PRIVACY POLICY

Last Updated: November 2025

1. INTRODUCTION

This Privacy Policy describes how Vento Digitale di Marco Forlani ("we", "us", "our", or "Company") collects, uses, protects, and shares your personal information when you use our website www.ilariaargento.com (the "Website") and our services, including contact forms, product purchases, and general inquiries.

We are committed to protecting your privacy and ensuring transparency in how we handle your personal data in compliance with applicable data protection laws worldwide, including the EU General Data Protection Regulation (GDPR), UK GDPR, California Consumer Privacy Act (CCPA), and Lei Geral de Proteção de Dados (LGPD).

2. DATA CONTROLLER

The data controller responsible for your personal information is:

Vento Digitale di Marco Forlani
Via Pietro Mascagni, 119
24033 Calusco d'Adda (BG)
Italy

VAT/P.IVA: IT03694090139
Email: info@ventodigitale.com
Website: www.ilariaargento.com

We do not have a designated Data Protection Officer (DPO) as we do not meet the legal requirements necessitating one under applicable data protection regulations.

3. SCOPE AND APPLICABILITY

This Privacy Policy applies to:

Geographic Scope: This policy complies with privacy laws in the European Union (EU GDPR), United Kingdom (UK GDPR), California (CCPA), Brazil (LGPD), and other applicable jurisdictions worldwide.

4. INFORMATION WE COLLECT

4.1 Information You Provide Directly

When you interact with our Website or services, we may collect:

Contact Information:

Commercial Information:

Communications:

4.2 Information Collected Automatically

When you visit our Website, we automatically collect:

Technical Information:

Cookies and Tracking Technologies:

We do NOT collect:

  • Sensitive personal data (health, religious beliefs, political opinions, etc.) unless legally required
  • Data from social media platforms
  • Behavioral profiling data for marketing purposes

5. PURPOSE AND LEGAL BASIS FOR PROCESSING

We collect and process your personal data for the following purposes:

5.1 Contact and Communication

Purpose: To respond to your inquiries, questions, and requests

Legal Basis: Consent (GDPR Art. 6(1)(a)) and Legitimate Interest (GDPR Art. 6(1)(f))

5.2 Commercial Activities and Sales

Purpose:

Legal Basis:

5.3 Legal and Fiscal Compliance

Purpose: To comply with legal obligations including tax laws, accounting regulations, and consumer protection laws

Legal Basis: Legal Obligation (GDPR Art. 6(1)(c))

Retention: 10 years as required by Italian fiscal law for invoices and transaction records

5.4 Website Operation and Security

Purpose:

Legal Basis: Legitimate Interest (GDPR Art. 6(1)(f))

5.5 Marketing and Business Development

Purpose: To analyze aggregate, anonymized data for marketing strategies and business insights

Legal Basis: Legitimate Interest (GDPR Art. 6(1)(f))

Note: We do NOT conduct personalized marketing or behavioral profiling

6. COOKIES AND TRACKING TECHNOLOGIES

6.1 What Are Cookies

Cookies are small text files stored on your device when you visit our Website. They help us provide you with a better experience and analyze how our Website is used.

6.2 Types of Cookies We Use

Strictly Necessary Cookies (Technical Cookies)

Analytics Cookies

6.3 Cookies We Do NOT Use

We do NOT use:

  • Social media cookies or integrations
  • Advertising or marketing cookies
  • Third-party tracking cookies
  • Cross-site tracking technologies
  • Behavioral profiling cookies

6.4 Managing Cookie Preferences

Browser Controls:

You can control and manage cookies through your browser settings:

Blocking Cookies:

Blocking strictly necessary cookies may affect website functionality. Blocking analytics cookies will not impact your browsing experience.

Withdrawal of Consent:

You can withdraw consent for analytics cookies at any time by changing your browser settings or contacting us at info@ventodigitale.com.

6.5 Cookie List

Cookie Name Type Purpose Duration
session_id Technical Session management Session
security_token Technical Security and CSRF protection Session
analytics_anon Analytics Anonymized traffic analysis 24 months

7. DATA SHARING AND DISCLOSURE

7.1 Third-Party Service Providers

We share your personal data only with trusted service providers who assist us in operating our business:

Hosting and Infrastructure:

Payment Processors:

Shipping and Logistics:

7.2 Legal Obligations and Protection

We may disclose your personal information when:

7.3 What We Do NOT Do

We do NOT:

  • Sell, rent, or trade your personal information to third parties
  • Share your data for third-party marketing purposes
  • Transfer data outside the EU without appropriate safeguards
  • Use external social media platforms or analytics services that collect personal data

8. INTERNATIONAL DATA TRANSFERS

8.1 Data Storage Location

Your personal data is primarily stored and processed on AWS servers located within the European Union. We do not transfer data to servers outside the EU.

8.2 Payment Processor Transfers

Payment processors (PayPal, Paddle, Stripe) may transfer data internationally as part of their payment processing operations. These providers implement appropriate safeguards:

8.3 Safeguards for International Transfers

When data is transferred internationally, we ensure:

9. DATA RETENTION

We retain your personal information only as long as necessary for the purposes outlined in this Privacy Policy:

9.1 Communication and Inquiry Data

9.2 Commercial and Transaction Data

9.3 Technical and Analytics Data

9.4 Data Deletion

After retention periods expire:

10. YOUR RIGHTS

10.1 Rights Under GDPR (EU and UK)

If you are located in the European Economic Area (EEA) or United Kingdom, you have the following rights:

Right to Access (Art. 15 GDPR)

Right to Rectification (Art. 16 GDPR)

Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR)

Right to Restrict Processing (Art. 18 GDPR)

Right to Data Portability (Art. 20 GDPR)

Right to Object (Art. 21 GDPR)

Right to Withdraw Consent (Art. 7(3) GDPR)

Right Not to be Subject to Automated Decision-Making (Art. 22 GDPR)

Right to Lodge a Complaint

10.2 Rights Under CCPA (California Residents)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

Right to Know

Right to Delete

Right to Opt-Out of Sale

Right to Non-Discrimination

Authorized Agent

Verification

10.3 Rights Under LGPD (Brazilian Residents)

If you are a Brazilian resident, you have rights under Lei Geral de Proteção de Dados:

10.4 How to Exercise Your Rights

To exercise any of the above rights, please contact us:

Email: info@ventodigitale.com
Subject Line: "Privacy Rights Request"

Include:

  • Your full name
  • Email address associated with your data
  • Specific right(s) you wish to exercise
  • Any relevant details to help us locate your information

Response Time:

Verification:

We may request additional information to verify your identity before processing requests.

10.5 Supervisory Authorities

European Economic Area (EEA):

You have the right to lodge a complaint with your local data protection authority:

United Kingdom:

California:

Brazil:

11. DATA SECURITY

11.1 Security Measures

We implement appropriate technical and organizational security measures to protect your personal information:

Technical Measures:

Organizational Measures:

11.2 Security Limitations

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security. You are responsible for:

11.3 Data Breach Notification

In the event of a data breach affecting your personal information:

12. AUTOMATED DECISION-MAKING AND PROFILING

We do NOT use:

  • Automated decision-making processes
  • Profiling or behavioral analysis
  • Algorithmic decisions with legal or significant effects on individuals
  • AI-based processing of personal data for automated decisions

All decisions affecting your rights, services, or commercial relationships are made by human review.

13. CHILDREN'S PRIVACY

Our Website and services are not intended for children under the age of 16 (or the applicable age of digital consent in your jurisdiction).

We do NOT knowingly:

If you believe a child has provided us with personal information:

Parental Rights:

Parents or legal guardians may request access to, correction, or deletion of their child's personal data by contacting us.

14. CHANGES TO THIS PRIVACY POLICY

14.1 Updates and Modifications

We may update this Privacy Policy from time to time to reflect:

14.2 Notification of Changes

Material Changes:

Non-Material Changes:

14.3 Your Options

If you do not agree with changes to this Privacy Policy:

15. THIRD-PARTY LINKS

Our Website may contain links to external websites not operated by us. We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any external sites you visit.

16. BUSINESS TRANSFERS

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of the business transaction. We will:

17. CONTACT INFORMATION

17.1 Privacy Inquiries

For questions, concerns, or requests regarding this Privacy Policy or your personal data:

Email: info@ventodigitale.com
Subject: Privacy Inquiry

Mail:
Vento Digitale di Marco Forlani
Via Pietro Mascagni, 119
24033 Calusco d'Adda (BG)
Italy

17.2 Data Protection Rights Requests

To exercise your data protection rights (access, rectification, erasure, etc.):

Email: info@ventodigitale.com
Subject: Data Rights Request
Include: Full name, email address, specific request details

17.3 Response Commitment

We commit to responding to all inquiries within:

18. GOVERNING LAW AND JURISDICTION

18.1 Governing Law

This Privacy Policy is governed by:

18.2 Additional Jurisdictions

Where applicable, this Privacy Policy also complies with:

18.3 Dispute Resolution

Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Bergamo, Italy, except where otherwise required by mandatory consumer protection laws in your jurisdiction.

19. ACCEPTANCE OF THIS POLICY

By using our Website, submitting information through our contact forms, or purchasing products or services from us, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use our Website or services.

20. EFFECTIVE DATE

This Privacy Policy is effective as of the "Last Updated" date shown at the beginning of this document.

Current Version: November 2025
Previous Version: October 2025

APPENDIX: SPECIFIC PROVISIONS BY JURISDICTION

A. European Union and United Kingdom

B. California (United States)

C. Brazil

D. Rest of World

For users in other jurisdictions, we apply GDPR standards as the baseline for data protection, ensuring high-level protection regardless of location.