Privacy Policy
How we handle your data.
Last updated:
1. Data controller
The data controller is Vitale Systems (legal entity: Francesco Vitale), P.IVA 06178100878, registered address Via Repubblica 51, 95040 Ramacca (CT), Italy. Contact for privacy matters: info@vitalesystems.com.
2. Data we collect
2.1 Browsing data
When you visit this site, Vercel Analytics measures aggregate
traffic: page path, anonymized referrer, and approximate country derived
from the request. The data is aggregated at collection. No cookies, no
localStorage, and no persistent identifier are set on your
device — see our Cookie Policy for the
full picture.
2.2 Communications you initiate
When you email us, book a call via Cal.com, or interact with us directly, we receive the data you choose to share: your name, email, company name, message content, and any meeting metadata Cal.com makes available (calendar selection, time zone).
2.3 Service delivery data
When you become a client, we process data necessary to deliver the service: contact details, billing details, project context (Figma files, design briefs, repository access, etc.), and any other information you share to enable us to ship the agreed work.
3. Why we process this data (purposes & legal basis)
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Replying to inquiries; pre-contractual communications | Art. 6(1)(b) — contract / pre-contractual measures |
| Delivering subscription services to clients | Art. 6(1)(b) — contract performance |
| Tax, accounting, statutory record-keeping | Art. 6(1)(c) — legal obligation |
| Aggregated, cookieless traffic measurement (Vercel Analytics) | Art. 6(1)(f) — legitimate interest (no personal identifiers stored) |
| Security, fraud prevention, abuse mitigation | Art. 6(1)(f) — legitimate interest |
4. Who we share data with (recipients)
We share data only with the following categories of third parties, acting as data processors or independent controllers:
- Hosting provider — Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. See vercel.com/legal/privacy-policy
- Vercel Analytics — Vercel Inc. (same entity as hosting). Cookieless, aggregated traffic measurement. See vercel.com/legal/privacy-policy
- Cal.com — Cal.com, Inc. for scheduling. See cal.com/privacy
- Email provider — [EMAIL_PROVIDER, to be confirmed]
- Payment processor (clients only) — Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland. See stripe.com/privacy
- Tax/accounting advisor (commercialista) — for statutory compliance
We do not sell personal data and we do not share it with parties beyond those listed above without your knowledge.
5. Transfers outside the EU/EEA
Some processors (notably Vercel Inc.) are established in the United States and may process data there. These transfers rely on the EU-US Data Privacy Framework adequacy decision and/or Standard Contractual Clauses (SCC) under GDPR Art. 46. You may request a copy of the SCC documentation via info@vitalesystems.com.
6. How long we keep your data
| Data category | Retention |
|---|---|
| Email inquiries (non-clients) | 24 months from last contact |
| Client engagement records (contracts, invoices, project files) | 10 years (Italian fiscal obligation) |
| Analytics data (anonymized, aggregated) | Per Vercel Analytics retention (rolling, no per-visitor record) |
7. Your rights (GDPR Art. 15–22)
You have the right to:
- Access the personal data we hold about you
- Rectify inaccurate or incomplete data
- Erase your data (subject to legal retention obligations)
- Restrict processing in specific circumstances
- Object to processing based on legitimate interest or direct marketing
- Receive your data in a structured, machine-readable format (data portability)
- Withdraw consent at any time, without affecting prior processing
To exercise any of these rights, email info@vitalesystems.com. We respond within 30 days (extendable to 60 for complex requests).
8. Right to complain
If you believe your data has been mishandled, you have the right to lodge a complaint with the Italian Data Protection Authority: Garante per la Protezione dei Dati Personali, Piazza Venezia n. 11 — 00187 Roma.
9. Cookies
This site does not set cookies or similar tracking technologies. See the Cookie Policy for the full statement.
10. Children
This site is not directed at children under 16. We do not knowingly collect personal data from minors. If you believe a minor has shared data with us, contact us and we will delete it.
11. Security
We take reasonable technical and organisational measures to protect personal data: TLS in transit, access control, principle of least privilege, and processor agreements (DPA) where required. No system is perfectly secure — if a breach affects your data, we will notify you and the Garante within 72 hours as required by GDPR Art. 33–34.
12. Changes to this policy
We may update this policy occasionally. The "Last updated" date at the top reflects the latest version. Material changes will be announced on the site or by email to active clients.
13. Contact
Questions about this policy or your data: info@vitalesystems.com.