Privacy Policy
Version: 12 October 2026
This policy describes how the two companies that trade as ITGRATE handle personal data on www.itgratevn.com. It covers this website as it currently operates. We keep it accurate: when the processing described here changes, we change this page and update the date above.
Contents
- 1.Who is responsible for your data
- 2.Applicable law
- 3.Contact form
- 4.Booking a call
- 5.Emails
- 6.Hosting, delivery and technical connection data
- 7.MVP enquiries: referral to a partner
- 8.Cookies
- 9.Tracking, analytics and third-party content
- 10.Retention at a glance
- 11.Your rights
- 12.No automated decision-making
- 13.Changes to this policy
1. Who is responsible for your data
Two companies trade under the ITGRATE name, and which of them is the controller of your personal data depends on where the work is for.
For customers and enquiries in Germany, Austria and Switzerland, the controller is:
ITGRATE GmbH Lucile-Grahn-Straße 48, 81675 München, Germany Register court: Amtsgericht München, HRB 255186 Email: [email protected]
For customers and enquiries everywhere else, the controller is:
CÔNG TY TNHH ITGRATE VIỆT NAM (in English: ITGRATE Vietnam Limited Liability Company) 37 Hoàng Diệu, Phường Xóm Chiếu, Thành phố Hồ Chí Minh, Việt Nam Enterprise and tax code: 0316879820 Legal representative: Nguyễn Ngọc Bảo Email: [email protected]
This website is operated by ITGRATE GmbH, and an enquiry you send through it reaches ITGRATE GmbH first. If the engagement you are asking about lies outside Germany, Austria and Switzerland, CÔNG TY TNHH ITGRATE VIỆT NAM takes your enquiry over from that point and is the controller for it. If you want to know which of the two companies holds your data at any time, ask us at [email protected] and we will tell you.
Representative in the EU under Article 27 GDPR, for CÔNG TY TNHH ITGRATE VIỆT NAM: ITGRATE GmbH, Lucile-Grahn-Straße 48, 81675 München, Germany. You may contact the representative on any question about the processing of your personal data by CÔNG TY TNHH ITGRATE VIỆT NAM.
Neither company has appointed a data protection officer. Please send all data protection enquiries to [email protected].
2. Applicable law
The General Data Protection Regulation applies to the processing described on this page.
ITGRATE GmbH is established in Germany, so the Regulation applies to its processing directly (Article 3(1) GDPR).
CÔNG TY TNHH ITGRATE VIỆT NAM is established outside the European Union and offers its services to companies in the European Union, so the Regulation applies to its processing of personal data relating to people who are in the Union (Article 3(2)(a) GDPR). It has designated an EU representative, named in section 1.
3. Contact form
What we collect
The contact form on this website asks for your first name, your last name, your email address and your message. All four are required; without them we cannot answer you. You are under no legal obligation to give us this data, and you are welcome to email us at [email protected] instead.
The form asks for nothing else. There is no checkbox on it, and we do not ask you to agree to marketing in order to send it.
Purpose
We process the details you provide in order to answer your enquiry and to discuss a possible engagement with you. We also use them internally to manage and review the enquiries we receive. We do not process your details for any other purpose, and we do not sell your data.
Legal basis
Article 6(1)(b) GDPR (steps taken at your request prior to entering into a contract). Where no contractual relationship is in prospect, we rely on Article 6(1)(f) GDPR (our legitimate interest in responding to business enquiries). Our internal review of the enquiries we receive rests on that same legal basis.
Recorded with your enquiry
The time you submitted it, and the technical connection data described in section 6. We do not add anything else to it. We do not record which page you came from, which search term or campaign brought you here, or which website linked to you, and we do not derive anything from your email address. If you have consented to analytics, Google Analytics separately receives a notice that a contact form was sent, and on which page (see section 9). It never receives what you entered in the form.
Where it is stored
Your enquiry is received and stored by this website's own system. We do not pass it to a separate customer relationship management service, and no third-party form or survey service is involved in collecting it.
Who can see it
Only the people who need your enquiry in order to answer it and to prepare a possible engagement — that is, the responsible people in sales and project management at the two companies named in section 1.
Our delivery teams work in Vietnam. So your enquiry may be seen by colleagues at CÔNG TY TNHH ITGRATE VIỆT NAM even in cases where ITGRATE GmbH is the controller, and your personal data is then processed outside the European Union. You can obtain details of the safeguards that apply to that processing on request from [email protected].
Retention
If no contract results, we delete your enquiry 24 months after the last contact. If a contract results, statutory commercial and tax retention periods apply.
4. Booking a call
Our website links to an appointment booking page operated by Google, at calendar.app.google. If you follow that link you leave this website, and the page you arrive at is Google's. Google's own privacy policy applies to it, not this one.
If you book a call there, we receive the booking and the details you entered — typically your name, your email address, the slot you chose and any note you add. We process those details in order to hold the call you asked for and to prepare a possible engagement. The legal basis is Article 6(1)(b) GDPR.
Booking through Google involves your details being processed outside the European Union. You can obtain details of the safeguards that apply to that processing, and of our arrangement with Google, on request from [email protected].
Retention of a booking: as in section 3 — 24 months after the last contact where no contract results.
We do not embed the booking tool in this website. Nothing from it loads on this page, and it sets nothing on your device unless you follow the link.
5. Emails
We reply to your enquiry personally, from a mailbox at itgratevn.com.
We send no newsletter and no marketing email. We have no mailing list, the form offers no subscription, and we do not add your address to one.
6. Hosting, delivery and technical connection data
This website is delivered and protected by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Every request to this website passes through Cloudflare's network before it reaches the system that serves the page, and Cloudflare processes that request on our behalf in order to deliver it.
To deliver the site and keep it available, technical connection data is processed: your IP address, the time of the request, the page requested, the response status, and the browser and operating system your request reports. The purpose is the technical operation, stability and security of this website, including protection against attacks and automated abuse. The legal basis is Article 6(1)(f) GDPR. This data is not combined with the details you send through the contact form.
Retention: this technical connection data is retained only for as long as it is needed to operate and secure the website, and the period is set by the provider that records it rather than chosen by us. We will tell you the period currently in force if you ask us at [email protected], and we will state it here as soon as it is confirmed.
Because our traffic passes through Cloudflare's network, this involves your connection data being processed outside the European Union. You can obtain details of the safeguards that apply to that processing, and of our arrangement with Cloudflare, on request from [email protected].
7. MVP enquiries: referral to a partner
We do not build MVPs ourselves for the German-speaking market. If your enquiry concerns an MVP build, we reply to you and ask whether we may pass your enquiry to our partner GoPassion in Germany. We pass it on only after you have expressly agreed; the legal basis is then Article 6(1)(a) GDPR. Without your agreement we do not pass your enquiry on.
8. Cookies
This website uses a small number of cookies and similar browser storage. Some are strictly necessary and are always set. The analytics cookies are set only if you agree to them in our consent banner.
Strictly necessary
Name: NEXT_LOCALE Purpose: it stores which language version of the website you are being shown, so that the site serves the same language on your next page and on your next visit. Content: a language code, for example "en". It contains no identifier for you. Lifetime: 12 months.
Name: itgrate.analytics-consent (stored in your browser's local storage, not a cookie) Purpose: it stores the choice you made in the consent banner, so that we can respect it and do not ask you again on every page. Content: your choice (accepted or rejected), a version number and the date your choice expires. It contains no identifier for you. Lifetime: 180 days. After that we ask you again.
Name: itgrate_analytics_denied Purpose: it records that you rejected analytics, so that your refusal still applies if your browser does not keep local storage. Content: the date your choice expires. It contains no identifier for you. Lifetime: 180 days. It is set only if you reject analytics.
These are needed to deliver the language version you requested and to respect your consent choice. In our view that makes them strictly necessary for the service you asked for, so no consent is required for them (§ 25(2) no. 2 TDDDG). The legal basis for the related processing is Article 6(1)(f) GDPR. If you block or delete them in your browser, the site keeps working; it will simply stop remembering your language and ask you about analytics again.
Only with your consent: Google Analytics
Name: _ga and _ga_<ID> Set by: Google Analytics, loaded through Google Tag Manager (section 9) Purpose: they tell visits apart and recognise returning browsers, so that Google Analytics can count page views, blog reading and enquiries. Content: a randomly generated identifier and timestamps. Lifetime: up to 2 years, unless you delete them or withdraw your consent first.
These cookies are set only after you click "Accept all" in the consent banner. The legal basis is your consent (§ 25(1) TDDDG and Article 6(1)(a) GDPR). If you click "Reject", or make no choice, we do not load Google Tag Manager or Google Analytics and no analytics cookie is set.
You can change your choice at any time through "Cookie settings" on this website. If you withdraw your consent, we stop sending analytics data at once, delete the analytics cookies set for this website and reload the page. Withdrawing does not affect the lawfulness of the processing carried out before it (Article 7(3) GDPR).
We set no cookie for advertising or for recognising you across other websites.
9. Tracking, analytics and third-party content
We measure how this website is used in two ways: with Cloudflare's standard page visit statistics, which set no cookie and need no consent, and with Google Analytics through Google Tag Manager, which run only if you consent. We use the results to understand which pages and blog articles are read and how many enquiries the website generates (lead conversion), so that we can improve our content.
Cloudflare page visit statistics
Cloudflare, named in section 6, provides us with its standard statistics on visits to this website. They are derived from the requests that pass through Cloudflare's network anyway, as described in section 6: for example the number of visits and page views, which pages and blog articles were requested, the referring website, the country, and the type of device and browser. We see these figures only in aggregated form. These statistics set no cookie, store nothing on your device and do not follow you across visits or across websites.
Purpose: measuring the reach of our website and our blog. Legal basis: Article 6(1)(f) GDPR (our legitimate interest in measuring the use of our website in a way that respects your privacy). Processing outside the European Union: as described in section 6.
Google Tag Manager and Google Analytics
Only if you click "Accept all" in the consent banner do we load Google Tag Manager and, through it, Google Analytics. Both are services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Tag Manager manages the analytics code on our pages; it builds no profile of you itself, but loading it sends your IP address and browser information to Google.
With your consent, Google Analytics records: – the pages and blog articles you view, with the page address stripped of any query parameters other than the page number of a list; – the page you came from, and the language version you are using; – which sections of a page came into view; – when you send the contact form, the fact that an enquiry was sent and on which page and form it was sent (a lead conversion). Google also processes your IP address, information about your device and browser, and the cookies listed in section 8. Google Analytics never receives what you enter in the contact form: not your name, your email address or your message.
Purpose: measuring how our website and blog are used and how many enquiries the website generates, so that we can improve our content and our website. Legal basis: your consent (§ 25(1) TDDDG and Article 6(1)(a) GDPR). You can withdraw it at any time, as described in section 8.
Google may process this data in the United States. Google LLC is certified under the EU–U.S. Data Privacy Framework, for which the European Commission has adopted an adequacy decision (Article 45 GDPR). Google Analytics data is kept for at most 14 months and then deleted automatically. Google's own privacy policy is available at policies.google.com/privacy.
What we do not use
We use no advertising network, no tracking pixel, no social media plugin and no third-party CAPTCHA service, and we do not use Google Analytics for advertising. We build no profile about you to target you, and no automated decision is taken about you.
Apart from Google Tag Manager and Google Analytics, which load only with your consent, this website loads no fonts, scripts, images or media from third-party servers. Everything else the page needs is served from this website.
This website links out to other services — among them LinkedIn, Zalo, Google Maps, the appointment booking page named in section 4, our insurance provider's verification page and our partner GoPassion. External links are recognisable as such. Following one takes you to that provider, and from that point that provider's own privacy policy applies, not this one. Nothing from those services loads on our pages, so following a link is your choice and not something that happens as you read.
10. Retention at a glance
Contact enquiries: enquiries that do not lead to a contract are deleted 24 months after the last contact. Data arising from contractual relationships is retained in line with statutory commercial and tax retention periods.
Bookings: as for contact enquiries.
Technical connection data: as stated in section 6 — only for as long as needed to operate and secure the website, for the period set by the provider that records it, which we will tell you on request.
The language cookie: 12 months, as stated in section 8.
Your consent choice: 180 days, as stated in section 8.
Google Analytics cookies: up to 2 years, unless you delete them or withdraw your consent first (section 8).
Google Analytics data: at most 14 months, as stated in section 9.
Cloudflare page visit statistics: we see these only as aggregated figures, which identify no one (section 9).
11. Your rights
You have the right of access, rectification, erasure, restriction of processing, data portability and objection, and the right to lodge a complaint with a supervisory authority. Contact [email protected].
In detail:
- Access (Article 15 GDPR): you may ask us to confirm whether we process data about you, and to give you a copy of it.
- Rectification (Article 16 GDPR): you may have inaccurate data corrected.
- Erasure (Article 17 GDPR): you may ask us to delete your data, except where we still need it to meet a legal obligation.
- Restriction (Article 18 GDPR): you may ask us to store your data and otherwise stop processing it.
- Portability (Article 20 GDPR): you may receive the data you provided in a structured, commonly used format.
- Objection (Article 21 GDPR): where we rely on our legitimate interest, you may object to the processing.
One request is enough. You do not have to work out which of the two companies in section 1 holds your data; write to [email protected] and we will deal with it for whichever of them it concerns. If your data is held by CÔNG TY TNHH ITGRATE VIỆT NAM you may instead contact its EU representative, named in section 1.
Where we process your data on the basis of your consent — analytics (section 9) or a referral to our partner (section 7) — you may withdraw that consent at any time with effect for the future, for analytics through "Cookie settings" on this website, otherwise by writing to us.
We answer without undue delay and in any event within one month. Exercising your rights is free of charge.
Right to complain: you may lodge a complaint with the data protection supervisory authority of your member state, in particular the authority where you habitually reside or work.
12. No automated decision-making
We take no decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Article 22 GDPR). Your enquiry is always decided on by a person.
13. Changes to this policy
We update this policy when the processing described here changes, for example when we start using a new service provider or add a field to the contact form. The version in force is dated at the top of this page. For enquiries already collected, the version shown to you at the time of collection applies.