Last updated: 22 July 2026
1. Data Controller
The Data Controller (the party that determines the purposes and means of processing personal data) is Di-Vinum di Silvia Rama, registered office at via Mantovana 21, Pastrengo (VR), Italy. Any request concerning the processing of personal data may be sent to info@di-vinum.it.
2. Categories of data collected
The website collects browsing data, i.e. information that IT systems acquire automatically during use of the website (for example IP address, browser type, operating system, pages visited, date and time of access).
The website also collects data that users provide voluntarily through the contact form, such as name, email address and message content.
If a user subscribes to the newsletter, their email address is collected in order to send the requested communications.
If a user submits a job application, the data contained in the CV and in any correspondence voluntarily sent by the user may be processed.
The website uses cookies and similar technologies. For detailed information on categories, purposes, duration and how to manage preferences, please see the Cookie Policy.
3. Purposes and legal basis of processing
Data is processed for the following purposes, each with its corresponding legal basis:
- to respond to requests submitted through the contact form, on the basis of pre-contractual measures requested by the user or, where not directly pre-contractual, of the Controller’s legitimate interest in managing communications received;
- to ensure the technical operation and security of the website, and to prevent spam, abuse and attack attempts, on the basis of the Controller’s legitimate interest in protecting the website and its IT systems;
- to comply with legal obligations, on the basis of the legal obligation applicable to the Controller;
- to establish, exercise or defend a legal claim, where necessary, on the basis of the Controller’s legitimate interest in protecting its own rights;
- to carry out aggregated, anonymous statistical analysis of website traffic through analytics tools that do not use cookies or persistent identifiers (e.g. Umami), on the basis of the Controller’s legitimate interest in understanding website performance without individually tracking users;
- to send newsletters and marketing communications, on the basis of the user’s consent;
- to evaluate unsolicited applications or respond to applications submitted by the user, on the basis of pre-contractual measures requested by the data subject.
Where processing is based on consent, the user may withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal.
4. Data recipients and third-party providers
Personal data may be disclosed to the following third-party providers, involved in the technical management, security and promotion of the website:
Hosting (Aruba) — The website is hosted on the servers of Aruba S.p.A., which processes the data necessary to provide the hosting service. Place of processing: Italy/European Union.
Wordfence — The website uses Wordfence to protect against suspicious access, spam, malware and attack attempts. The service may process IP addresses and other technical data necessary for security functions. Place of processing: United States and/or other countries indicated by the provider.
Contact form — Data entered in the contact form is sent to the Controller and/or stored on the website’s hosting server, depending on the technical configuration adopted.
Umami — The website uses Umami, a statistical analysis tool that does not use cookies or persistent identifiers: it does not track individual users across different sessions and collects data in aggregated, anonymous form for statistical purposes. Place of processing: European Union.
Mailchimp — The website includes a newsletter sign-up form; data collected is transferred to Mailchimp (Intuit Inc.) for sending communications and managing the mailing list. Place of processing: United States, unless an EU data-location option is available under the subscribed plan. For more information: https://mailchimp.com/gdpr/
Embedded YouTube videos — The website may include videos embedded from YouTube. Playing the videos or interacting with the player may involve the processing of data by Google. Place of processing: European Union and/or other countries where Google operates.
5. Transfer of data outside the European Economic Area
Some providers referred to in this Privacy Policy may process personal data in countries located outside the European Economic Area, including the United States.
Where this occurs, the transfer is carried out on the basis of an adequacy decision issued by the European Commission, including the provider’s possible adherence to the EU-US Data Privacy Framework, or on the basis of appropriate safeguards, such as the Standard Contractual Clauses approved by the European Commission, where applicable.
6. Data retention period
Personal data is retained for the time necessary to achieve the purposes for which it was collected, according to the following criteria:
- data submitted through the contact form is retained for the time necessary to manage and respond to the request, and in any case for no longer than 12 months from the closure of the request, unless retention is required to protect the Controller’s rights;
- technical and security data is retained for the time necessary to ensure the operation, security and abuse-prevention of the systems, in line with the technical timeframes of the systems and providers used;
- data processed through cookies and tracking tools is retained for the periods indicated in the Cookie Policy;
- data used for the newsletter is retained until consent is withdrawn or the subscription is cancelled;
- data contained in job applications is retained for 12 months, unless an employment relationship is established or a different legal requirement applies;
- data necessary to comply with legal obligations or to protect the Controller’s rights may be retained for the periods provided for by applicable law or until the related rights become time-barred.
7. Rights of the data subject
Users may at any time exercise the following rights by writing to info@di-vinum.it: right of access to their own data, rectification of inaccurate data, erasure, restriction of processing, data portability where applicable, objection to processing, and withdrawal of consent without affecting the lawfulness of processing already carried out.
Users also have the right to lodge a complaint with the Data Protection Authority (Garante per la Protezione dei Dati Personali).
8. Provision of data
Providing data through the contact form and the newsletter sign-up is optional. However, failure to provide the necessary data will prevent the Controller from responding to the request, providing the requested service, or sending the communications for which the user has given consent.
9. Changes to this Privacy Policy
The Controller reserves the right to amend this Privacy Policy. The updated version will always be published on this page, with an indication of the date of the last update.