Privacy Policy
Last updated: 16 May 2026 — version 2.0
This Privacy Policy describes how personal data of users visiting the website www.smartricicla.it (hereinafter, the "Website") is collected, used and protected, in accordance with Regulation (EU) 2016/679 ("GDPR") and applicable Italian legislation.
⚠️ Note: This policy applies exclusively to the Website. For information about data processing through the SmartRicicla mobile application, please refer to the dedicated App Privacy Policy, available within the app itself.
1. Data Controller
The Data Controller is:
INFO CONSULTING
VAT No. IT01811500766
Registered office: Piazza XXIII Novembre 10/2, 85020 Atella (PZ), Italy
Email: info@smartricicla.it
A Data Protection Officer (DPO) has not been appointed, as the conditions of mandatory appointment under Article 37 GDPR do not apply.
2. Categories of Data Collected by the Website
Through the Website, the following categories of data are processed:
2.1 Browsing data (technical logs)
The IT systems and software procedures used to operate the Website collect, during their normal operation, certain personal data whose transmission is inherent in the use of Internet communication protocols, such as: IP addresses, browser type, operating system, date and time of visit, pages visited. Such data is stored in the hosting server logs solely for IT security purposes, diagnostics, and to comply with any legal obligations.
2.2 Statistical analysis data (Google Analytics 4)
The Website uses exclusively Google Analytics 4 to collect aggregated statistical information about the use of the Website (pages visited, duration of the visit, traffic source, device type, approximate geographical area). Such data is processed only after the user's consent has been given through the cookie banner. The IP address is anonymized according to GA4 default settings.
2.3 Contact data voluntarily provided
When a user sends an email to info@smartricicla.it, the personal data contained in the message (sender's email address, name if provided, content of the communication) is processed solely for the purpose of responding to the request.
3. Purposes and Legal Bases for Processing
| Purpose | Data | Legal basis |
|---|---|---|
| Technical operation of the Website and IT security | Server logs | Legitimate interest (Art. 6.1.f GDPR) |
| Statistical analysis of traffic | GA4 data | User consent (Art. 6.1.a GDPR) |
| Response to contact requests | Received emails | Pre-contractual measures / legitimate interest (Art. 6.1.b/f GDPR) |
4. Retention Periods
- Hosting server logs: 12 months
- Google Analytics 4 data: 14 months (GA4 default setting)
- Contact emails: up to 24 months from the last communication, unless longer retention is required by law or to exercise rights
5. Data Recipients and Non-EU Transfers
Data may be processed by the following parties, acting as Data Processors under Article 28 GDPR:
Aruba S.p.A.
- Headquarters: Via San Clemente 53, 24036 Ponte San Pietro (BG), Italy
- Purpose: hosting of the Website and email service management
- Server location: Italy / European Union
- Privacy Policy: www.aruba.it/informativa-privacy.aspx
Google Ireland Limited
- Headquarters: Gordon House, Barrow Street, Dublin 4, Ireland
- Purpose: Google Analytics 4 service
- Non-EU transfers: the service may involve the transfer of data to Google LLC (USA). Such transfers are regulated by the Standard Contractual Clauses approved by the EU Commission and by Google's adherence to the EU-US Data Privacy Framework (EU Commission adequacy decision of 10 July 2023).
- Privacy Policy: policies.google.com/privacy
6. Cookies
The Website uses technical cookies and, with the user's consent, statistical analysis cookies provided by Google Analytics 4. For detailed information on the cookies used and how to manage preferences, please refer to the Cookie Policy.
7. User Rights
Pursuant to Articles 15-22 of the GDPR, the user has the right to:
- Access their personal data (Art. 15)
- Rectify inaccurate or incomplete data (Art. 16)
- Delete their data — right to erasure (Art. 17)
- Restrict processing (Art. 18)
- Receive their data in a structured format — data portability (Art. 20)
- Object to processing (Art. 21)
- Withdraw consent at any time, without prejudice to the lawfulness of processing based on the consent given prior to the withdrawal
To exercise these rights, please write to: info@smartricicla.it
The Data Controller will respond within 30 days of receiving the request, pursuant to Article 12 GDPR.
8. Right to Lodge a Complaint
If the user believes that the processing of their data violates the GDPR, they have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali):
- Website: www.garanteprivacy.it
- Email: protocollo@gpdp.it
- Address: Piazza Venezia 11, 00187 Rome, Italy
EU users also have the right to lodge a complaint with the supervisory authority of their country of residence.
9. Minors
The Website is not specifically aimed at children under the age of 14 and personal data of minors is not knowingly collected. If a parent or guardian becomes aware that a minor has provided personal data through the Website, they are invited to contact the Data Controller for removal.
10. Changes to this Policy
The Data Controller reserves the right to modify this policy at any time, providing notice through publication on the Website with indication of the last update date. Users are invited to consult this page regularly.