Privacy Policy

1. Introduction

This Privacy Policy describes how personal data is processed for users who visit the website www.consultlario.com (hereinafter "Website").

This information is provided pursuant to Article 13 of EU Regulation 2016/679 (GDPR) to those who interact with Consultlario SRL's web services.

2. Data Controller

The Data Controller is CONSULTLARIO S.R.L., with registered office at Via Paolino dei Morti 13, 23900 Lecco (LC), Italy, VAT Number IT03950980130, contactable at: privacy@consultlario.com.

3. Types of Data Collected

3.1 Browsing Data

The computer systems and software procedures used to operate this Website acquire, during normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

This category includes: IP addresses, browser type, operating system, domain names and website addresses from which access or exit was made, information about pages visited, access time, time spent on individual pages, internal path analysis and other parameters relating to the user's operating system and computer environment.

3.2 Data Voluntarily Provided by the User

The optional, explicit and voluntary sending of messages to the contacts indicated on the Website, as well as the completion and submission of forms on the Website, involves the acquisition of the sender's contact data, necessary for response, as well as all personal data included in communications.

Data that may be collected includes:

• First and last name
• Email address
• Phone number
• Company name
• Other information voluntarily provided in messages

3.3 Business Contact Data Collected from Public Sources (B2B Outreach)

As part of commercial outreach activities directed exclusively at businesses (B2B), the Data Controller may process business contact data of parties other than Website users, collected from publicly accessible sources. Such data relates to the individual in their professional capacity and not their private sphere.

The categories of data processed for this purpose include:

• Company name and business sector
• Business email address
• Business phone number
• Company location

Such data is collected from the following sources:

• Public registers (Business Register / Chamber of Commerce)
• Publicly accessible company websites
• Professional B2B contact-sourcing services (e.g. Hunter.io, Apollo.io)

The recipient may object to this processing at any time by replying "STOP" to any of our emails, using the unsubscribe link, or by writing to privacy@consultlario.com.

4. Purpose of Processing

Personal data is processed for the following purposes:

• Service provision: responding to information and quote requests
• Contractual obligations: managing contractual relationships with clients
• Legal obligations: accounting, tax and administrative requirements
• Information communications: sending newsletters and updates (with consent)
• B2B commercial outreach: sending service presentation communications to businesses deemed relevant to the Controller's activity (occupational safety consulting and mandatory training), with the recipient's right to object at any time
• Statistical analysis: improving the Website and services offered (aggregated and anonymized data)

5. Legal Basis for Processing

Personal data processing is based on the following legal grounds:

• Consent: for newsletter subscription and promotional communications
• Contractual performance: for managing requests and client relationships
• Legal obligation: for tax and accounting compliance
• Legitimate interest (Art. 6(1)(f) GDPR): for Website security, anonymized statistical analysis and B2B commercial outreach to relevant businesses, limited to business contact data and respecting the data subject's right to object (Art. 21 GDPR)

6. Processing Methods

Personal data is processed using automated tools for the time strictly necessary to achieve the purposes for which it was collected. Specific security measures are observed to prevent data loss, unlawful or improper use and unauthorized access.

7. Data Retention

Personal data will be retained for the time necessary to achieve the purposes for which it is processed and in any case for a period not exceeding that provided for by current regulations.

Specifically:

• Contractual data: 10 years from termination of the relationship
• Tax data: 10 years
• Contact data (information requests): 24 months from last contact
• Newsletter data: until consent is withdrawn
• Contact data from B2B commercial outreach: 24 months from last contact, unless an objection is raised earlier

8. Communication and Disclosure of Data

Personal data will not be disclosed but may be communicated to third parties acting as Data Processors, such as:

• IT and hosting service providers
• Tax and legal consultants
• Instantly.ai Inc. — email marketing and deliverability verification platform, for newsletter communications (consent-based) and B2B commercial outreach (legitimate interest) (USA, with GDPR Standard Contractual Clauses)

An updated list of Data Processors can be requested by writing to privacy@consultlario.com.

9. Data Transfer

Personal data is mainly processed within the European Union. Should it be necessary to transfer data to third countries, the Controller will ensure compliance with GDPR provisions, adopting appropriate safeguards.

10. Data Subject Rights

Pursuant to Articles 15-22 of the GDPR, the data subject has the right to:

• Access: obtain confirmation of the existence of processing and access their data
• Rectification: obtain correction of inaccurate data
• Erasure: obtain deletion of data ("right to be forgotten")
• Restriction: obtain restriction of processing
• Portability: receive data in a structured, machine-readable format
• Objection: object to processing at any time
• Withdrawal of consent: withdraw previously given consent

To exercise your rights, you may send a request to privacy@consultlario.com.

The data subject also has the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

11. Cookie Policy

For information on the use of cookies by the Website, please consult our Cookie Policy.

12. Changes to the Privacy Policy

The Controller reserves the right to modify, update, add or remove parts of this Privacy Policy. Users are invited to periodically consult this page. The date of the last update is indicated above.

13. Contact

For any questions regarding this Privacy Policy or to exercise your rights, you may contact the Data Controller:

• Email: privacy@consultlario.com
• Phone: +39 338 287 4097
• Address: Via Giuseppe Resinelli, 4, 23900 Lecco LC, Italy