Privacy Policy

Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). Effective from 11/09/2025 .

INTRODUCTION

This information takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree 30 June 2003 No. 196). The document was also drafted on the basis of the Guidelines of the Privacy Guarantor (especially the Guidelines to combat spam issued by the Privacy Guarantor on 4 July 2013).

Data Controller: Simone D’Antoni – Via di Pratale 28 – 56127 Pisa – Tel: +39 391 482 1572 – Email: info@ectoconsulting.it

Site to which this privacy policy refers: https://ectconsulting.eu/ (Site).

The Data Controller has not appointed a DPO. Therefore, you can send any requests for information directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Site.

The main processing of your personal data is described below. In particular, the legal basis of the processing is explained, whether the provision is mandatory and the consequences of failure to provide personal data. To better describe your rights, where necessary, we have specified if and when a certain processing of personal data is not carried out. On the Site you have the possibility to enter personal data of third parties. In this case you guarantee that you have obtained consent from these subjects to the insertion of this personal data. Therefore, you agree to indemnify and hold harmless the Data Controller from any liability.

Registration on the Site

The information and data requested in case of registration will be used to allow you both to access the reserved area of the Site and to use the online services offered by the Data Controller to registered users. The legal basis of the processing is the need for the Data Controller to execute pre-contractual measures taken at the request of the data subject. The provision of data is optional. However, your refusal to provide data will make it impossible to register on the Site. On the Site it is also possible to register using external services. In this case, your registration data will be shared with the companies of these external services for the sole purpose of allowing registration on the Site. The legal basis of this processing is the legitimate interest of the Data Controller to allow registration to the Site through external services. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data will, however, make it impossible to register through external services.

Purchases on the Site

Your personal data will be processed to allow you to make purchases on the Site. In the case of placing an online purchase order, to allow the conclusion of the purchase contract and the correct execution of the operations connected to it (and, if necessary according to sector regulations, to fulfill tax obligations). The legal basis of the processing is the obligation of the Data Controller to execute the contract with the data subject or to fulfill legal obligations. Regardless of the above (and therefore your consent), the Data Controller may process your data for the purpose of so-called “soft-spam”, regulated by art. 130 of the Privacy Code. This means that limited to the email provided by you in the context of a purchase through the Site, the Data Controller will process the email to allow the direct offer of similar products/services, provided that you do not object to this processing in the manner provided in this information. The legal basis of the processing is the legitimate interest of the Data Controller to send this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject to receive “soft-spam” communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis of this processing is the legitimate interest of the Data Controller to send this type of communication.

Responding to your requests

Your data will be processed to respond to your requests for information. The provision is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis of the processing is the legitimate interest of the Data Controller to follow up on user requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller.

Generic marketing

With your prior consent, the Data Controller may process the personal data you have provided in order to send you advertising material and/or newsletters relating to its own or third-party products. The legal basis of this processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties as well as the impossibility for the Data Controller to carry out market surveys, also aimed at assessing the degree of user satisfaction, as well as to send you newsletters.

Profiling

With your prior consent, the Data Controller may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices through the disclosure of the type and frequency of purchases made by you, in order to send you advertising material and/or newsletters relating to its own or third-party products, of your specific interest. The legal basis of this processing is your consent. The provision of data for this purpose is purely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to process your commercial profile, by detecting your purchasing choices and habits as well as to send you advertising material, relating to products of the Data Controller and/or third parties, of your specific interest.

Transfer of data

The Data Controller does not transfer your personal data to third parties.

Geolocation

In case of access to the Site you may receive a notification on your device (fixed and/or mobile) that will give you the possibility to consent or not to the identification of the device itself (so-called geo-location). You can freely consent or refuse this setting, without this entailing substantial changes to the functionality of the Site. You can change the geolocation settings at any time through the settings of your device. The legal basis of the processing consists in the legitimate interest of the Data Controller to provide services relevant to the user’s position. This legitimate interest is equal to the user’s interest in receiving services as relevant as possible to his position.

Communication of personal data

In the context of its ordinary activity, the Data Controller may communicate your personal data to certain categories of subjects. In Article 2 you can find the list of subjects to whom the Data Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data is not communicated to third parties.

The “communication” to third parties of personal data is different from the “transfer” (regulated in the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller of the personal data. Furthermore, to transfer your personal data to third parties your consent is always required.

Without prejudice to the foregoing, it is understood that the Data Controller may in any case use your personal data to correctly fulfill the obligations provided for by the laws in force.

SPECIFIC PRIVACY INFORMATION

Art. 1 Processing methods

1.1 The processing of your personal data will be mainly carried out with the help of electronic or otherwise automated means, according to the methods and with the tools suitable to guarantee security and confidentiality in accordance with the GDPR. If the automatic chatbot service is operational, your personal data will also be processed to allow the activation of this service, through which the user can contact and be contacted by the Data Controller, with prior consent. The legal basis is the legitimate interest of the Data Controller to respond to user requests through the chatbot service. This legitimate interest can be considered equivalent to the interest of the data subject to use the automatic chatbot service.

1.2 The information acquired and the methods of processing will be relevant and not excessive with respect to the type of services provided. Your data will also be managed and protected in secure IT environments suitable for the circumstances. On the Site, you will have the possibility to create a public profile in which other users will be able to view the material published by you and your personal data (e.g.: photographs or videos). Therefore, you acknowledge and accept that the Data Controller is not responsible for the use that users may make of this material and your personal data.

1.3 “Particular data” are not processed through the Site. Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, health status and sexual life.

1.4 Judicial data are not processed through the Site.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to determined categories of subjects. Below are the subjects to whom the Data Controller reserves the right to communicate your data:

• The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
• Your personal data may also be communicated to all those public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labor, etc.), if the communication is necessary or functional to the correct fulfillment of the obligations deriving from the law.
• The Data Controller makes use of employees and/or collaborators in any capacity. For the correct functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
• In its ordinary activity of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or of which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
• For sending its communications, the Data Controller uses external companies in charge of sending this type of communications (CRM platforms). Your personal data (in particular the email) may therefore be communicated to these companies.
• The Data Controller does not use external companies to provide the customer care service.

The Data Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.

Art. 3 Retention of personal data

3.1 This article describes for how long the Data Controller reserves the right to retain your personal data.

• Your personal data will be kept only for the time necessary to guarantee the correct provision of the services offered through the Site.
• For marketing purposes, personal data will be kept until the eventual revocation of consent. For inactive users, personal data will be deleted one year after sending the last email possibly viewed.
• For customer care purposes, the data will be deleted once the assistance service is completed.
• For the purpose of executing the sales contract, the data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defense and to demonstrate that it has correctly executed the contract.
• As required by Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in case of control.

3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view as it is governed by the GDPR. If the transfer of your personal data takes place in a non-EU country and for which the European Commission has expressed an adequacy judgment, the transfer is considered in any case safe from a regulatory point of view. This article 4.1 indicates from time to time the countries in which your personal data may be eventually transferred and where the European Commission has expressed an adequacy judgment.

4.2 Your data are not transferred to countries outside the European Union.

4.3 In this article the Data Controller indicates the countries in which it eventually directs its activity in a specific way. This circumstance may imply the application of the legislation of the country of reference, together with that of the GDPR.

• At the user’s request, the Data Controller will apply to the processing of personal data the eventually more favorable legislation provided for by the national legislation of the user himself.

Art. 5. Rights of the data subject

Pursuant to art. 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:

• ask the Data Controller for access to your personal data and the rectification or cancellation of the same or the limitation of the processing that concerns you or to oppose their processing, in addition to the right to data portability
• revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation
• lodge a complaint with a supervisory authority (e.g.: the Guarantor for the protection of personal data).

The aforementioned rights may be exercised with a request addressed without formalities to the contacts indicated in the Introduction.

Art. 6. Changes and Miscellaneous

The Data Controller reserves the right to make changes to this information at any time, giving adequate publicity to the users of the Site and guaranteeing in any case an adequate and analogous protection of personal data. In order to view any changes, you are invited to consult this information regularly. In case of substantial changes to this privacy policy, the Data Controller may also give notice by email.