1. Data controller

This website is operated by Velune Como. For the purposes of data protection law, Velune Como is the controller of your personal data.

Registered name Velune Como. Registered address Via Parini 10, 22100 Como, Italy. VAT / P.IVA 04324330135. Contact: info@velunecomo.eu

2. What we process

We process personal data only when you give it to us, where it is technically necessary for the site to work, or, for website statistics, with your consent:

  • What you send through the contact form: name, company, e-mail address, country, enquiry type and the content of your message.
  • If you write to us directly: your e-mail address and the content of the correspondence.
  • Server logs: IP address, browser and device information, time of visit — kept for security and technical operation.
  • A language preference stored in your browser. It is never sent to us; see the Cookie Policy.
  • Website statistics, only if you accept them in the cookie banner: a random identifier stored in a cookie, the pages you visit and technical data about your device, collected through Google Analytics 4. See section 11 and the Cookie Policy.

We do not ask for special categories of personal data. Please do not include such information in the forms.

3. Why we process it

  • To answer your enquiry and your questions.
  • To assess brand representation, retail and partnership requests.
  • To manage an established business relationship.
  • To keep the site secure, fix faults and improve how it works.
  • To meet legal obligations that apply to us.
  • With your consent, to measure in aggregate how the site is used so that we can improve it (see section 11).

We do not sell your data and do not pass it to third parties for marketing. We do not send you marketing messages without your consent.

4. Legal basis

Our processing rests on the following grounds under Article 6 of the EU General Data Protection Regulation (GDPR):

  • Pre-contractual steps and performance of a contract — to answer your enquiry and establish a business relationship (Art. 6(1)(b)).
  • Legitimate interest — site security, prevention of misuse and management of correspondence (Art. 6(1)(f)).
  • Consent — for non-essential cookies and optional communications (Art. 6(1)(a)); you may withdraw consent at any time.
  • Legal obligation — records we are required to keep (Art. 6(1)(c)).

For enquiries made from Türkiye, the corresponding conditions in Article 5 of Law no. 6698 on the Protection of Personal Data apply.

5. How long we keep it

  • Enquiries that do not lead anywhere: 24 months from the last correspondence.
  • Enquiries that become a business relationship: for the duration of the relationship and, after it ends, for the applicable limitation periods.
  • Server logs: 12 months.
  • Where law requires longer retention, that period applies.
  • Website statistics: user-level and event-level data in Google Analytics, 2 months; analytics cookies, up to 6 months; your cookie choice, 6 months.

When the period ends, data is deleted or irreversibly anonymised.

6. Who we share it with

We share your data only to the extent needed to provide the service, and only with providers bound by a written agreement:

  • Hosting and infrastructure provider: Hostinger.
  • E-mail and form delivery provider: Hostinger.
  • Content management and database infrastructure.
  • Competent public authorities where legally required.
  • Web analytics provider: Google Ireland Limited (only if you have given consent; see the Cookie Policy).

These providers act as processors and may not use your data for their own purposes.

7. Transfers outside the EEA

Your data is processed primarily within the European Economic Area. Where a provider makes a transfer outside the EEA necessary, it is made on the basis of a European Commission adequacy decision or standard contractual clauses (SCCs). We will share the safeguard used on request.

8. Your rights

You have the following rights over your personal data:

  • To access your data and obtain a copy.
  • To have inaccurate or incomplete data corrected.
  • To have your data erased.
  • To have processing restricted.
  • To receive your data in a structured format and have it ported.
  • To object to processing.
  • To withdraw consent you have given.

To exercise these rights, write to info@velunecomo.eu. We answer within one month at the latest.

If our answer does not satisfy you, you may complain to the Garante per la protezione dei dati personali in Italy, or to the Personal Data Protection Authority (KVKK) if you are writing from Türkiye.

9. Security

We apply technical and organisational measures to protect your data against unauthorised access, loss and alteration: encryption in transit (HTTPS), access control, and written confidentiality undertakings with our providers. No transmission over the internet is entirely secure.

10. Cookies

How this site uses cookies and browser storage is explained separately in the Cookie Policy.

11. Website statistics (Google Analytics 4)

  • Purpose: to measure in aggregate how the site is used (visits, pages viewed, where visitors come from, country, type of device) in order to improve its content and how it works. Not used for advertising, profiling or marketing.
  • Data: online identifiers (the random identifier in the `_ga` cookies); browsing data (pages, date and time, length of visit, referring page); technical data about your device and browser; approximate location (country and region) derived from your IP address. For visitors in the EU, Google does not log or store the IP address. We do not use your name or e-mail address for this purpose and do not link this data to enquiries sent through the contact form.
  • Legal basis: your consent (Art. 6(1)(a) GDPR; Art. 122 of the Italian Personal Data Protection Code). Giving consent is optional; refusing it has no effect on your use of the site.
  • Recipients: Google Ireland Limited, acting as our processor under Article 28 GDPR, and its sub-processors, including Google LLC.
  • Transfers outside the EEA: to Google LLC in the United States, on the basis of the EU-U.S. Data Privacy Framework adequacy decision (Implementing Decision (EU) 2023/1795) and, where it does not apply, standard contractual clauses.
  • Retention: user-level and event-level data in Google Analytics: 2 months. Analytics cookies: up to 6 months. Your cookie choice: 6 months.
  • Your rights: you may withdraw consent at any time through "Cookie preferences" at the bottom of every page, without affecting earlier processing; the other rights set out in this policy also apply. Because Google Analytics data is linked only to a random identifier, we may not be able to identify you within it (Art. 11 GDPR); the simplest way to have it removed is to withdraw consent or delete the site's cookies. You may lodge a complaint with the Garante per la protezione dei dati personali.
  • No automated decision-making that produces legal or similarly significant effects takes place.

12. Changes

We update this text when needed. The current version is always published on this page and the date above is changed. We will announce any substantial change on the site.

13. Contact

For any question about this policy: info@velunecomo.eu