Privacy

Who is responsible

The data controller is Vulpera S.R.L., Viale Giorgio Ribotta 11, 00144 Roma (RM), Italy. You can reach us at info@vulpera.it, or by certified email (PEC) at vulpera@arubapec.it.

What this website collects

This site sets no cookies, runs no analytics, embeds no maps, videos or social widgets, and has no forms. It makes no requests to any third party: every file that makes up a page is served from vulpera.it itself.

Hosting and server logs

The site is hosted on GitHub Pages, a service of GitHub, Inc. (United States). To deliver a page, GitHub processes connection data, including your IP address. GitHub also logs visitors’ IP addresses for security purposes, under its own privacy statement. We never receive these logs, and GitHub decides how long it keeps them.

The legal basis is our legitimate interest in making the site available and keeping it secure (Article 6(1)(f) GDPR). The transfer to the United States relies on the EU-U.S. Data Privacy Framework, in which GitHub participates (the European Commission’s adequacy decision of 10 July 2023, Article 45 GDPR), and on the Commission’s Standard Contractual Clauses where that does not apply.

If you write to us

When you write to info@vulpera.it or to our PEC address, we process what you chose to send: your address, your name if you give it, and the content of your message. We use it to answer you and to carry on the conversation that follows.

Writing to us is voluntary, but without your email address we cannot reply.

The legal basis is taking steps at your request before entering a contract (Article 6(1)(b) GDPR), and our legitimate interest in responding to enquiries (Article 6(1)(f)).

Our email runs on Google Workspace, and certified email (PEC) on Aruba PEC S.p.A., an Italian provider. We also use other providers, acting on our behalf, to read and manage email, such as email client apps and AI tools that help us sort messages and draft replies. Some of these providers, Google included, may process messages in the United States; those transfers rely on the EU-U.S. Data Privacy Framework where the provider participates in it, and otherwise on the European Commission’s Standard Contractual Clauses. Apart from these providers, we share it only with public authorities where the law requires it.

We keep correspondence while it is useful to the exchange and to any relationship that comes out of it, then delete it. Correspondence the law requires us to keep, such as letters about a contract or an invoice, is kept for ten years (Article 2220 of the Italian Civil Code).

Your rights

You have the right to ask what personal data we hold about you, to have it corrected or deleted, to restrict how we use it or object to it, and, where applicable, to receive it in a portable format (Articles 15 to 22 GDPR). Write to info@vulpera.it and we will answer.

We make no decisions about you based solely on automated processing, including profiling (Article 22 GDPR).

If you think we have handled your data wrongly, you can lodge a complaint with the Garante per la protezione dei dati personali, the Italian supervisory authority, at www.garanteprivacy.it.