Privacy Policy

1. Data Controller

The Data Controller is Havermond & Partners Srl, with registered office in Via Andrea Costa 2, 20131 Milan (MI), VAT Number and Tax Code 14740750964 — email: privacy@havermondepartners.com [TO BE CONFIRMED].

2. Types of Data Collected

The Controller processes the following categories of data:

• Contact data voluntarily provided via the "Contact" form (first name, last name, email, phone number, company, message).
• Navigation data automatically collected by IT systems (IP address, browser type, operating system, pages visited, timestamp).
• Cookies and online identifiers as described in the Cookie Policy.

3. Purposes and Legal Bases

• Responding to contact requests — legal basis: performance of pre-contractual measures at the request of the data subject (Art. 6, para. 1, letter b GDPR).
• Fulfilment of legal obligations to which the Controller is subject (Art. 6, para. 1, letter c GDPR).
• Website improvement and aggregated statistical analysis — legal basis: consent of the data subject (Art. 6, para. 1, letter a GDPR), given via the specific cookie banner.
• Protection of the Controller's rights in judicial proceedings — legitimate interest (Art. 6, para. 1, letter f GDPR).

4. Processing Methods and Security

Data is processed using electronic tools and with logic strictly related to the stated purposes. The Controller adopts appropriate technical and organisational measures pursuant to Art. 32 GDPR to ensure the confidentiality, integrity and availability of personal data.

5. Recipients and External Processors

Data may be disclosed to third parties acting as Data Processors (Art. 28 GDPR), including: hosting and infrastructure service providers, email service providers, analytical and marketing tool providers (Google, Meta), legal and tax consultants. The updated list is available upon request. [TO BE COMPLETED]

6. Transfers Outside the EU

Some providers (in particular Google LLC and Meta Platforms Inc.) may involve the transfer of personal data to countries outside the European Economic Area. Such transfers are carried out in compliance with the safeguards provided for in Articles 44 et seq. of the GDPR, in particular through Standard Contractual Clauses adopted by the European Commission (Art. 46 GDPR) and, where applicable, on the basis of adequacy decisions.

7. Retention Period

Data provided via the contact form is retained for the time strictly necessary to fulfil the request and, in any case, for no longer than 24 months from the last contact, unless otherwise required by law or for the establishment and defence of a right in judicial proceedings. Navigation data and cookies are retained according to the terms indicated in the Cookie Policy.

8. Data Subject's Rights

Pursuant to Articles 15-22 GDPR, the data subject has the right to ask the Controller for access to their data, rectification, erasure, restriction of processing, data portability, objection to processing and, where applicable, to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. The right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it) is also recognised. Requests can be sent to privacy@havermondepartners.com.

9. Changes to the Information Notice

The Controller reserves the right to update this information notice to adapt it to subsequent regulatory or organisational changes. The version currently in force is published on this page with an indication of the last update date.