How Unlead processes the personal data of site visitors, people who write to us and clients.

01Who processes the data

The data controller is Unlead di Gabriele Giudici, Via Armando Diaz 29, 20013 Magenta (MI), VAT no. 07471240965, PEC (certified email) amministrazione@pec.unlead.it. For any questions about privacy, write to info@unlead.it.

This policy covers the websites www.unlead.it and www.unleadcloud.com and Unlead's services. It is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018.

02What data we process and why

Browsing the site

The server hosting the site automatically logs certain technical data: IP address, date and time of the request, page requested, browser and operating system. We use this data solely to run the site, protect it from abuse and fix faults; we do not use it to identify visitors.

Legal basis: legitimate interest in the security and operation of the site (Art. 6(1)(f) GDPR).

Requests via the contact form or by email

If you write to us using the form, we process your name, company, email, areas of interest and the text of your message; if you email or phone us, the data you provide. We use it to reply to you and, if you ask, to prepare a proposal. We do not use it for newsletters or promotions.

Name and email are required for us to reply; the other fields are optional.

Legal basis: performance of pre-contractual measures taken at your request (Art. 6(1)(b) GDPR).

Spam protection for the form

To block spam and automated submissions, the contact form uses Cloudflare Turnstile, a service of Cloudflare, Inc. The check only starts on the contact page, when the form appears on screen, and usually does not ask you to solve puzzles. Turnstile collects some technical signals from the browser, such as IP address, User-Agent header and connection characteristics, to tell people apart from automated programs. Cloudflare states that it does not use them to identify or profile people or to target them with advertising.

For the spam check, Cloudflare acts as a data processor on behalf of Unlead. It also uses the same signals to improve its own bot detection and, for that purpose, is an independent controller. Details are in Cloudflare's Turnstile privacy notice.

Legal basis: legitimate interest in protecting the form and our mailbox from spam and abuse (Art. 6(1)(f) GDPR).

Clients

For clients, we process the data needed to sign and manage the contract, deliver the services, invoice and comply with tax and accounting obligations.

Legal basis: performance of the contract (Art. 6(1)(b)) and legal obligations (Art. 6(1)(c) GDPR).

In services where we host client data (websites, email, cloud, ERA software), the client remains the controller of the data it uploads and is responsible for it, including the consent of the individuals it relates to. Unlead processes that data on the client's behalf as data processor (Art. 28 GDPR), in accordance with the contract or the appointment.

03How long we keep it

• Technical browsing data: for as long as needed for site security, and in any case no longer than 12 months, unless an abuse is being investigated.
• Contact requests: for as long as needed to reply and follow up the negotiation, and in any case no longer than 24 months from the last exchange if no business relationship results.
• Client data: for the entire term of the contract and then for 10 years, as required by civil and tax rules on document retention.

04Cookies

The site does not use cookies for profiling, statistics or advertising, and does not use analytics tools such as Google Analytics. Fonts are hosted on our own server, with no connections to external services. For this reason the site does not display a cookie banner.

On the contact page, the form loads Cloudflare Turnstile, described above. Turnstile processes only the technical data needed to detect bots and is not used for statistics or advertising.

Some pages contain YouTube videos. A video does not load until you click "Watch the video". After the click, the video is served from youtube-nocookie.com and Google processes data in accordance with its own privacy policy.

05Who we disclose data to

Data is never published or sold. It may be received only by:

• the suppliers we need in order to work, appointed as data processors: providers of technical services, such as hosting, cloud infrastructure, email and spam protection for the form (Cloudflare), and consultants, such as the tax adviser for client data;
• professionals and authorities, where necessary to fulfil a legal obligation or to establish or defend a legal claim.

If a supplier processes data outside the European Economic Area, the transfer is based on an adequacy decision of the European Commission, such as the EU-US Data Privacy Framework, or on standard contractual clauses.

06How we protect data

The site uses encrypted connections only (HTTPS). Data is stored on systems with access restricted to authorised persons, protected by authentication and backups. We do not take decisions based solely on automated processing.

07Your rights

At any time you may ask to:

• know whether we process your data and receive a copy of it (Art. 15);
• correct or complete it (Art. 16);
• erase it (Art. 17) or restrict its use (Art. 18);
• receive it in a machine-readable format or have it transferred to others (Art. 20);
• object to processing based on legitimate interest (Art. 21).

Write to info@unlead.it: we reply within one month. If you believe the processing infringes the GDPR, you may lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).

08Third-party sites

The site contains links to client and partner sites, such as era-management.com. Those sites have their own policies, for which Unlead is not responsible.

09Updates

We may update this policy when the site, the services or the regulations change. The date at the top shows the latest revision.