1. Data Controller
The Data Controller for the processing of personal data carried out through this website is ELimpia S.r.l., with registered office in Gallarate (VA), Italy. For any matter relating to this notice or to the exercise of your rights, write to support@elimpia.eu. Full corporate identification is provided in the Legal Notice.
Given the limited categories and volumes of personal data processed, the Data Controller is not required to designate a Data Protection Officer pursuant to Article 37 GDPR. Data subjects may nonetheless use the contact above for any matter relating to this notice.
2. Categories of personal data processed
This website processes the following categories of personal data:
- Data provided voluntarily by the data subject through the contact form (name, e-mail address, company, project type, message content) or through any direct correspondence sent to the e-mail addresses published on this website.
- Technical and consent data stored locally in the browser by means of strictly necessary technologies (see the Cookie Policy), used exclusively to remember the user's consent choice and to ensure proper functioning of the website.
This website uses Google Analytics 4 (provided by Google Ireland Limited) to collect aggregated statistics on website usage, only after the user has expressly granted consent via the cookie banner. Google may transfer data to the United States; transfers are covered by Standard Contractual Clauses pursuant to Chapter V GDPR. No other analytics, profiling or advertising technologies are used. Should additional tools be introduced in the future, this Privacy Policy will be updated accordingly.
3. Purposes of processing and legal basis
Personal data are processed for the following purposes and on the following legal bases pursuant to Article 6 GDPR:
- Reply to enquiries and pre-contractual requests, to receive, evaluate and respond to messages submitted through the contact form or by direct e-mail. Legal basis: Article 6(1)(b) GDPR (steps taken at the data subject's request prior to entering into a contract) and, where applicable, Article 6(1)(f) GDPR (legitimate interest of the Controller in managing business correspondence).
- Compliance with legal obligations, to fulfil obligations imposed by applicable law, by competent authorities or by judicial bodies. Legal basis: Article 6(1)(c) GDPR.
- Defence in legal proceedings, to establish, exercise or defend legal claims. Legal basis: Article 6(1)(f) GDPR (legitimate interest).
4. Provision of data
The provision of personal data through the contact form is voluntary. However, failure to provide the information marked as required (name, e-mail, message) will make it impossible for ELimpia S.r.l. to respond to the request submitted.
5. Recipients and transfers
Personal data are processed by authorised personnel of ELimpia S.r.l. and, where strictly necessary, by the hosting provider operating the website (acting as Data Processor pursuant to Article 28 GDPR) and by professional advisors. Data are not transferred outside the European Economic Area.
6. Retention period
Personal data are retained only for the time strictly necessary to achieve the purposes for which they were collected and, in any case, in compliance with the principles of necessity and proportionality set out in Article 5 GDPR. As a general rule:
- data collected through the contact form are retained for the time strictly necessary to handle the enquiry and, where the enquiry develops into a contractual relationship, for the duration of such relationship plus the term required by applicable law;
- data retained for legal-defence purposes are kept until the expiry of the relevant statute-of-limitation periods.
7. Rights of the data subject
Pursuant to Articles 15 to 22 GDPR, data subjects may exercise their rights of access, rectification, erasure, restriction, portability and objection, and may withdraw consent at any time where processing is based on it. Requests are to be addressed to support@elimpia.eu; the Controller replies within the term set forth in Article 12(3) GDPR.
8. Right to lodge a complaint
Without prejudice to any other administrative or judicial remedy, data subjects have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) where they consider that the processing of their personal data infringes the GDPR or the Italian Privacy Code. Contact details and procedures are available at garanteprivacy.it.
9. Automated decision-making and security
ELimpia S.r.l. does not carry out automated decision-making or profiling pursuant to Article 22 GDPR. Appropriate technical and organisational security measures are applied in accordance with Article 32 GDPR (encryption in transit, restricted access, periodic review).
10. Updates
This Privacy Policy may be updated to reflect changes in applicable law or in the processing activities carried out by the Data Controller. Updates are published on this page with a revised "last updated" date.