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Privacy & Policy

Last updated: April 4, 2025

This privacy policy is provided pursuant to Article 13 of Regulation (EU) 2016/679 ("GDPR") and applies to the website of Totem Marketing, accessible at [www.totemmarketing.it].

1. Data Controller

The Data Controller is Totem Marketing, represented by its owners Spedicati Stefano and Michele Ongarato, with registered office at [Full address].
Email: [Contact email]
Certified Email (PEC): [If applicable]

2. Types of Data Collected

While browsing this website, the following categories of personal data may be collected:

  • Identification Data: name, surname, email address, phone number;

  • Browsing Data: IP address, browser and device information, pages visited, timestamps;

  • Voluntarily Provided Data: information submitted through contact forms, newsletter subscriptions, quote or consultation requests;

  • Cookies: technical, analytical, and, with prior consent, profiling cookies.

3. Purpose and Legal Basis of Processing

Personal data are processed for the following purposes and on the following legal bases:

PurposeLegal Basis

Responding to contact form submissionsData subject’s consent

Newsletter subscriptions and promotional communicationConsent

Contractual or pre-contractual obligationsPerformance of a contract

Legal and tax obligationsLegal obligation

Website performance and analyticsLegitimate interest / Consent (for non-essential cookies)

Marketing and profiling (if enabled)Explicit consent

4. Data Processing Methods

Data are processed using digital and/or paper-based tools, with technical and organizational measures in place to ensure the confidentiality, integrity, and security of the data in accordance with Articles 5 and 32 of the GDPR.

5. Data Disclosure and Transfer

Personal data will not be disseminated. However, they may be shared with:

  • Authorized employees and collaborators;

  • Third-party service providers involved in technical, administrative, or marketing operations (e.g., hosting providers, CRM platforms, email marketing tools, accounting consultants);

  • Public authorities, when required by law.

If data are transferred outside the European Economic Area, the transfer will comply with the safeguards required by the GDPR (e.g., adequacy decisions, Standard Contractual Clauses).

6. Data Retention Period

Data will be retained as follows:

  • Contact data: up to 24 months from last interaction;

  • Administrative/contractual data: up to 10 years for legal compliance;

  • Data processed under consent: until consent is withdrawn;

  • Cookies: according to the durations set in the Cookie Policy.

7. Data Subject Rights

Under Articles 15–22 of the GDPR, data subjects have the right to:

  • Access their personal data;

  • Request rectification or updates;

  • Request erasure (right to be forgotten), where applicable;

  • Restrict processing;

  • Object to processing on legitimate grounds;

  • Receive data in a structured, commonly used, and machine-readable format (data portability);

  • Withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal;

  • Lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).

To exercise these rights, users may contact: [Contact email] or PEC: [PEC, if available].

8. Cookies

This website uses technical cookies for functionality and, with user consent, third-party cookies for analytical and marketing purposes. For more information, please refer to the Cookie Policy.

9. Changes to This Policy

Totem Marketing reserves the right to update or amend this Privacy Policy at any time in compliance with changes in law or in the company’s services. Users are encouraged to regularly review this section.

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