Privacy policy

1. Data controller

The data controller is CLIRA S.r.l. startup innovativa, with registered office at Corso Castelfidardo 30/A c/o I3P, 10129 Turin (TO), Italy.

• VAT No.: IT13328870012
• Email: info [at] clira.cloud
• Certified email (PEC): clira [at] pec.it

2. Personal data collected

Through the website https://www.clira.cloud (hereinafter "the site"), CLIRA collects the following categories of personal data:

• Data voluntarily provided through the contact form: full name, email address, subject, and message text.
• Anonymised and aggregated browsing data collected through Google Analytics 4 (only upon consent): pages visited, session duration, approximate geographic origin, device type, and browser.

3. Purposes and legal bases for processing

Personal data are processed for the following purposes, on the following legal bases (Art. 6 EU Regulation 2016/679):

4. Recipients and data processors

Personal data may be shared with the following third parties, acting as data processors pursuant to Art. 28 GDPR:

• Formspree Inc. (USA) — processing and forwarding of contact form data.
• Google LLC (USA) — collection and analysis of browsing data via Google Analytics 4.
• Aruba S.p.A. (Italy) — website hosting.

5. Transfers of data outside the EU

Some data processors are based in the United States of America. Transfers of personal data to the USA are carried out on the basis of the European Commission's adequacy decision regarding the EU-US Data Privacy Framework (implementing decision of 10 July 2023) and, where applicable, on the basis of Standard Contractual Clauses approved by the European Commission pursuant to Articles 44-49 of the GDPR, ensuring an adequate level of protection for personal data.

6. Data retention period

Personal data collected are retained for the time strictly necessary to fulfil the purposes stated:

• Contact form data: retained for the time necessary to respond to the request, then deleted.
• Browsing data (Google Analytics 4): retained according to data retention settings (default: 14 months), in anonymised and aggregated form.

7. Data subject rights

Under Articles 15-22 of EU Regulation 2016/679 (GDPR), you have the right to:

• access your personal data and obtain a copy (Art. 15)
• rectify inaccurate or incomplete data (Art. 16)
• obtain erasure of your data — right to be forgotten (Art. 17)
• restrict the processing of your data (Art. 18)
• receive your data in a structured, machine-readable format — data portability (Art. 20)
• object to the processing of your data (Art. 21)
• withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (Art. 7(3))

To exercise your rights, write to info [at] clira.cloud or clira [at] pec.it. We will respond within 30 days of receiving your request.

8. Automated decision-making and profiling

CLIRA does not carry out any profiling activities nor adopt decisions based solely on automated processing of data, including profiling, that produce legal effects or significantly affect the data subject (Art. 22 GDPR).

9. Supervisory authority

You have the right to lodge a complaint with the competent supervisory authority for the protection of personal data. In Italy, the supervisory authority is:

Garante per la Protezione dei Dati Personali
Piazza Venezia 11, 00187 Rome
www.garanteprivacy.it

10. Changes to this privacy notice

CLIRA reserves the right to amend or update this privacy notice at any time. Changes shall take effect from the date of publication on the site. We encourage you to review this page periodically for any updates.

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