Privacy policy

1. Who processes your data

The data controller is Motta Del Ministro S.r.l.s., represented by its Sole Director, Stefania Motta.

Registered office

Via Madre Teresa di Calcutta 3, 20063 Cernusco sul Naviglio (MI), Italy

Operating office

Via Sant'Andrea 7, 20121 Milan, Italy

VAT and Tax ID

14522770966

Companies Register

REA MI-2790220

Email

info@mottadelministro.com

Certified email

mottadelministro@pec.it

No Data Protection Officer has been appointed, as the conditions of Article 37 of the Regulation do not apply. For any matter concerning your data, write to the addresses above.

2. What data we collect

Three categories, with different origins and different handling.

Navigation data

The systems running this site record data whose transmission is inherent in the use of internet protocols: IP address, browser and operating system, date and time of the request, page requested, response status. This data is not collected in order to be linked to identified individuals, but could allow identification through processing and association with third-party data.

Data you give us

By two routes. The first is you writing to the address given on the Contact page or telephoning the Firm: we process whatever you choose to tell us — as a rule your name, contact details, the company you represent and the content of your message. The second is the form on the Italian «check-up finanziario aziendale»: at the end of the questionnaire we ask for your name, company, email and telephone so that we can send you the result. Alongside those details we keep the answers you gave — turnover, margin, size of the transaction and the rest — because they are what makes the result readable and any later conversation useful. There is no other form anywhere on the site.

Usage and advertising data

Only if you consent, two tools are activated: the Meta pixel, which reports your visit to Meta so that we can measure the results of our campaigns, and Microsoft Clarity, which records anonymously how the pages are used — scrolling, clicks, the point at which you leave. We pass neither of them your name nor any contact detail. Without consent they are not even loaded. Details are in the Cookie policy.

3. Why we process it, and on what basis

If the relationship leads to a mandate, your data becomes part of the professional file and follows the retention periods set by law, which prevail over the 24 months stated for simple enquiries.

4. Do you have to provide it

No. If you write to us, you decide what to say and how much: the only limit is a natural one rather than an imposed one — without contact details we cannot reply.

The check-up form asks for name, company, email and telephone because its purpose is to send you the result: without them there is nowhere to send it. Nothing obliges you to fill it in, and we ask for nothing beforehand — the sixteen questions are read and answered freely, and if you choose not to leave your details you have still seen the whole page.

The commercial-communications box is a different matter again: it is optional, it is not pre-ticked, and leaving it empty changes nothing — you receive the result either way. The same goes for consent to the advertising pixel: refusing it limits your use of the site in no way, and you may withdraw it at any time from the foot of any page.

5. Who else sees your data

Your data is handled by the people at the firm authorised to process it. Beyond them, it may be processed by:

• the provider hosting the site, with servers located in Italy, appointed as processor under Article 28 of the Regulation;
• Google Ireland Limited, which provides the Firm's email service and the spreadsheet the check-up form feeds into: the messages you send us and the rows from the form are received and stored on that infrastructure. It acts as a processor under Article 28, on the terms of the relevant data processing agreement;
• Brevo SA, a French company with servers in the European Union, which provides the platform we use to manage contacts and send email: the data from the check-up form is recorded there. It acts as a processor under Article 28;
• Meta Platforms Ireland Limited, for the measurement of advertising campaigns alone and only if you have consented; for that processing Meta acts as an independent controller, under its own notice;
• Microsoft Ireland Operations Limited, which provides the Microsoft Clarity analytics tool, and only if you have consented; it acts as a processor under Article 28;
• advisors, professionals and service providers engaged by the firm, bound by confidentiality;
• public authorities, where disclosure is required by law or by an order of a competent authority.

Your data is never sold, transferred or disclosed to third parties for their own commercial purposes.

6. Whether data leaves the European Union

Site hosting runs on servers located in Italy: simply reading the pages involves no transfer outside the European Economic Area.

The Firm's email, by contrast, is provided by Google Ireland Limited. The messages you send us are kept in our mailbox on that infrastructure, and the service may involve a transfer of data to the United States. The transfer relies on the European Commission's adequacy decision of 10 July 2023 concerning the EU-US Data Privacy Framework and, additionally, on the standard contractual clauses incorporated in the provider's data processing terms.

Data from the check-up form travels the same road as the email: it reaches a spreadsheet hosted by Google Ireland Limited, with any transfer to the United States resting on the same adequacy decision. The contact platform, Brevo SA, is French and keeps the data on servers inside the European Union: for that part no transfer takes place.

If you decline the advertising consent and do not fill in the form, no other transfer takes place: the site talks to no external server, not even for the typefaces, which are hosted alongside the rest of the pages.

If you grant it, the Meta pixel and Microsoft Clarity both involve a transfer of data to the United States. The transfers rely on the European Commission's adequacy decision of 10 July 2023 concerning the EU-US Data Privacy Framework. You can prevent them, or bring them to an end, simply by refusing or withdrawing consent.

7. Your rights

At any time, and without formality, you may exercise the rights set out in Articles 15 to 22 of the Regulation:

Access

learn whether we process data concerning you and obtain a copy.

Rectification

have inaccurate data corrected or incomplete data completed.

Erasure

obtain deletion of your data, in the cases set out in Art. 17.

Restriction

ask that data be stored but not otherwise processed.

Portability

receive your data in a structured, machine-readable format.

Objection

object to processing based on legitimate interest.

Withdrawal of consent

withdraw consent at any time, without affecting the lawfulness of processing carried out beforehand.

To exercise them write to info@mottadelministro.com or mottadelministro@pec.it. We reply within one month, extendable by two months where a request is particularly complex, in which case we will tell you.

If you believe the processing infringes the Regulation you have the right to lodge a complaint with the Italian Data Protection Authority — Piazza Venezia 11, 00187 Rome, garante@gpdp.it — or to bring the matter before a court.

8. How we protect it

The site is served exclusively over an encrypted connection. Access to data is restricted to authorised people and protected by individual credentials. We apply technical and organisational measures appropriate to the risk, but no measure can guarantee the absolute security of an internet transmission — which is why we ask you to leave confidential information out of a first email.

9. Automated decisions and profiling

The financial check-up computes its result automatically, from the answers you enter and from thresholds stated on the page itself. It is not, however, a decision about you: it grants nothing and denies nothing, it determines access to no service, and it produces neither legal effects nor similarly significant effects within the meaning of Article 22 of the Regulation. It is an orientation, and the page says so plainly.

The enquiries we receive, and the results of the check-up, are read and assessed by people. We carry out no advertising profiling on the questionnaire answers: those answers are passed neither to Meta nor to Microsoft, and stay between your device and our records.

10. Minors

This site addresses professionals, businesses and investors. We do not knowingly collect data from anyone under sixteen. If you believe a minor's data has been sent to us, tell us and we will delete it.

11. Changes to this notice

This notice may be updated to reflect changes in law or in how the site works. The version in force is always the one published at this address, with the update date shown at the top. Substantial changes will be brought to your attention appropriately.