Privacy Policy

Data Controller

Palomba & Co., Via Pasolini Snc, 81100 Caserta (CE) — Italy. Email: palomba.salesagents@gmail.com. The Controller may be contacted at any time to exercise GDPR rights or request information about processing.

Data Protection Officer (DPO)

The Controller has not appointed a DPO as the conditions of art. 37 GDPR do not apply. For any privacy-related request, please contact the Controller directly using the contacts above.

Categories of Data Processed

The website collects and processes the following categories of personal data:

• Contact data voluntarily provided through forms (first name, last name, email, phone, company, message).
• Browsing data automatically collected by IT systems (IP address, requested URLs, timestamp, user agent) for statistical and security purposes.
• Cookies and identifiers, as described in the Cookie Policy.

Purposes and Legal Basis of Processing

Personal data are processed for the following purposes:

• Responding to enquiries sent through contact forms. Legal basis: art. 6(1)(b) GDPR (pre-contractual measures) and (f) (legitimate interest in handling enquiries).
• Legal, tax and accounting obligations in the event of a commercial relationship. Legal basis: art. 6(1)(c) GDPR.
• Site security and operation, fraud and abuse prevention. Legal basis: art. 6(1)(f) GDPR.
• Analytics and marketing cookies, subject to consent. Legal basis: art. 6(1)(a) GDPR.

Nature of Provision

Provision of data via forms is optional but necessary to receive a response. Without the requested data we will not be able to follow up on the enquiry.

Recipients and Categories of Recipients

Data are not disseminated. They may be disclosed to parties acting as Processors under art. 28 GDPR, including: hosting and cloud providers, email providers, Cybot A/S (Cookiebot), legal and tax advisors. The updated list of Processors is available upon request.

Transfer Outside the EU

Some providers may transfer data outside the European Economic Area. In such cases, transfers are made on the basis of EU Commission adequacy decisions or Standard Contractual Clauses under art. 46 GDPR, ensuring an adequate level of protection.

Retention Period

• Contact form data: for the time necessary to handle the enquiry and, in the absence of follow-up, for a maximum of 24 months.
• Data relating to commercial relationships: for the duration of the relationship and for 10 years thereafter for tax purposes (art. 2220 of the Italian Civil Code).
• Browsing logs: maximum 12 months, except for requests from judicial authorities.
• Cookies: as per the durations indicated in the Cookie Policy.

Rights of the Data Subject

The user may exercise the following rights at any time, free of charge, under arts. 15-22 GDPR:

• right of access to their data (art. 15);
• right of rectification (art. 16) and erasure (art. 17);
• right to restrict processing (art. 18);
• right to data portability (art. 20);
• right to object to processing (art. 21);
• right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise these rights, write to palomba.salesagents@gmail.com. The Controller will reply within 30 days from receipt of the request.

Right to Lodge a Complaint

The data subject has the right to lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it) or with the supervisory authority of their country of residence, if they believe that the processing infringes the GDPR.

Automated Decision-Making

The Controller does not carry out any automated decision-making, including profiling, within the meaning of art. 22 GDPR.

Changes to this Notice

The Controller reserves the right to amend this notice. Changes will be published on this page with the date of last update.