Website Privacy Policy

1. Data Controller

The Data Controller is: Alfred S.r.l. (Tax Code and VAT no. 06888990485), with registered office at Via Ghibellina 37r-39r, Florence (FI), Italy; contactable at the e-mail address: [email protected].

2. Categories of data processed

The Controller may process the following categories of personal data.

2.1 Browsing data

The IT systems and software procedures responsible for the operation of the Site acquire, in the course of their normal operation, certain personal data the transmission of which is implicit in the use of Internet communication protocols.

By way of example:

• IP addresses;
• URIs (Uniform Resource Identifiers) of the requested resources;
• the time of the request;
• the method used to submit the request;
• the size of the file obtained in response;
• the numerical code indicating the status of the response given by the server;
• information relating to the browser and the device used.

2.2 Data provided voluntarily by the user

The Controller may process data provided directly by the user through:

• requests for information;
• e-mail communications;
• commercial requests;
• the completion of digital forms.

The data processed may include:

• first name and surname;
• e-mail address;
• telephone number;
• the content of communications sent to the Controller.

2.3 Waitlist

The “Join the waitlist” button opens a form hosted by Typeform (Typeform S.L.), which acts as data processor on behalf of the Controller. The form collects name, e-mail address and consent, which the Controller uses only to contact the user about the launch of Alfred. The legal basis is consent (art. 6(1)(a) GDPR), which can be withdrawn at any time by writing to [email protected]. Typeform’s own privacy policy also applies to its processing: typeform.com/privacy-policy.

3. Cookies and tracking technologies

The Site does not use analytics cookies, profiling cookies, remarketing tools or advertising pixels.

The Site stores in the user's browser only the language chosen, in order to show the pages in that language on later visits. This is a technical tool.

4. Purposes of the processing and legal bases

Personal data is processed for the following purposes.

4.1 Technical management and security of the Site

Data is processed for:

• the technical operation of the Site;
• the management of digital infrastructure;
• IT security;
• the prevention of unauthorised access;
• monitoring the proper functioning of the services.

Legal basis

• the legitimate interest of the Controller;
• Article 6(1)(f) GDPR.

4.2 Management of requests and contacts

Data is processed to:

• respond to requests;
• manage communications;
• provide commercial and operational information;
• manage pre-contractual and contractual relationships.

Legal basis

• the performance of pre-contractual measures;
• the performance of a contract;
• Article 6(1)(b) GDPR.

4.3 Marketing and commercial communications

Data may be processed for:

• newsletters;
• promotional communications;
• commercial offers;
• promotional initiatives.

Legal basis

• the consent of the data subject;
• legitimate interest in the cases permitted by the applicable legislation;
• Article 6(1)(a) and (f) GDPR.

5. Methods of processing

The processing is carried out by means of:

• electronic tools;
• IT tools;
• digital tools;
• telematic tools;
• paper-based tools.

The Controller adopts appropriate technical and organisational measures pursuant to Articles 24, 25 and 32 GDPR.

6. Disclosure of data

Personal data may be disclosed to:

• authorised personnel of the Controller;
• IT suppliers;
• cloud providers;
• hosting providers;
• CRM providers;
• Typeform S.L., for the waitlist form (section 2.3);
• professional advisors;
• public Authorities in the cases provided for by law.

7. Data retention

Personal data is retained for the time strictly necessary to achieve the purposes set out in this notice and, in any event:

• within the time limits provided for by law;
• for the duration of the contractual relationships;
• until the consent is withdrawn, where applicable;
• within the applicable limitation periods.

8. Rights of the data subject

1. The right of access to personal data – Article 15 GDPR;
2. The right to obtain the rectification or erasure of such data, or the restriction of the processing concerning the data subject – Articles 16, 17, 18 and 19 GDPR;
3. The right to obtain the portability of the data, where the processing is carried out by automated means and the transfer in a structured format is technically feasible – Article 20 GDPR;
4. The right to object to the processing. The Controller will proceed with such processing only where there are compelling legitimate grounds, or for the establishment, exercise or defence of a legal claim – Article 21 GDPR;
5. The right to withdraw consent – Article 7 GDPR. The data subject is informed that the withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal and that, where for a specific purpose the processing is based on a legal basis other than consent, such processing will continue limited to that purpose;
6. The right to lodge a complaint with the supervisory authority (the Italian Data Protection Authority – "Garante per la protezione dei dati personali") – Article 77 GDPR.

Requests may be sent to: [email protected]

9. Automated decision-making

No solely automated decisions capable of producing legal effects concerning the data subject or similarly significantly affecting them within the meaning of Article 22 GDPR are taken.

10. Updates

This Privacy Policy may be subject to changes, additions and updates.

The updated version will be made available on the Controller's Site.