Privacy

Who the data controller is

The data controller is [PLACEHOLDER: company name and legal form], with its registered office at [PLACEHOLDER: registered office address]. All company details are in the Legal notice.

For any questions about your data, you can write to us at [PLACEHOLDER: privacy email]. We have not appointed a data protection officer: for a business like ours it is not mandatory.

What data we collect

• Browsing data: when you open the site, the server hosting it automatically records your IP address, the date and time, the page requested and the type of browser.
• Booking data: when you book the call, you give us your first name, last name and email and, if you wish, your phone number and company name. We use the phone number only to call you if the video call does not start.
• Call data: the call takes place by video call on Google Meet. Only if you agree, we record and transcribe it with Fathom, an AI tool, to have notes of the call. We ask you when you book and again at the start of the call: if you say no, the call still takes place, without recording.
• Email data: if you write to us, we process your address and what you write.

Why we use it and on what legal basis

• Organizing and holding the call you asked for and replying to your emails: these are steps you request before a possible contract (GDPR, Article 6(1)(b)).
• Recording and transcribing the call: only with your consent (point (a)), which you can withdraw at any time.
• Keeping the site secure and working, using browsing data: this is our legitimate interest, namely preventing abuse and attacks and fixing faults (point (f)).
• If you become a client: performing the contract (point (b)) and complying with legal obligations, for example accounting and tax obligations (point (c)).

[PLACEHOLDER: to be confirmed whether we will use contact details for newsletters or promotional messages; in that case your consent is required and must be stated here]

Who we share it with

We rely on some providers who process data on our behalf, only for the service they provide to us, under a written data processing agreement [PLACEHOLDER: to be signed with each provider before publication]:

• website hosting: [PLACEHOLDER: provider];
• call booking: Google (Google Calendar, through Google Workspace);
• video calls: Google (Google Meet, through Google Workspace);
• call recording and transcription: Fathom;
• email: [PLACEHOLDER: provider].

Apart from them, data reaches public authorities only when the law requires it.

Transfers outside the European Economic Area

Some providers may process data outside the European Economic Area, for example in the United States. In these cases the transfer is protected: for Google by the EU-US Data Privacy Framework, which Google has joined, and by the European Commission's standard contractual clauses included in its data processing agreement; for Fathom by the EU-US Data Privacy Framework, which Fathom has joined; for the other providers by [PLACEHOLDER: mechanism for each provider]. You can ask us for a copy of the safeguards by writing to [PLACEHOLDER: privacy email].

How long we keep it

• Browsing data: [PLACEHOLDER: duration], then it is deleted.
• Booking and email data, and call recordings and transcripts, if you do not become a client: 12 months from the last contact, then we delete them.
• Client data: for the duration of the contract and then for as long as the law requires, for example for accounting [PLACEHOLDER: duration to be confirmed with the professional].

Automated decisions

We do not make automated decisions about you and we do not create profiles.

Are you required to give us your data?

No. Without your name and email, however, we cannot schedule the call or reply to you. Consent to recording, instead, is up to you: without it, the call still takes place.

Cookies

A cookie is a small file that a website saves on your device. This site does not use cookies or any other tools that save or read information on your device: no analytics, no advertising, no content from other sites embedded in the pages. That is why we do not ask for your consent. [PLACEHOLDER: to be checked with the chosen hosting provider]

The button to book the call opens the Google Calendar booking page in a new tab, which uses Google's cookies under its privacy policy (opens in a new tab).

If we add cookies or analytics in the future, we will update this page and, where required, ask for your consent before using them.

Your rights

You can ask us at any time to:

• see what data we hold about you and get a copy of it;
• correct or complete it;
• delete it;
• restrict its use;
• receive it in a machine-readable format, to take it elsewhere;
• object to its use based on our legitimate interest;
• withdraw your consent to recording, without affecting what was done before.

Just write to [PLACEHOLDER: privacy email]. We reply within one month, as the GDPR requires.

Complaints

If you believe we are processing your data incorrectly, you can lodge a complaint with the data protection supervisory authority of the country where you live or work, or where the infringement took place.

Changes

If we change this policy, we publish the new version here, with the date of the update at the top of the page.

Contact

For questions about this page: [PLACEHOLDER: privacy email].