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Privacy Policy pursuant to Article 13 of EU Regulation 2016/679 (GDPR)

Last update: October 23, 2026

1. Data Controller

The Data Controller of personal data is Tradigo Giovanni S.r.l. (hereinafter "Tradigo"), with registered office at Via Privata Bolivia 15, 20157 Milan, Italy.

• Email: info@tradigo.it

• Phone: +39 02 3321171

• Website: https://www.tradigo.it

2. Scope of Application

This privacy policy describes how Tradigo collects and processes personal data of users who visit its website, consult the product catalog, request information, or subscribe to the newsletter.

The processing is carried out in compliance with EU Regulation 2016/679 (GDPR), Legislative Decree 196/2003 as amended, and other applicable data protection provisions.

3. Categories of Personal Data Processed

Navigation Data

During browsing, the IT systems and software procedures used to operate this website may acquire technical information such as IP addresses, browser type, operating system, pages visited, access times, and information regarding site functionality.

This information is processed to ensure the operation and security of the site and, where permitted, to analyze its usage.

Data Provided Voluntarily

When the user fills out a contact form or submits a request, Tradigo may collect name, surname, email address, company name, phone number, and the content of the communication, based on the fields present in the form.

Newsletter Data

When the user subscribes to the newsletter, Tradigo collects the email address, information regarding the subscription and the granting of consent, as well as any communication preferences.

Through Wix Email Marketing, information regarding message delivery, opens, and link clicks within sent communications may also be collected.

4. Purposes and Legal Bases for Processing

Tradigo processes personal data for the following purposes:

A. Management of Contact and Information Requests

To respond to user inquiries, provide information on products and services, and handle any preliminary commercial communications.

• Legal basis: Execution of pre-contractual measures taken at the request of the data subject pursuant to Article 6(1)(b) of the GDPR, where applicable; in other cases, legitimate interest of the Controller to manage received communications pursuant to Article 6(1)(f).

B. Operation and Security of the Site

To ensure the proper functioning of the site, prevent misuse, protect IT systems, and resolve technical issues.

• Legal basis: Legitimate interest of the Controller pursuant to Article 6(1)(f) of the GDPR, and compliance with legal obligations where applicable.

C. Statistical Analysis of Site Usage

To analyze traffic and browsing patterns, understand which content is most visited, and improve user experience. For this purpose, Tradigo uses Google Analytics 4.

• Legal basis: For analytics cookies and tracking tools not exempt from the consent requirement, processing is subject to the user's prior consent pursuant to Article 6(1)(a) of the GDPR and applicable cookie regulations.

D. Newsletter and Commercial Communications

To send, subject to the data subject's prior consent, updates on products, company news, informational content, initiatives, and promotional communications from Tradigo.

• Legal basis: Consent of the data subject pursuant to Article 6(1)(a) of the GDPR. Subscription is voluntary. Consent may be revoked at any time without affecting the lawfulness of processing based on consent before its withdrawal.

E. Analysis of Newsletter Interactions

To detect message delivery, open rates, and link clicks within newsletters to evaluate the effectiveness of communications and improve sent content. Statistics may be associated with the recipient's email address. They are not used to make solely automated decisions that produce legal or similarly significant effects on the data subject.

• Legal basis: Individual interaction tracking is carried out subject to specific consent, where required by applicable law. In the absence of such consent, Tradigo limits processing to technical information necessary to manage the service and effectively anonymous statistics.

5. Nature of Providing Data

Providing data marked as mandatory in contact forms is necessary to enable Tradigo to process the request. Failure to provide such data may make it impossible to respond.

Subscribing to the newsletter and granting the corresponding consent is optional. Refusing consent does not limit the ability to browse the website or request information.

6. Processing Methods and Security

Personal data are processed using automated and IT tools, in a manner appropriate to the indicated purposes.

Tradigo adopts appropriate technical and organizational measures to protect personal data against unauthorized access, loss, destruction, alteration, or unlawful disclosure, in accordance with Article 32 of the GDPR.

Access to data is restricted to authorized personnel and providers who need it to perform their assigned duties.

7. Recipients of Personal Data

Personal data may be communicated to entities supporting Tradigo in managing the website and business activities, including:

• Wix, for hosting, website management, contact forms, and email marketing services.

• Google, for statistical site analysis services.

• Authorized IT and professional service providers.

• Public authorities, where required by law.

Service providers processing personal data on behalf of Tradigo are designated, when necessary, as Data Processors pursuant to Article 28 of the GDPR.

Data are not transferred to third parties for independent commercial purposes, unless explicitly provided for and supported by a suitable legal basis.

8. International Transfers

The use of international technology providers, including Wix and Google, may involve the processing or transfer of personal data to countries outside the European Economic Area (EEA).

When such transfers occur, the conditions under Chapter V of the GDPR are applied through European Commission adequacy decisions, Standard Contractual Clauses, or other legitimate transfer mechanisms, as applicable.

For information on the safeguards adopted or to obtain a copy, you may contact Tradigo at info@tradigo.it.

9. Data Retention Period

Personal data are stored for no longer than necessary to achieve the purposes for which they were collected.

Specifically:

• Contact Requests: Data related to inquiries that do not lead to a commercial relationship are retained for up to 24 months from the last meaningful interaction, unless further retention is documented as necessary.

• Commercial Relationships: Data and documents subject to retention obligations or necessary to protect rights are retained for the duration of the relationship and for additional periods required by law, ordinarily up to 10 years where justified.

• Newsletter: Subscription data are retained until consent is revoked or the service is discontinued, with periodic reviews of their relevance.

• Individual Newsletter Statistics: Open and click tracking information is retained for a maximum of 24 months from the last interaction, where processing is lawfully conducted, and subsequently deleted or anonymized.

• Consent Records: Information required to demonstrate the acquisition, management, and revocation of consent is retained for the period necessary to defend rights and demonstrate compliance.

• Analytics Data: User- and event-level data are retained according to Google Analytics 4 settings, with a standard period of 14 months, where available and configured.

• Technical and Security Logs: Retained ordinarily for up to 12 months, unless specific documented needs justify a different period.

Upon expiration of the applicable retention period, data are deleted or anonymized, unless further legal obligations apply.

10. Newsletter and Consent Management

Tradigo uses Wix Email Marketing to send newsletters and promotional communications.

Subscription occurs via dedicated forms on the website through a voluntary user action accompanied by privacy notice information.

Every promotional communication contains an unsubscribe link. Consent can also be revoked by writing to info@tradigo.it. Revocation does not affect the lawfulness of processing carried out prior to withdrawal.

11. Data Subject Rights

In cases provided for by the GDPR, data subjects may exercise the following rights:

• Access to their personal data.

• Rectification of inaccurate data.

• Erasure (right to be forgotten) of data.

• Restriction of processing.

• Data Portability.

• Objection to processing.

• Withdrawal of consent previously granted.

To exercise these rights, you can write to info@tradigo.it.

Data subjects also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) at https://www.garanteprivacy.it.

12. Cookies and Tracking Tools

The website uses technical cookies necessary for its operation and, subject to consent where required, analytics cookies and tools.

For information on cookie categories, purposes, and preference management, please consult the Cookie Policy available on the website.

13. Minors

The website is intended to present the company, its products, and services, and is not specifically directed at minors. Tradigo does not intentionally collect personal data from minors through the site.

14. Automated Decision-Making

Within the scope of the features described in this policy, Tradigo does not engage in decision-making based solely on automated processing that produces legal effects concerning the data subject or similarly significantly affects them, pursuant to Article 22 of the GDPR.

15. Policy Updates

Tradigo may update this privacy policy to reflect regulatory, organizational, or technological changes, or following the introduction of new website features.

The updated version will be published on this page, indicating the date of the latest revision.