⚠ Draft to be reviewed by a professional
This text is a working draft: it is not legal advice and must not be published as it is. Points marked [TO BE VERIFIED] must be checked by a privacy (GDPR) consultant before publication. The Italian version is the reference text [TO BE VERIFIED].
Privacy notice
Under Articles 13 and 14 of Regulation (EU) 2016/679 («GDPR») and Italian Legislative Decree 196/2003. Draft of 22 October 2026.
1. Data controller
Oliviero Dall'Asta, sole proprietorship (ditta individuale) trading as WebbyDO
Registered office: Via G. Randaccio 39, 25128 Brescia, Italy · VAT no. (P.IVA) 03269620179
Email: oliviero@webbydo.it · Phone +39 393 670 0296
Certified email (PEC): olivierodallasta@pec.it
No Data Protection Officer (DPO) has been appointed [TO BE VERIFIED] that one is not required.
2. What data we process
- Browsing data: IP address, date and time, page visited, browser and operating system, recorded automatically in the hosting provider’s technical logs.
- Data you give us by email, phone, WhatsApp or the contact form: name, company, email, phone, content of the message.
- Data of clients and suppliers needed for contracts, invoices and tax obligations.
- Data we may see while working on a client’s systems: processed only on the client’s instructions, under a separate agreement (Art. 28 GDPR) and any NDA [TO BE VERIFIED].
We do not process special categories of data (Art. 9 GDPR). Please do not send any.
3. Purposes and legal basis
| Purpose | Legal basis |
|---|---|
| Answering your requests for information or a proposal | Pre-contractual steps at your request (Art. 6(1)(b) GDPR) |
| Carrying out consulting and development work | Performance of a contract (Art. 6(1)(b) GDPR) |
| Invoicing and legal obligations (tax, accounting) | Legal obligation (Art. 6(1)(c) GDPR) |
| Security and operation of the website (technical logs) | Legitimate interest (Art. 6(1)(f) GDPR) |
| Defending our rights in case of disputes | Legitimate interest (Art. 6(1)(f) GDPR) |
We do not carry out profiling or automated decision-making (Art. 22 GDPR). We use software and artificial intelligence tools in our work, with human review; no client secrets or credentials are placed in the context of AI tools [TO BE VERIFIED]: list of the providers of these tools.
4. Contact form
When it is active, the contact form will send the data you enter to the controller’s email address through an email delivery service chosen at that time [TO BE VERIFIED]: name of the service. In this demo draft the form is disabled and sends no data.
5. Cookies and statistics
The website uses no profiling or advertising cookies. It may use Cloudflare Web Analytics, which according to the provider uses no cookies and gives only aggregated data [TO BE VERIFIED] whether it is active on the final website. The browser may store only technical preferences (localStorage), for example a dismissed notice. For this reason no cookie banner is planned at present [TO BE VERIFIED].
6. Who receives the data
Data is not sold or published. It may be processed, as processors (Art. 28 GDPR), by the providers of the services we use:
- hosting of webbydo.com [TO BE VERIFIED]: final provider; draft previews: Cloudflare;
- email: Aruba S.p.A. (mailbox oliviero@webbydo.it), with automatic forwarding to Gmail (Google) [TO BE VERIFIED];
- accountant and advisers, for legal obligations;
- authorities, only when required by law.
7. Transfers outside the European Union
Some providers may process data outside the EU. In that case the transfer relies on the safeguards of the GDPR, such as adequacy decisions (EU-U.S. Data Privacy Framework) or standard contractual clauses [TO BE VERIFIED] provider by provider.
8. How long we keep the data
- Contact requests with no follow-up: 12 months from the last exchange [TO BE VERIFIED].
- Contract and invoice data: 10 years, as required for accounting records (Art. 2220 of the Italian Civil Code).
- Technical logs: according to the hosting provider’s settings [TO BE VERIFIED].
9. Your rights
You can ask at any time to access, correct or erase your data, restrict processing, receive it in a portable format, and object to processing based on legitimate interest (Articles 15–21 GDPR). Write to oliviero@webbydo.it. You can also lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or with the authority of your country.
10. Changes
This notice may be updated. The current version is always on this page, with the date of the last update: 22 October 2026 (draft).