Privacy Policy

Last updated: 9 September 2025

This Privacy Policy explains how we process personal data collected through this website, in accordance with Regulation (EU) 2016/679 (“GDPR”) and applicable ePrivacy rules.

1) Data Controller

SOC. COOP. SINERGIE A R.L.
(Project Coordinator – SkillSphere)
Email: info@sinergiecoop.it

2) Types of Data Processed

• Contact form data: name, email address, and message content (plus minimal technical metadata needed for delivery).

• Technical/navigation data: server logs, IP address, user-agent, and similar telemetry for security and diagnostics.

• Statistics data (Google Analytics 4): aggregated usage statistics collected only with your consent via the cookie banner.

3) Purposes and Legal Bases

• Responding to contact form requests
  Legal basis: performance of pre-contractual measures at your request (Art. 6(1)(b) GDPR) and/or legitimate interest in handling enquiries (Art. 6(1)(f) GDPR).

• Website security and fraud prevention (e.g., log analysis, incident response)
  Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

• Statistics and audience measurement (Google Analytics 4)
  Legal basis: consent (Art. 6(1)(a) GDPR) and applicable ePrivacy rules.

4) Cookies and Tracking

This website uses a consent management system provided by Complianz. Non-essential cookies (e.g., for analytics) are only set after your consent. You can review or change your preferences at any time by clicking “Manage cookie preferences” in the footer.

For a detailed list of cookies and vendors, see our Cookie Policy.

Google Analytics 4 (GA4) is used to collect aggregated data, only after consent. IP addresses are not visible in GA4 reports, and EU-oriented safeguards are enabled. Event data is retained for 14 months.

5) Data Provision

• Contact form: required to respond to your request; without it, we cannot process your message.

• Analytics: optional; the website remains fully usable without your consent.

6) Recipients and Data Processors

Personal data may be processed, under our instructions, by service providers acting as data processors (Art. 28 GDPR), including:

• web hosting and IT maintenance provider;

• email service provider for contact form messages;

• Google Ireland Limited (for Google Analytics 4).

These providers process data under agreements that ensure GDPR compliance.

7) International Data Transfers

In the context of Google services, data may be transferred outside the European Economic Area (EEA), including to the United States. Such transfers rely, where applicable, on the EU–U.S. Data Privacy Framework and/or the European Commission’s Standard Contractual Clauses (SCCs), with appropriate safeguards.

8) Data Retention

• Contact form requests: stored for 12 months after the request is closed (unless longer retention is needed to protect our rights).

• Technical/security logs: stored for 30 days, unless longer is required to investigate security incidents.

• GA4 analytics data: event data is retained for 14 months.

9) Your Rights

You have the right to request:

• access to your personal data,

• rectification, erasure, or restriction of processing,

• objection to processing,

• data portability,

• withdrawal of consent (where applicable).

Withdrawal of consent does not affect the lawfulness of processing before its withdrawal.

10) How to Exercise Your Rights

To exercise your rights or for any privacy-related question, please contact: info@sinergiecoop.it
We will respond without undue delay and within the timeframes established by the GDPR.

11) Complaints

If you believe that the processing of your personal data violates data protection laws, you can file a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or the relevant supervisory authority in your country of residence within the EU.

12) Security Measures

We implement appropriate technical and organisational measures to protect personal data (e.g., TLS/HTTPS, server hardening, access controls, monitoring), in line with Art. 32 GDPR.

13) Children

This website is intended for a general audience and is not directed at children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can delete it.

14) External Links

This website may contain links to third-party websites. We are not responsible for their content or their data processing practices, which are subject to their own privacy policies.

15) Changes to This Privacy Policy

We may update this Privacy Policy for legal or technical reasons. Where appropriate, significant changes will be communicated. Please check this page periodically to stay informed about the latest version.