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Draft for legal review. This privacy policy is a working template based on standard GDPR requirements. It must be reviewed and approved by a qualified legal professional before being considered final.
Last updated: [DATE — to be set when finalised]
1. Data Controller
The data controller is IDV S.R.L. — Italian Dolce Vita, with registered office in [ADDRESS — to be completed], Sicily, Italy. Tax code / VAT number: [TO BE COMPLETED].
For any questions regarding the processing of your personal data, you can contact us at: info@italiandolcevita.com
2. What Data We Collect
When you use our website and services, we may collect the following personal data:
- Contact form data: full name, email address, phone number, nationality, budget range, preferred area, timeline, and any information you include in the message field.
- Browsing data: IP address, browser type, pages visited, time of visit — collected automatically through standard web technologies.
- Communication data: any information exchanged via email, phone, or messaging services after initial contact.
3. Why We Process Your Data (Legal Basis)
We process your personal data for the following purposes:
- To respond to your enquiry (legal basis: your consent, given by submitting the contact form)
- To provide our consultancy services (legal basis: performance of a contract or pre-contractual measures at your request)
- To send updates and communications about our services (legal basis: your explicit consent, which you can withdraw at any time)
- To comply with legal obligations (legal basis: legal obligation)
4. Who Receives Your Data
Your personal data may be shared with:
- Our team members (Valerio, Enrico, Barbara) who handle client communication and service delivery
- Professional partners (notaries, surveyors, accountants, real estate agencies) — only when necessary for the delivery of our services, and only with your prior knowledge
- Technical service providers (hosting, email services) who process data on our behalf under appropriate data processing agreements
We do not sell, rent, or trade your personal data to third parties. We do not share your data with any party for their own marketing purposes.
5. Data Transfers Outside the EU
Your data is primarily processed within the European Union. If any data processing requires transfer outside the EU (e.g., through the use of third-party services), we ensure that appropriate safeguards are in place as required by GDPR (e.g., Standard Contractual Clauses, adequacy decisions).
6. How Long We Keep Your Data
- Contact form enquiries: retained for up to 24 months from the last contact, unless a contractual relationship is established
- Client data (active contract): retained for the duration of the service and for 10 years thereafter, as required by Italian law for accounting and tax purposes
- Marketing communications: until you withdraw your consent
7. Your Rights
Under GDPR, you have the following rights:
- Access: request a copy of the data we hold about you
- Rectification: request correction of inaccurate data
- Erasure: request deletion of your data ("right to be forgotten")
- Restriction: request that we limit how we process your data
- Portability: receive your data in a structured, commonly used format
- Objection: object to data processing based on legitimate interest
- Withdraw consent: withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal
To exercise any of these rights, contact us at info@italiandolcevita.com. We will respond within 30 days.
You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) at www.garanteprivacy.it.
8. Cookies
This website currently uses only essential technical cookies necessary for the basic functioning of the website. We do not use profiling cookies or third-party tracking cookies.
[NOTE FOR LEGAL: If analytics tools (e.g., Google Analytics) or advertising pixels are added in the future, this section must be updated accordingly, and a cookie consent banner must be implemented.]
9. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this page periodically.
10. Contact
For questions, requests, or concerns about this Privacy Policy or the processing of your personal data:
IDV S.R.L. — Italian Dolce Vita
Email: info@italiandolcevita.com
Location: Sicily, Italy