processing
Business Booster Italia S.R.L. acts as:
- Data Controller for User data (registration, access, platform usage).
- Data Processor for the data of Users' Customers, which is entered and managed by the User. In this case, the User is the Data Controller of their own customers' data and must ensure they have an adequate legal basis for processing such data.
4. Data Collected
4.1 User Data
| Category | Data | Purpose |
|---|---|---|
| Registration data | First name, last name, email, password (hashed) | Account creation and management |
| Billing data | Company name, VAT number, address, payment details (managed by Stripe) | Service provision and invoicing |
| Usage data | Access logs, IP addresses, browser type, pages visited | Security, diagnostics, and service improvement |
| Preferences | Account settings, notification preferences, channel configurations | Service personalization |
4.2 Users' Customers Data
| Category | Data | Purpose |
|---|---|---|
| Contact data | Name, phone numbers, email addresses, custom fields | CRM contact management |
| Communications | WhatsApp messages, emails, notes, attachments | Conversation management |
| Commercial data | Deals, tasks, pipeline stages | Sales cycle management |
| Tags and classifications | Tags, lead sources, contact stage | Organization and segmentation |
5. Legal Basis for Processing
Users' personal data is processed on the basis of:
- Performance of a contract (Art. 6.1.b GDPR): processing is necessary to provide the Service requested by the User.
- Legal obligation (Art. 6.1.c GDPR): to fulfill tax and accounting obligations.
- Legitimate interest (Art. 6.1.f GDPR): to ensure platform security, prevent abuse, and improve the service.
- Consent (Art. 6.1.a GDPR): for sending commercial communications related to GetCloser, where applicable.
6. Artificial Intelligence
GetCloser integrates artificial intelligence features to provide response suggestions, conversation analysis, and automated assistance tools. These features are delivered through OpenAI APIs (OpenAI, L.L.C., headquartered in the United States).
The data sent to OpenAI consists exclusively of the message content necessary to generate the requested suggestion. OpenAI acts as a sub-processor and does not use data transmitted via API to train its models, in accordance with its API usage policy.
The User may disable AI features from their account settings at any time.
7. WhatsApp Business API Integration
GetCloser uses Meta's official APIs (WhatsApp Cloud API) to enable the sending and receiving of WhatsApp messages. Messages pass through the servers of Meta Platforms, Inc. (headquartered in the United States) before being delivered to the recipient.
The User is responsible for obtaining consent from their Customers for sending messages via WhatsApp, in compliance with applicable regulations and Meta's policies.
8. Sub-processors
To provide the Service, the Data Controller engages the following sub-processors:
| Provider | Location | Function |
|---|---|---|
| Supabase, Inc. | United States | Database, authentication, file storage |
| Vercel, Inc. | United States | Web application hosting |
| Meta Platforms, Inc. | United States | WhatsApp Business API |
| OpenAI, L.L.C. | United States | Artificial intelligence services |
| Stripe, Inc. | United States | Payment processing |
All sub-processors listed above are headquartered in the United States. The transfer of personal data to the United States is carried out on the basis of the EU-U.S. Data Privacy Framework (DPF) or, where applicable, the Standard Contractual Clauses (SCCs) adopted by the European Commission, pursuant to Art. 46.2.c GDPR.
9. Data Retention
Personal data is retained for the period strictly necessary to fulfill the purposes for which it was collected:
- Account data: for the entire duration of the contractual relationship and for 10 years following its termination, for tax and accounting obligations.
- Users' Customers data: for the entire duration of the User's use of the Service. In the event of account deletion, data is erased within 30 days, unless otherwise required by law.
- Access logs: retained for a maximum of 12 months for security purposes.
- Billing data: retained for 10 years as required by Italian tax legislation.
10. Push Notifications
GetCloser may send push notifications through the User's browser to provide real-time alerts about new messages received. To enable this feature, the User must explicitly grant permission through their browser. The technical data required for sending notifications (endpoint, encryption keys) is stored in the platform's database and associated with the User's account. The User may revoke this permission at any time from their browser settings or account settings.
11. Cookies and Similar Technologies
GetCloser uses only technical and session cookies that are strictly necessary for the operation of the platform:
- Authentication cookies: to maintain the active User session.
- Preference cookies: to store interface settings (e.g., table/kanban view).
No profiling or third-party cookies are used for advertising purposes. Therefore, a cookie banner is not required.
12. Data Subject Rights
In accordance with Articles 15-22 of the GDPR, the User has the right to:
- Access (Art. 15): obtain confirmation of whether personal data is being processed and access such data.
- Rectification (Art. 16): request the correction of inaccurate data or the completion of incomplete data.
- Erasure (Art. 17): request the deletion of personal data, within the limits provided by law.
- Restriction (Art. 18): request the restriction of processing under certain circumstances.
- Data portability (Art. 20): receive personal data in a structured, commonly used, and machine-readable format.
- Objection (Art. 21): object to processing based on legitimate interest.
- Withdrawal of consent (Art. 7.3): withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise these rights, the User may send a request to privacy@getcloser.chat. The Data Controller will respond within 30 days of receiving the request.
The User also has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) (www.garanteprivacy.it).
13. Data Security
The Data Controller implements appropriate technical and organizational measures to protect personal data from unauthorized access, loss, destruction, or alteration, including:
- Encryption of data in transit (HTTPS/TLS) and at rest.
- Secure authentication with password hashing.
- Role-based access control (owner, admin, operator).
- Row Level Security (RLS) at the database level for data isolation between tenants.
- Regular database backups.
- Continuous infrastructure monitoring.
14. Changes to This Privacy Policy
The Data Controller reserves the right to modify this privacy policy at any time. Any material changes will be communicated to Users via email or a notice within the platform. The date of the last update is indicated at the top of this document.
15. Contact Information
For any questions or requests regarding the processing of personal data, you may contact the Data Controller at the following address:
BUSINESS BOOSTER ITALIA S.R.L.
Via Fabio Filzi 20, 66034 Lanciano (CH), Italy
Email: privacy@getcloser.chat