Privacy Policy

1. Data controller

The controller of personal data is:

• Roberto Cinque
• P.IVA 10201131215
• Email: info.robertocinque@gmail.com
• WhatsApp: +39 320 427 1276

The controller has not appointed a Data Protection Officer (DPO), as the conditions set out in Article 37 GDPR do not apply. For any request concerning the processing of personal data you can contact the controller directly at the details above.

2. Types of data collected

Data you provide voluntarily

This site contains no contact form and does not collect personal details directly. You freely choose whether to contact the controller via WhatsApp or by email (see the /contatti page). Anything you share in that conversation (name, phone number, email address, a description of what you manage in Excel, attached files) is provided by you, inside the channel you chose.

Data collected automatically

• Browsing data: browser and device type, operating system, pages visited, date and time of access
• The page the request came from, the referring site and the position of the button clicked
• Campaign parameters (utm_source, utm_medium, utm_campaign, utm_term, utm_content) and, where consent is given, advertising click identifiers (Google Ads gclid, fbclid) and a session identifier

Notification of a WhatsApp button click

When you click a WhatsApp button or the call booking link, the site sends the controller a Telegram notification containing: the page, the position of the button, campaign parameters, the referring site, the device type (desktop or mobile, inferred from the user agent) and the language the page was shown in. Without analytics consent the notification contains no session identifier and no gclid or fbclid; with consent those identifiers are included so that campaigns can be measured. The IP address is not stored.

This notification is not filed in any database held by the controller: there is no database, no archive of contact requests and no event history. The message stays only in the controller's Telegram chat, which he reads and deletes once it is no longer useful.

Advertising conversion measurement (ChatGPT Ads)

This site is advertised inside ChatGPT. When a user arrives from one of those ads, the landing page address carries a click identifier (oppref) generated by OpenAI. If the user then clicks a WhatsApp button, the site reports the conversion to OpenAI together with: the click identifier, IP address, user agent, an event identifier, and the date and time. Its only purpose is to know which ads produce real enquiries.

This transmission reads and writes no cookie and stores nothing on the user's device: the click identifier is read from the page address and kept in the browser tab's memory alone, for as long as the page stays open. Since there is neither storage of, nor access to, information on the terminal equipment, art. 122 of Italian Legislative Decree 196/2003 does not apply: the legal basis is the Controller's legitimate interest in measuring the effectiveness of his own advertising (art. 6.1.f GDPR).

The user may object at any time under art. 21 GDPR: simply choose “Necessary only” in the cookie banner, or write to info.robertocinque@gmail.com. From that moment on, no conversion is reported to OpenAI. Separately, and only after consent, the ChatGPT Ads measurement pixel is also loaded; it does use first-party cookies and is described in the Cookie policy.

3. Purposes and legal basis

4. How data is processed

Personal data is processed using electronic and automated tools, with logic strictly related to the purposes above and with technical and organisational security measures appropriate to safeguarding the confidentiality and integrity of the data.

Data is not disseminated, nor disclosed to unidentified recipients.

5. Contact via WhatsApp and call booking

The contact buttons on this site open the WhatsApp app with a prefilled message, which you remain free to edit or not to send. The site has no access to the content of the conversation before you send it.

Once started, the conversation takes place entirely inside WhatsApp and is subject to the terms and privacy notice of WhatsApp Ireland Ltd. (Meta group). Messages, your phone number and any files you send (for example a spreadsheet) travel across Meta's infrastructure under its policies. The controller processes what he receives on WhatsApp solely to reply, review the file and prepare a quote.

As an alternative to WhatsApp, the site offers a link to book a 30-minute call. The link leads off the site, to calendly.com: the page embeds no widget and sets no Calendly cookies. The details entered when booking (name, email address, chosen time and any notes) are collected directly by Calendly LLC under its privacy notice and passed to the controller, who processes them solely in order to hold the call. The campaign parameters (utm_*) already present in the visit are appended to the link, so the controller knows which ad the request came from.

6. Recipients of the data

Personal data may be disclosed to the following categories of recipient, acting as processors (Art. 28 GDPR):

7. Transfers outside the EU

Some of the providers listed above are based outside the European Union. Transfers to the United States take place under the EU-US Data Privacy Framework (European Commission adequacy decision of 10 July 2023) and, where applicable, under Standard Contractual Clauses (SCCs) approved by the European Commission, which ensure an adequate level of protection for personal data.

8. Retention period

Once those periods have passed the data is deleted or irreversibly anonymised.

9. Your rights

Under Articles 15-22 GDPR you have the right to:

• Access (Art. 15) — obtain confirmation that processing is taking place and access your data
• Rectification (Art. 16) — correct inaccurate or incomplete data
• Erasure (Art. 17) — have your data deleted when it is no longer needed, when consent is withdrawn or in the other cases set out in the GDPR
• Restriction (Art. 18) — request restriction of processing in certain circumstances
• Portability (Art. 20) — receive your data in a structured, commonly used, machine-readable format
• Objection (Art. 21) — object to processing based on legitimate interest or for direct marketing. If you object to direct marketing, processing stops immediately
• Withdrawal of consent (Art. 7(3)) — withdraw consent at any time, as easily as it was given, without affecting the lawfulness of processing carried out before withdrawal

For ChatGPT Ads conversion measurement alone, which rests on legitimate interest, the objection under art. 21 can be exercised directly from the cookie banner by choosing “Necessary only”: from that moment no conversion data is transmitted to OpenAI any more.

To exercise your rights, send a request to info.robertocinque@gmail.com with the subject “Privacy request”. The controller will reply within 30 days of receiving it.

10. Right to lodge a complaint

You have the right to lodge a complaint with the competent supervisory authority:

11. Providing your data

Providing personal data is entirely optional: the site can be browsed without giving any. If you choose not to write on WhatsApp or by email, it is not possible to reply to you or to review your file for free.

12. Cookies

For details on the cookies and tracking tools used by this site, see the Cookie Policy.

13. Changes to this notice

The controller reserves the right to amend this notice at any time. Changes will be published on this page together with the date of the last update.

14. Applicable legislation

• Regulation (EU) 2016/679 (GDPR)
• Italian Legislative Decree 196/2003 (Privacy Code) as amended (Legislative Decree 101/2018)
• Directive 2002/58/EC (ePrivacy Directive) and its implementing rules
• Guidelines of the Italian Data Protection Authority on cookies and other tracking tools (10 June 2021, effective from 10 January 2022)