Privacy Policy – EDC Management Consulting

Information on the processing of personal data under Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018.

Last updated: 2 August 2026.

The short version

This is a brochure site. It sells nothing, has no login area, profiles nobody and uses no cookies. The only place where we ask you for data is the form on the Contact page, and we use it solely to reply to you.

What	Why	How long
Name, e-mail, subject and text you type into the contact form	To read your enquiry and answer it	Up to 24 months, or for as long as a working relationship lasts
IP address and technical details of the request	To deliver pages to you, defend the site against abuse and filter spam on the form	The technical retention of our infrastructure provider
Aggregate visit counts	To know how many people read the site	Already aggregated: they cannot be traced back to you

Who processes your data

The data controller is EDC di Tiziana Timelli, Via Febo 2, 10133 Torino, Italy – VAT number 12376770017, trading online under the name EDC Management Consulting.

For anything concerning your data, write to [email protected].

No Data Protection Officer has been appointed: none of the circumstances that make one mandatory under Article 37 GDPR applies here.

What we process, and on what legal basis

1. Browsing data

As with any website, in order to deliver a page our infrastructure provider receives from your browser your IP address, the browser and operating system type, the date and time of the request and the address of the page you asked for. These are the data technically required to get the page to you and to recognise attacks and abuse.

Legal basis: the controller's legitimate interest in operating the site and keeping it secure (Article 6(1)(f) GDPR). We derive no profiles from it and we do not combine it with anything else.

2. The contact form

If you fill in the form on the Contact page you send us your name, your e-mail address, a subject and the body of your message. The only genuinely required fields are the e-mail address and the message: without them we could not reply. Everything else is optional.

Please do not put special category data into your message — what Article 9 GDPR calls health, political or religious opinions, trade union membership, sexual orientation, genetic or biometric data. We do not need it and we do not want to process it.

Legal basis: steps taken at your request prior to entering into a contract (Article 6(1)(b) GDPR). You wrote to us: replying is the natural next step, which is why we do not ask you for a consent that would serve no purpose.

Your message is delivered by e-mail to the company mailbox and lives there. There is no database behind this site, and nothing you write is stored anywhere else.

3. The anti-spam check on the form

Before accepting a submission, the form runs an automated check that tells people apart from automated programs. The check relies on technical signals from your browser and on your IP address, which is transmitted to Cloudflare for verification only and is not used to identify you or to build a profile.

Legal basis: our legitimate interest in not turning the form into a spam channel (Article 6(1)(f) GDPR). Without this check the address [email protected] would be reachable by any automated program.

4. Visit statistics

We use Cloudflare Web Analytics to know how many pages are read and which ones. It is a tool that uses no cookies, writes nothing into your browser and does not follow you from site to site: it produces only aggregate counts, from which no individual can be identified.

Legal basis: our legitimate interest in understanding whether the site is being read (Article 6(1)(f) GDPR).

Cookies and tracking technologies

This site sets no cookies — neither its own nor third-party ones — and uses no local storage, session storage or other means of storing information on your device. We verified this by loading the pages with the browser developer tools: the cookie list stays empty, including on the Contact page where the anti-spam check runs.

That is why you see no banner: there is nothing here for which the law requires us to collect consent under Article 122 of the Italian Privacy Code. Should we ever introduce tools that write to your device, a banner will appear and this notice will say so first.

The typefaces used by this site are hosted on our own servers: loading a page does not make your browser contact Google, or any other external font provider.

Who receives your data

We do not sell, trade or otherwise share personal data with anyone. It is processed by the providers of the technical services needed to run the site, each acting as a processor appointed under Article 28 GDPR:

Provider	What it does for us	Where it processes data
Cloudflare, Inc.	Hosts the site, distributes it, protects it from attacks, runs the anti-spam check on the form and produces the aggregate statistics	United States, with network nodes worldwide
Plus Five Five, Inc. (Resend)	Delivers the e-mail generated by the contact form to the company mailbox	United States
The company e-mail provider	Hosts the [email protected] mailbox where we read the messages	European Union

Data may additionally be disclosed to public authorities where a legal provision requires it, and to our professional advisers where necessary to establish or defend a legal claim.

Transfers outside the European Union

Cloudflare and Resend are United States companies, so part of the processing described above takes place outside the European Economic Area. The transfer rests on two safeguards provided for in Chapter V GDPR: both companies' participation in the EU-U.S. Data Privacy Framework, for which the European Commission adopted an adequacy decision on 10 July 2023, and the Standard Contractual Clauses approved by the Commission, incorporated in their respective data processing agreements.

You may request a copy of the safeguards in place by writing to [email protected].

How long we keep data

Messages received through the contact form stay in the mailbox for as long as it takes to handle your enquiry. If no relationship follows, we delete them within 24 months. If a professional relationship does follow, we keep them for its whole duration and for ten years afterwards, the period Article 2220 of the Italian Civil Code imposes for business records.
Browsing data is not retained by us: it stays in our infrastructure provider's systems for the technical periods stated in its own documentation, and we have no access to it in individual form.
Anti-spam signals are used for the check alone and give rise to no retention on our behalf.
Visit statistics are aggregated from the outset: there is no individual record to keep or to erase.

Your rights

Articles 15 to 22 GDPR give you the right to:

find out whether we process data concerning you and obtain a copy of it (access);
have it corrected if it is wrong or incomplete (rectification);
have it erased once it is no longer needed for the purpose we collected it for (erasure);
ask us to suspend its use while a challenge of yours is pending (restriction);
object to the processing we carry out on the basis of legitimate interest, explaining your particular situation (objection);
receive it in a machine-readable format in order to take it elsewhere (portability).

An e-mail to [email protected] is all it takes. We reply within one month; if the request is complex that period may be extended by two further months, in which case we will tell you within the first. There is nothing to pay.

We take no automated decisions and carry out no profiling within the meaning of Article 22 GDPR.

If you think something is wrong

You can come to us, and you are better off doing that first because it is the quickest route. But you also have the right to lodge a complaint with the supervisory authority, which in Italy is the Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome – www.garanteprivacy.it. If you live in another EU country you may address that country's authority.

Changes

If we change the way we process data we will update this page and the date at the top. Where the change is substantial we will flag it prominently on the site. It is worth having a look now and then.

This English text is provided for convenience. In case of discrepancy, the Italian version prevails.