Last updated: 04/06/2025
1. Introduction
This Privacy Policy describes how the website www.romanobiondani.com (hereinafter referred to as the “Website” or the “Controller”) processes users’ personal data in accordance with Regulation (EU) 2016/679 (“GDPR”) and Italian legislation.
2. Data Controller
The Data Controller is: Gaetano Soliman
3. Data Protection Officer (DPO)
No Data Protection Officer has been appointed, as we do not fall under the obligations set out in Article 37 of the GDPR.
4. Personal Data Collected
The Website collects exclusively:
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Data voluntarily provided via Google Forms: name, surname, email, phone number, and any other data freely entered in the form.
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Anonymous traffic data, collected in aggregated form and not traceable to users, through Cloudflare Web Analytics (without cookies or personal identifiers).
The Website does not use profiling cookies or invasive tracking tools.
5. Purposes and Legal Basis of Processing
| Purpose | Data Processed | Legal Basis |
|---|---|---|
| Managing requests via form | Data provided in the form | Explicit consent |
| Website traffic analysis and performance (Cloudflare) | Aggregated and anonymized data | Legitimate interest of the Controller |
Providing data via the form is optional but necessary to receive a response. No identifiable data is collected for analytics purposes.
6. Method and Retention Period
Data is processed using IT tools, in a lawful and secure manner.
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Data sent via Google Forms is retained for a maximum of 2 years, unless required for legal purposes.
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Anonymous data collected by Cloudflare is not traceable to the user and is not stored on the Website.
7. Recipients and International Transfers
Data may be processed by:
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Google LLC, via Google Forms – Data Processor. Data may be transferred to the USA in compliance with the Data Privacy Framework or Standard Contractual Clauses (SCCs).
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Cloudflare Inc., for anonymous traffic analysis – Data Processor. Data is processed in accordance with SCCs and the DPF.
The Controller ensures that all service providers comply with the GDPR.
8. Data Subject Rights
You have the right to:
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Access your data
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Rectify or erase data
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Restrict processing
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Object to processing
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Data portability
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Withdraw consent
9. Right to Lodge a Complaint
You have the right to lodge a complaint with the Italian Data Protection Authority if you believe that your data is being processed in violation of the GDPR.
10. Profiling and Automated Decision-Making
The Website does not use profiling or automated decision-making processes that produce legal or similarly significant effects for users.
11. Cookies and Other Tools
The Website does not use profiling cookies.
For traffic analysis, we use Cloudflare Web Analytics, which does not set cookies or collect personal data.
12. Updates to the Privacy Policy
This Privacy Policy may be updated. We encourage you to review it periodically.
Last updated: 04/06/2025