Personal data privacy notice
Under Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)
Last updated: 3 October 2026
1. Data controller
- Practice
- Studio Carlo Cassarino
- Controller
- Ing. Carlo Cassarino
- VAT number
- 11886391009
- Registered address
- Via Alberico II n° 15, 00193 Roma (RM), Italy
- info@studiocassarino.org
- Certified email (PEC)
- protocollo@pec.studiocassarino.org
No Data Protection Officer (DPO) has been appointed, as the processing does not fall within the circumstances requiring appointment under Article 37 GDPR.
2. Categories of data and purposes
2.1 Browsing data
The systems operating the website receive technical data transmitted through Internet protocols. These may include your IP address, browser type, request time and requested resource. These data are processed to deliver the website, check its operation and protect it from misuse. Technical logs may be retained by the hosting provider. Google Analytics statistics are processed separately, only after consent.
2.2 Data you provide through the website forms
The website provides a message form and a technical site-visit request form. The message form requires your first name, surname, email address, telephone number, subject and message; the organisation field is optional. A site-visit request also includes the property address and geographical coordinates, services of interest, and preferred appointment date and time. These data are processed to answer your request, arrange a possible visit, manage any resulting pre-contractual or contractual relationship, and meet legal obligations. They are not sold or used by the practice for marketing.
2.3 Third-party services
The website uses third-party services that may process user data as independent controllers or processors. For services covered by Google’s general privacy policy, Google Ireland Limited is the controller for users in the EEA and Switzerland, subject to exceptions for specific services; Google LLC participates in service provision and international transfers. Their privacy notices provide further details.
- Google Analytics 4 (Google LLC): website traffic analysis. With consent, it also measures contact clicks and form stages (start, error and request received), without sending message contents, names, email addresses or telephone numbers. It processes pseudonymised identifiers and browsing data. According to Google, IP addresses are used during collection to estimate location and then discarded, without being logged or stored in Analytics. These data are not anonymous under the GDPR. Legal basis: consent (Article 6(1)(a)). Google Privacy Policy.
- Google reCAPTCHA v3 (Google LLC): anti-spam protection for both website forms. It analyses user behaviour to distinguish human traffic from automated traffic, without requiring an explicit action. Legal basis: the controller's legitimate interest in website security (Article 6(1)(f)). This website is protected by reCAPTCHA; Google's Privacy Policy and Terms of Service apply.
- OpenStreetMap Foundation: supplies map tiles for the site-visit form. When the map loads, your browser connects to the provider's servers, which may receive your IP address, technical connection data and information about the requested tiles. The Foundation acts as an independent controller for its own services. Legal basis for loading the map: legitimate interest in locating the property involved in the request (Article 6(1)(f)). OpenStreetMap Privacy Policy.
- HERE Geocoding and Search (HERE Global B.V.): address search, autocomplete and geocoding in the site-visit form. Typing or selecting an address, filling the fields or moving the marker may send the required address text or coordinates to HERE. HERE does not supply the map tiles, and the website does not use a HERE traffic-data service. Legal basis: legitimate interest in arranging the requested visit (Article 6(1)(f)). HERE Privacy Policy.
- Google Apps Script and its integrated Maps service (Google LLC): route requests to the controller's mailbox and check appointment availability. Apps Script processes form data: name, surname, email, telephone, subject and message; for visits, also address, services and preferred date and time. To check whether a driving journey fits an appointment time, Maps receives departure and destination coordinates and the journey time. The route query does not contain the applicant's name or contact details. Processing terms depend on the Google service configuration and agreements in use. Google Privacy Policy.
- Gmail and Google Calendar (Google LLC): the forms use the controller's personal Google account. Requests are notified to his mailbox through Gmail. When a local visit passes the automatic checks, the appointment is recorded in the practice's calendar. For a long journey, outbound travel, the visit and return travel may instead be provisionally reserved pending the controller's personal confirmation. Data include name, surname, email, telephone, property address, requested services and proposed date and time. The terms and privacy notices of the Google services used apply. Google Privacy Policy.
- Aruba S.p.A.: website hosting and infrastructure. Data locations and any subcontractors depend on the contracted service and its documentation. Aruba Privacy Notice (Italian).
3. Legal bases
Personal data are processed under the following bases in Article 6 GDPR:
- Pre-contractual steps or performance of a contract (Article 6(1)(b)): form data used to respond to requests and arrange a possible visit, including calendar entries and email notifications.
- Legitimate interests (Article 6(1)(f)): browsing data for website security; data processed through reCAPTCHA, OpenStreetMap and HERE for form operation and property location.
- Consent (Article 6(1)(a)): data collected by Google Analytics 4 through optional third-party analytical cookies. Consent is requested through the website banner and can be withdrawn at any time.
- Legal obligation (Article 6(1)(c)): processing required by law, such as invoicing and professional obligations.
4. Recipients
The practice does not sell personal data or make them public. Data may be disclosed, to the extent necessary, to the following recipients. Providers acting as independent controllers process data under their own privacy notices:
- Technical service providers, including hosting, email and cloud infrastructure, according to the roles and agreements for the service used;
- Google Ireland Limited and Google LLC, OpenStreetMap Foundation, HERE Global B.V. and other providers for the purposes described in section 2.3;
- Public and judicial authorities where required by law.
5. Transfers outside the European Union
The services listed in section 2.3 may involve processing outside the European Economic Area. Transfers must rely on the safeguards under Articles 44–49 GDPR, according to the terms of the provider and the service used. OpenStreetMap tiles are requested directly from the Foundation's infrastructure, which may use servers in several countries. Provider privacy notices and relevant contractual documents describe their safeguards.
For Analytics, Google states that it relies on the EU–US Data Privacy Framework for transfers covered by its certification and on Standard Contractual Clauses in the circumstances provided in its service terms. See Google Analytics transfer safeguards and data processing terms. For the personal Google account services used by the forms, Google describes adequacy decisions, the Data Privacy Framework and Standard Contractual Clauses in its data transfer documentation. HERE states that it uses Standard Contractual Clauses where necessary, together with technical and organisational measures. Further information or a copy of the relevant safeguards can be requested from the controller using the contact details in section 1.
6. Retention periods
Data are retained for as long as necessary for their purposes, respecting the storage limitation principle in Article 5(1)(e) GDPR:
- Browsing data: technical logs are retained for the period configured with the hosting provider, limited to security, maintenance and investigation of misuse.
- Form data: retained as needed to handle the request. If a professional engagement follows, relevant documents are retained according to legal obligations and the need to protect rights connected with the engagement. The period depends on the documents and relationship concerned.
- Google Analytics 4 data: the website's property is configured to retain event data for 2 months and user data for 14 months. Resetting the retention period for user identifiers on new activity is enabled, so the 14-month period runs from the latest activity. These limits do not apply to most standard aggregated reports, which may have different retention periods.
7. Your rights
Under Articles 15–22 GDPR, you have the right to:
- Article 15: obtain confirmation of whether your personal data are being processed and, if so, a copy of those data (access);
- Article 16: have inaccurate data corrected or incomplete data completed (rectification);
- Article 17: have data deleted in the circumstances provided by law (erasure);
- Article 18: obtain restriction of processing;
- Article 20: receive data in a structured, commonly used, machine-readable format and transmit them to another controller, where applicable (portability);
- Article 21: object to processing based on the controller’s legitimate interests;
- Article 7(3): withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
8. Exercising your rights
Send written requests to the controller using the contact details in section 1. The controller will respond without undue delay and within one month of receiving the request (Article 12(3) GDPR). This may be extended by two further months where necessary because of the complexity or number of requests; you will be informed of the extension.
9. Complaints to a supervisory authority
Without prejudice to other administrative or judicial remedies, you may lodge a complaint with the competent supervisory authority. In Italy, this is the Garante per la Protezione dei Dati Personali: www.garanteprivacy.it, Piazza Venezia 11, 00187 Roma, Italy.
10. Changes to this notice
The controller may update this notice. Changes will be published on this page with a revised date at the beginning. Please check this page periodically.