This is a translation of the Italian privacy policy. In case of doubt, the Italian version prevails.
This page explains how I process the personal data of people who visit the site and people who contact me, in accordance with EU Regulation 2016/679 (GDPR) and the Italian Privacy Code (Legislative Decree 196/2003).
1. Data controller
Ing. Riccardo Sponchiado
Via Armando Diaz 110, 31050 Vascon di Carbonera (TV), Italy
VAT no. 05643450264
Email studio@riccardosponchiado.com · PEC riccardo.sponchiado@ingpec.eu
2. Data collected
a. Data you send me
- through the contact form: full name, company, email, phone, service of interest, message and any photo;
- by email, phone or WhatsApp: the data you choose to share.
Name, email and message are needed to reply to you; the other data are optional. Please don’t include sensitive data, such as health information.
b. Browsing data
- technical data such as IP address, browser type, page visited, date and time;
- anonymous, aggregated visit statistics, collected without cookies.
c. Hosting
The site is hosted by Cloudflare, Inc., which processes browsing data to run and protect it. Provider’s policy: cloudflare.com/privacypolicy.
3. Purposes of processing
- Replying to requests and preparing quotes.
- Carrying out the work I am commissioned to do.
- Meeting tax and accounting obligations.
- Protecting the site and the form from spam and abuse.
I don’t use the data for advertising or newsletters.
4. Legal basis
- pre-contractual measures taken at your request (Art. 6(1)(b) GDPR), for requests and quotes;
- performance of a contract (Art. 6(1)(b)), for commissioned work;
- legal obligation (Art. 6(1)(c)), for tax compliance;
- legitimate interest (Art. 6(1)(f)), for the security of the site.
5. How data are processed
Data are processed electronically, only by me and by the providers listed in section 7. I don’t make decisions based solely on automated processing, including profiling.
6. Retention
- requests that don’t turn into a job: 24 months from the last contact;
- commissioned work: for the duration of the work and then for the periods required by law (10 years for tax documents).
7. Disclosure and transfer of data
I don’t sell or give away data. I only share them with the providers I need, appointed as data processors:
- Cloudflare, Inc.: hosting, statistics, anti-spam protection and form delivery;
- Aruba S.p.A.: mailbox;
- Brevo (Sendinblue SAS, France): delivery of the form emails;
- my accountant, only for work to be invoiced.
When a provider is based outside the European Union, like Cloudflare in the United States, the transfer is protected by the EU-U.S. Data Privacy Framework or by the standard contractual clauses approved by the European Commission.
8. Cookies
The site uses no profiling or third-party cookies, which is why there is no cookie banner. The form’s anti-spam protection may use strictly necessary technical tools, which don’t require consent.
9. Your rights
You can ask me at any time to:
- access your data and get a copy;
- correct or delete them;
- restrict or object to their processing;
- receive them in a machine-readable format (portability).
Write to me at studio@riccardosponchiado.com: I reply within one month. You can also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).
10. Security
I take appropriate technical and organisational measures to protect data from unauthorised access, loss or misuse.
11. Changes
If the way I process data changes, I update this page and the date at the top.
Legal references
- EU Regulation 2016/679 (GDPR)
- Legislative Decree 196/2003 (Italian Privacy Code), as amended by Legislative Decree 101/2018