Privacy policy
Last updated:
This notice explains how we process the personal data of people who visit upholding.it and who write to us through the contact form, under Articles 13 and 14 of Regulation (EU) 2016/679.
01Who processes your data
The data controller is UP Holding Srl, Via Luigi Einaudi 4, 30174 Venezia (VE), Italia, P. IVA IT03754241200.
- info@upholding.it
- Privacy email
- privacy@upholding.it
- Data protection officer
- Non nominato
Each company in the group is an independent controller for its own processing: if you contacted UP Lavoro, UP Logistica, UP Facility, UP Family, UP Farm or UP Immobiliare directly, the notice published on their site applies.
02What we collect
- Data you give us through the contact form: first and last name, work email, phone, company name and the text of your message.
- Technical browsing data the server records in order to operate and stay secure: IP address, browser and device type, referring page, date and time of the request.
- Measurement data collected by statistics cookies, but only if you consented: pages viewed, time on page, traffic source.
We neither ask for nor want special categories of data (Art. 9 GDPR): please do not include any in the message field.
03Why we process it, and on what legal basis
- Answering your enquiry
- Legal basis: pre-contractual measures taken at your request (Art. 6.1.b) or legitimate interest in following up a business contact (Art. 6.1.f).
- Running the site and keeping it secure
- Legal basis: legitimate interest in delivering the service and preventing abuse (Art. 6.1.f).
- Measuring how the site is used
- Legal basis: your consent (Art. 6.1.a), which you can withdraw at any time from the cookie banner.
- Meeting legal obligations
- Legal basis: legal obligation (Art. 6.1.c), where we are required to retain or disclose data.
04How long we keep it
- Contact form enquiries: 24 months from the last exchange, unless a contractual relationship begins, in which case its own terms apply.
- Server technical logs: up to 12 months.
- Measurement data: as configured in the tool, and in any case no longer than 14 months.
- Proof of cookie consent: 6 months, after which we ask you again.
05Who we may share it with
Data is handled by authorised staff within the group and may be shared with suppliers acting as processors, appointed under Art. 28 GDPR:
- Hosting and site infrastructure providers.
- Email providers and tools that route incoming enquiries.
- Measurement tool providers, only where you have consented.
- Companies within the group, when your enquiry concerns their services: we tell you so in our reply.
We do not sell or transfer your data to third parties for their own purposes.
06Transfers outside the European Economic Area
Some suppliers may process data in third countries. Where that happens, the transfer relies on a European Commission adequacy decision or on standard contractual clauses, with any supplementary measures the case requires. You can ask us for a copy of the safeguards in place by writing to privacy@upholding.it.
07Your rights
You may exercise the rights under Articles 15 to 22 GDPR at any time:
- Access your data and obtain a copy of it.
- Ask for it to be rectified if inaccurate or incomplete.
- Ask for it to be erased, in the cases provided by law.
- Ask for processing to be restricted, or object to processing based on legitimate interest.
- Receive your data in a structured format and have it transferred to another controller.
- Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
To exercise them write to privacy@upholding.it: we reply within one month. If you believe the processing infringes the Regulation you may lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it) or with the authority of the country where you live.
08If you do not provide your data
Providing data is voluntary, but the fields marked as required in the form are what allow us to reply: without them we cannot follow up. Measurement data is entirely optional and the site works exactly the same without it.
09Automated decision-making
We do not take decisions based solely on automated processing that produce legal effects concerning you, and we do not carry out profiling from data collected on this site.
10Changes to this notice
We may update this document when the processing or the tools we use change. The version in force is always the one published here, with the last-updated date at the top of the page.