Privacy Policy

This notice describes how personal data is processed for users who visit the site and interact with the services provided, pursuant to Art. 13 of Regulation (EU) 2016/679 ("GDPR") and Legislative Decree 196/2003 as amended by Legislative Decree 101/2018.

1. Data Controller

The data controller is Geniale S.R.L., registered office at Via Torino 6, 80143 Napoli (Campania), operational office at Via Cook 119, 80056 Ercolano (NA) — VAT/CF 03381151202.

For any request, please write to geniale@gruppogeniale.com or via certified email (PEC) to genialesrl@arubapec.it.

The Controller has not appointed a Data Protection Officer (DPO), as the mandatory conditions under Art. 37 GDPR are not met.

2. Categories of data processed

• Navigation data: IT systems automatically acquire, during normal operation, data whose transmission is implicit in the use of Internet protocols (e.g. IP addresses, browser/device type, pages visited). Such data are used in aggregate and anonymous form for statistical and security purposes.
• Voluntarily provided data: name, phone number, e-mail and any information contained in messages, supplied when the user contacts us by e-mail or phone.
• Statistical data: anonymous and aggregated usage data collected, only with prior consent, via analytics tools (see Cookie Policy).

3. Purposes and legal bases

• Responding to enquiries and quotes— legal basis: performance of pre-contractual measures at the data subject's request (Art. 6.1.b GDPR).
• Anonymous/aggregated site usage statistics— legal basis: data subject's consent (Art. 6.1.a GDPR), withdrawable at any time.
• Compliance with legal obligations (e.g. accounting and tax) — legal basis: legal obligation of the Controller (Art. 6.1.c GDPR).
• Establishment, exercise or defence of legal claims — legal basis: legitimate interest of the Controller in protecting its rights (Art. 6.1.f GDPR).

Nature of provision. Providing contact data is optional but necessary to respond to your request: without it we cannot prepare a quote or follow up. Consent to statistical cookies is always optional and does not affect your ability to browse the site.

4. Processing methods

Data are processed by electronic means, adopting adequate technical and organisational measures to ensure security and confidentiality, for the time strictly necessary for the stated purposes. No automated decision-making or profiling takes place.

5. Recipients of data

Data may be processed by authorised personnel and communicated to suppliers acting as data processors, including:

• Vercel Inc. — site hosting and anonymous usage statistics;
• Aruba S.p.A. — standard and certified email (PEC) services;
• consultants and professionals (e.g. accountants) and technical suppliers, appointed as data processors where required.

Data are not disclosed or transferred to third parties for marketing purposes.

6. International data transfers

Some suppliers (e.g. Vercel Inc.) may process data outside the European Economic Area. In such cases the transfer takes place in compliance with Arts. 44 et seq. GDPR, on the basis of adequate safeguards (e.g. Standard Contractual Clauses issued by the European Commission).

7. Retention periods

Contact data are retained for as long as necessary to handle your request. In the absence of a contractual relationship, data related to contact requests are retained for a maximum of 24 months from the last interaction, unless otherwise required by law. If a contract is established, data are retained for the duration of the contract and for 10 years thereafter, in compliance with civil and tax obligations (Art. 2220 of the Italian Civil Code).

8. Data subject rights

At any time you may exercise the rights provided by Arts. 15–22 GDPR:

• access, rectification, erasure and restriction of processing;
• data portability;
• objection to processing;
• withdrawal of consent, without prejudice to the lawfulness of processing based on consent given before withdrawal;
• lodge a complaint with the supervisory authority (Italian Data Protection Authority — www.garanteprivacy.it).

9. How to exercise your rights

Requests should be sent to geniale@gruppogeniale.com or via PEC to genialesrl@arubapec.it. We will respond within the timeframes prescribed by applicable law.

10. Cookies

The site uses cookies and similar technologies as described in the Cookie Policy, where you can manage and withdraw your consent.

This notice may be updated: any changes will be published on this page with the relevant update date.