Privacy Policy


The digital platform “VirtualHugs” allows online donations of tablets and smartphones as well as monetary donations that will allow the purchase of additional devices.

Who this privacy statement applies to and what it covers?

This Privacy Statement applies to Close the Gap International vzw, Pleinlaan 2 1050 Elsene (BE 0860.353.772), being the entity that determines the purposes and means for processing your personal data as part of the Platform.

We are committed to protecting your privacy and handling your information in an open and transparent manner.

This privacy statement sets out how we will collect, handle, store and protect information about you when providing services to you through this Platform (“Services”).


This privacy statement also contains information about when we share your personal data with other third parties (for example, our service providers).

In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

What information we collect?

We will collect or obtain the following personal data about you as part of the Platform:

  • First name
  • Last name
  • Professional e-mail address
  • Phone number
  • Address (in case you provide us with your personal address instead of your company address)

How we use information about you?

We may also use your personal data for the purposes of, or in connection with:

  • To identify if the donated devices are eligible
  • To contact you for organizing the pick-up of the donated devices
  • To be able to provide you with a report
  • Any applicable legal or regulatory requirements
  • Requests and communications from competent authorities
  • To manage and respond to any request you submit through the Platform.

The legal grounds we use for processing personal information

We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data.

As a result, we use your personal data for the purposes outlined above because of our legitimate interests in providing you access to the Platform and in the effective and lawful operation of our business so long as such interests are not outweighed by your interests (Art. 6.1, f GDPR).

Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail.

Who we disclose your information to?

In connection with one or more of the purposes outlined in the “How we use information about you?” section above, we may disclose personal data about you to third parties that provide services to us; competent authorities (including courts and authorities regulating us) or our advisers and your advisers.

Our material sub-processor are:

  • Deloitte Services & Investments NV
  • Deloitte Consulting & Advisory CVBA
  • Sendgrid Inc.

We may also need to disclose your personal data if required to do so by law, a regulator or during legal proceedings.

When we share your personal data as mentioned above, the third parties with whom we share the personal data may be in the European Economic Area (“EEA”) or in countries outside the EEA, including countries where the legislation may not offer the same level of data protection. In the latter cases, we will ensure that there are sufficient safeguards to protect your personal data that meets our legal obligations (for example through standard provisions for the transfer of personal data).

For more information about the third parties we work with and how they treat your personal data, or for information on the appropriate measures we take with regard to data transfers to countries outside the EEA where laws do not offer the same level of data protection, please contact Peter Manderick (

We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

Protection of your personal information

We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:

  • education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data
  • administrative and technical controls to restrict access to personal data on a ‘need to know’ basis
  • technological security measures, including fire walls, encryption and anti-virus software
  • physical security measures, such as staff security passes to access our premises.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

How long we keep your information for?

We will hold your personal data on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise in respect of the Platform.

Your rights

You have various rights in relation to your personal data. In particular, you have a right to:

  • access the personal data that we hold about you;
  • obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you
  • request that we update or correct the personal data that we hold about you if you believe that it is incorrect or incomplete;
  • request that we delete personal data that we hold about you, or restrict the way in which we use such personal data
  • object to our processing of your personal data when the processing is not the result of our legal obligation to do so or the data does not have to be processed for the execution of our agreement (s)
  • obtain the personal data that you have provided to us in a structured, current and machine-readable form (data portability).

However, your rights are not absolute. There are cases where applicable laws or legal requirements limit these rights and allow or oblige us to refuse to meet your request, such as confidentiality obligations, the privacy rights of others, the protection of our legitimate business interests or the interests of our employees or clients.

We do everything reasonably possible to ensure that your personal data is correct for the intended use. It is your responsibility to inform us of changes to your personal data.

To exercise your rights, or in case of questions about this Privacy Statement or our use of your personal data as part of the Platform, you can contact Peter Manderick ( ). When you exercise your rights, please note that the DPO may ask you for specific information to enable them to confirm your identity and the existence and scope of your invoked right.

If you are not satisfied with the way we have processed your personal data, or with the way we have handled your privacy question or request, you have the right to file a complaint with the Belgian Data Protection Authority:

Data protection authority - Authority for protection of data - Data Protection Authority

Drukpersstraat 35

1000 Brussels

Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.