Privacy Policy

Updated June 26, 2026

Title21 Health Solutions is committed to protecting your personal data. The purpose of this information notice is to inform you about the processing of personal data concerning you in the context of our commercial relationship.

These personal data processing are implemented as data controller by (depending on your location):

• Title21 Health Solution, whose head office is located at 2325 E. Camelback Rd., Suite 320 Phoenix, AZ 85016, USA ; or
• Title21 Belgium, whose head office is located at 200 Kempische Steenweg, 303 3500 Hasselt, Belgium.

Origin of the collection of your personal data 

Your personal can be collected: 

• Directly from you when you are contacting us (ie. contact form), or during our exchanges.
• Indirectly, in the context of professional conferences and exhibitions, when you have been introduced to us by a third party, or through the use of publicly available data (especially on professional social networks). 

Why do we process your personal data?

First of all, we would like to remind you that we process your personal data exclusively for legitimate purposes that enable us to run our business properly. Under no circumstances will your personal data be used for purposes other than those listed below.

The purposes for which we process your data are:

• Sourcing of prospects or suppliers to identify possible commercial relationships. 
• Clients, prospects and suppliers contact management by the implementation of a dedicated platform. 
• To manage our commercial relationship, particularly during discussions concerning the implementation of our/your service;
• Management of contacts within the framework of our services, in particular with our clients' staff as part of the implementation of our solutions.
• Payment and issuing of invoices;
• Organization of events, webinars, and satisfaction surveys.

What categories of personal data do we process about you?

As part of the data processing operations we carry out, we ensure that we only collect data that is strictly necessary for the fulfillment of the aforementioned purposes. This data is therefore mandatory for the smooth running of our business.

Here is a list of the personal data we may need to process about you:

• Identification and contact data: surname, first name, title, business telephone number, business e-mail address);
• Professional data: function, title, company, attendance to an event or webinar, professional social network

What are the legal basis for processing your personal data?

First of all, a legal basis is a mechanism created by the General Data Protection Regulation (GDPR) on which data processing must be based in order to be lawful. This ensures that organizations, such as Title21, cannot use your personal data for purposes that would not be legitimate.

The legal basis for data processing is:

• The execution of the contract as well as the execution of pre-contractual measures: we are processing your personal data within the framework of the establishment of our commercial relationship, as well as during the execution of the latter when exchanges with the client’s staff are necessary.
• Our legitimate interests: in the context of sourcing contacts and managing clients, suppliers and prospects contacts.
• Your consent when contacting us for a business inquire.

Who can access your personal data?

We make every effort to share your personal data with as few people as possible, ensuring that the need is justified and legitimate.

Your data may be shared with various stakeholders, both internal and external to Title21. These recipients are

Internal to Title21:

• Title21 employees in the course of their duties (sales, legal, finance, marketing, etc.)
• Title21 affiliates / or mother company

External to Title21:

• Our processors responsible for improving the processing and security of your personal data, in particular:
  • CRM provider
  • Satisfaction surveys provider
  • Invoice management software provider
• Legal councils, auditors and consultants in the context of their attributed missions.
• Legal and administrative authorities, in accordance with applicable laws.

Title21 is a multinational organization operating in different countries. For this reason, we may transfer your personal data (including by providing access to it, allowing it to be viewed, or by storing it) to other jurisdictions, including outside the European Economic Area, to countries that may not be considered to offer a level of protection equivalent to that of the country in which you reside.

If we need to transfer your personal data outside the European Union, or outside the country in which you reside, we will ensure that adequate safeguards such as those prescribed by applicable data protection legislation are implemented (such as the European Commission's Standard Contractual Clauses where applicable).

How is your personal data protected?

We believe that IT security is essential to protect both your personal data and the data we process in the course of our business on behalf of our customers.

We have therefore implemented various practical measures to reinforce the protection of our information system, such as:

• Multi-factor authentication and a strong password policy to secure access to our applications;
• Encryption of our computers and use of cloud solutions to limit the consequences of hardware loss;
• Regular back-ups of our systems, with regular integrity tests to validate their operation;
• Raising our staff's awareness of personal data protection issues.

We do our utmost to maintain state-of-the-art system security, as part of a continuous improvement process.

How long do we keep your personal data?

We do our best to limit the retention of your personal data to the periods strictly necessary to meet legal retention obligations.

Here are the retention periods in place:

Purpose of processing	Retention period
Prospection management	3 years after the last contact with the data subject.
Payment and issue of invoices	For a minimum of 10 years from the end of the commercial relationship.
Clients management	For 5 years from the end of the service.

What rights do you have and how can I exercise them?

You have various rights enabling you to maintain control over your personal data:

• The right of access: you can obtain information about the processing of your personal data, as well as a copy of your personal data processed by Title21;
• The right of rectification: you may request the rectification of personal data that is incorrect or incomplete;
• The right to erasure: you may request the deletion of your personal data. N.B. We have a legal obligation to retain data for defined periods, and in some cases may not be able to honor your request;
• The right of limitation: in certain cases you may request the limitation of data processing (cf. article 18 of GDPR);
• The right to object: the right to object to data processing;
• The right to portability: the right to request a copy of your personal data in a machine-readable format;

For further information on the processing of your personal data, or to exercise your rights, please contact our Data Protection Officer, whose contact details are given below.

If you are not satisfied, you have the right to lodge a complaint with the Data Protection Authority.

Contact

For more information about our data processing operations, or to exercise your rights please contact our Data Protection Officer (DPO) at the following address:

Data Protection Officer Title21

• Email: privacy@title21.com
• Postal address:
  • 2325 E. Camelback Rd., Suite 320 Phoenix, AZ 85016, USA
  • 200 Kempische Steenweg, 303 3500 Hasselt, Belgium