Privacy Policy
Last updated: January 1, 2026
1. Introduction
PROSPETTIVA DI SRL ("we," "us," or "our"), with its registered office at Via Casoretto, 40, 20131 Milano, Italy, is committed to protecting the privacy and personal data of all visitors to our website and users of our services. This Privacy Policy explains how we collect, use, store, and protect your personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR"), the Italian Legislative Decree No. 196/2003 (Italian Data Protection Code) as amended by Legislative Decree No. 101/2018, and all other applicable data protection legislation.
By accessing or using our website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use our website or submit any personal data to us.
2. Data Controller
The data controller responsible for the processing of your personal data is:
For any questions or concerns regarding this Privacy Policy or the processing of your personal data, please contact us at the email address provided above.
3. Personal Data We Collect
We may collect and process the following categories of personal data:
3.1 Data You Provide Directly
- Contact Information: Full name, email address, and phone number when you submit our contact form or correspond with us via email.
- Program Interest Information: Your selected program of interest and preferred contact method as indicated through our contact form.
- Communication Content: Any messages, comments, or other content you include in your communications with us.
- Consent Records: Records of any consent you provide, including the date, time, and scope of such consent.
3.2 Data Collected Automatically
- Technical Data: IP address, browser type and version, operating system, device type, screen resolution, and language preferences.
- Usage Data: Pages visited, time spent on each page, referral source, navigation paths, and other website interaction data.
- Cookie Data: Information collected through cookies and similar tracking technologies as described in our Cookie Policy.
3.3 Data We Do Not Collect
We do not knowingly collect special categories of personal data (also known as sensitive data), including data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, or data concerning a person's sex life or sexual orientation. We do not collect financial or payment information through our website.
4. Purposes and Legal Bases for Processing
We process your personal data for the following purposes and on the following legal bases under Article 6 of the GDPR:
| Purpose | Legal Basis |
|---|---|
| Responding to your inquiries and contact form submissions | Your consent (Art. 6(1)(a) GDPR); Performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR) |
| Providing information about our educational coaching programs | Legitimate interest (Art. 6(1)(f) GDPR) |
| Improving our website functionality and user experience | Legitimate interest (Art. 6(1)(f) GDPR) |
| Website analytics and performance monitoring | Your consent (Art. 6(1)(a) GDPR) |
| Complying with legal obligations | Legal obligation (Art. 6(1)(c) GDPR) |
| Protecting our rights and preventing fraud | Legitimate interest (Art. 6(1)(f) GDPR) |
5. How We Use Your Personal Data
We use your personal data exclusively for the purposes stated in this Privacy Policy. Specifically, we use your data to:
- Process and respond to your inquiries submitted through our contact form.
- Provide you with information about our coaching and personal development programs available throughout Canada.
- Communicate with you using your preferred contact method, as indicated by you.
- Analyze website usage patterns to improve our website content, structure, and user experience.
- Ensure the security and proper functioning of our website.
- Comply with applicable laws, regulations, and legal processes under Italian and European Union law.
6. Data Sharing and Disclosure
We do not sell, rent, or trade your personal data to third parties. We may share your personal data only in the following limited circumstances:
- Service Providers: We may share data with trusted third-party service providers who assist us in operating our website, conducting our business, or providing services to you. These providers are contractually bound to process your data only on our behalf and in accordance with our instructions and applicable data protection law.
- Legal Requirements: We may disclose your data when required to do so by law, regulation, legal process, or enforceable governmental request by Italian or EU authorities.
- Protection of Rights: We may disclose data when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, to investigate fraud, or to respond to a government request.
7. International Data Transfers
PROSPETTIVA DI SRL is established in Italy and our primary data processing activities occur within the European Economic Area (EEA). If any transfer of personal data outside the EEA is required, we will ensure that appropriate safeguards are in place as required by the GDPR, including:
- Transfers to countries recognized by the European Commission as providing an adequate level of data protection (adequacy decisions).
- Use of Standard Contractual Clauses (SCCs) approved by the European Commission.
- Other appropriate safeguards as permitted under Article 46 of the GDPR.
You may request further information about the safeguards applied to international data transfers by contacting us at [email protected].
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:
- Contact Form Data: Retained for up to 24 months from the date of your last interaction, unless a longer retention period is required for legal compliance or the establishment, exercise, or defense of legal claims.
- Website Analytics Data: Retained for up to 26 months, in anonymized or aggregated form where possible.
- Consent Records: Retained for the duration of the processing activity to which the consent relates, and for a reasonable period thereafter to demonstrate compliance.
- Legal Compliance Data: Retained for the period required by applicable Italian and EU law (e.g., tax and accounting records are retained for 10 years under Italian fiscal regulations).
Upon expiration of the applicable retention period, your personal data will be securely deleted or anonymized.
9. Your Rights Under the GDPR
As a data subject, you have the following rights under the GDPR and applicable Italian data protection law:
Right of Access (Art. 15 GDPR)
You have the right to obtain confirmation of whether we process your personal data and, if so, to access a copy of that data along with supplementary information about the processing.
Right to Rectification (Art. 16 GDPR)
You have the right to request the correction of inaccurate personal data or the completion of incomplete personal data concerning you.
Right to Erasure (Art. 17 GDPR)
You have the right to request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for its original purpose or you withdraw your consent.
Right to Restriction of Processing (Art. 18 GDPR)
You have the right to request that we restrict the processing of your personal data under certain circumstances, such as when you contest the accuracy of the data.
Right to Data Portability (Art. 20 GDPR)
You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance.
Right to Object (Art. 21 GDPR)
You have the right to object to the processing of your personal data based on legitimate interest grounds at any time. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
Right to Withdraw Consent (Art. 7(3) GDPR)
Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Right to Lodge a Complaint
You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), Piazza Venezia 11, 00187 Roma, Italy, website: www.garanteprivacy.it, or with any other competent supervisory authority within the EU.
To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days in accordance with applicable law. We may ask you to verify your identity before processing your request.
10. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and understand usage patterns. For detailed information about the types of cookies we use, how they function, and how you can manage your cookie preferences, please refer to our Cookie Policy.
You may control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality and usability of our website.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Use of HTTPS and SSL/TLS encryption for all data transmitted through our website.
- Server-side validation and secure form processing for all data submissions.
- Access controls to limit data access to authorized personnel only.
- Regular security assessments and updates to our security infrastructure.
- Firewall protection and spam filtering mechanisms.
While we strive to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your data, but we are committed to maintaining and continually improving our security measures.
12. Children's Privacy
Our website and services are not directed at children under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child under 18, we will take immediate steps to delete such data. If you believe that a child under 18 has provided us with personal data, please contact us at [email protected].
13. Third-Party Links
Our website may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to such third-party websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies of any third-party websites you visit.
14. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time. Any changes will be posted on this page with an updated "Last updated" date. We encourage you to review this Privacy Policy periodically for any updates. Material changes may be communicated to you through a notice on our website. Your continued use of the website after any modifications to this Privacy Policy constitutes your acceptance of such modifications.
15. Governing Law and Jurisdiction
This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Italy and the applicable regulations of the European Union. Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts of Milano, Italy, without prejudice to your right to bring proceedings before the courts of your habitual residence if you are a consumer within the EU.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing activities, please contact us:
You may also contact the Italian Data Protection Authority (Garante per la protezione dei dati personali) if you wish to lodge a complaint regarding the processing of your personal data.