Privacy Policy for d10s.org
Last updated: 20 October 2025
This policy describes how the website www.d10s.org (the "Website") processes users’ personal data pursuant to Regulation (EU) 2016/679 ("GDPR") and applicable Italian law.
1) Data Controller
Trame Future s.r.l.s. Email: webmaster-d10s@tramefuture.com Registered office: Via Municipio 11, 81058 Pignataro Maggiore (CE), Italy VAT ID: 04886130618
The Controller determines the purposes and means of the processing of personal data carried out via the Website.
2) Categories of data processed
Usage data: IP address (also partially anonymised), device identifiers, browser type/version, pages visited, request timestamps, referrers, browsing information (session statistics, number of users), technical logs.
Tracking tools (cookies and similar technologies): used for technical purposes and – only with consent – for statistics/analytics and for displaying external content (e.g. Google Fonts).
Data provided voluntarily by the user (if contact forms or emails are used): name, email and any information included in the message.
Server-side tools: when you enter a URL, our servers perform HTTP requests to retrieve its metadata; the URL may appear in technical logs (retained for up to 12 months).
How the tools work
Depending on the functionality, the tools operate in two main ways:
- Local processing (files/text): files stay in the browser; we do not upload or store them.
- Network tools (URLs): we make HTTP requests to the indicated sites to retrieve headers/meta; technical logs of the URL are kept for security for up to 12 months.
Unless otherwise indicated, the data requested is necessary for the operation of the Website. Failure to provide it may make it impossible to deliver the service. Non-essential categories are activated only after consent.
3) Purposes and legal bases
| Purpose | Description | Legal basis |
|---|---|---|
| Technical operation of the Website | Page delivery, security, abuse prevention, system logs and maintenance (including logs generated by the hosting provider Aruba S.p.A.) | Legitimate interest of the Controller (Art. 6.1.f GDPR) |
| Statistics/Analytics (Google Analytics 4) | Aggregate measurement of traffic and Website performance | Consent (Art. 6.1.a GDPR) via Google Consent Mode v2 |
| Display of external content (Google Fonts) | Loading fonts hosted by Google to improve typography | Consent (Art. 6.1.a GDPR), where required |
| Handling contact requests (if forms/emails are provided) | Responding to questions and requests | Performance of pre-contractual steps/contract (Art. 6.1.b GDPR) |
You can modify or withdraw consents at any time via the “Manage cookie preferences” link in the Website footer (see §6).
4) Services/providers used
a) Hosting and infrastructure – Aruba S.p.A.
- Provider: Aruba S.p.A. (Arezzo, Italy)
- Role: Data processor for hosting services.
- Data processed: web server access logs (IP, date/time, requested URL, user agent, response code) and application logs needed to deliver the service.
- Location of processing: Italy.
- Legal basis: legitimate interest of the Controller (security and service continuity).
b) Statistics – Google Analytics 4 (GA4)
- Provider: Google LLC / Google Ireland Limited
- Data processed: usage data, online identifiers (via cookies or similar technologies), session statistics, number of users
- Location of processing: EU/EEA and, in some cases, USA
- Consent: collected and managed through Google Consent Mode v2; without consent, GA4 works in limited/aggregated mode according to the configured settings
c) Display of external content – Google Fonts
- Provider: Google LLC / Google Ireland Limited
- Purpose: Website typography rendering
- Data processed: usage data and technical information needed to load the fonts
- Location of processing: EU/EEA and, in some cases, USA
An up-to-date list of processors/third-party providers is available upon request by emailing webmaster-d10s@tramefuture.com.
5) Transfers outside the EU
If data is processed by providers located outside the European Economic Area (e.g. Google LLC, USA), the transfer takes place in accordance with Chapter V GDPR (EU-US adequacy decision, Standard Contractual Clauses and supplementary measures). Further details are available upon request.
6) Cookies, trackers and Google Consent Mode (v2)
On the first visit a banner allows Users to accept or refuse non-essential categories (e.g. analytics, external content). Choices are enforced via Google Consent Mode v2, which sets consent states (e.g. analytics_storage, ad_user_data, ad_personalization).
You can change your preferences at any time via the “Manage cookie preferences” link in the footer.
For technical details (list of cookies, duration, third parties), see the Cookie Policy.
7) Retention periods
- Technical and security logs (web/app access): up to 12 months, unless longer retention is required (e.g. abuse investigations or authority requests). Legal basis: security/legitimate interest (Art. 6.1.f GDPR).
- Analytics data (GA4): according to GA4 configuration (e.g. 14 months), possibly shortened.
- Communications/contact requests: for the time needed to respond and up to 24 months to prove handling or for legal compliance.
Once the relevant period has expired, the data is deleted or anonymised unless legal obligations require otherwise.
8) Processing methods and security
Processing is carried out using electronic tools and technical/organisational measures appropriate to ensure data integrity, confidentiality and availability. Access is limited to authorised personnel and processors appointed by contract (e.g. hosting, analytics).
9) Data subjects’ rights (GDPR)
You have the right to:
- Access your data and obtain a copy;
- Request rectification/update;
- Obtain erasure or restriction;
- Object to processing based on legitimate interest;
- Withdraw consent at any time;
- Request portability of the data you provided;
- Lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).
To exercise your rights, contact webmaster-d10s@tramefuture.com. Requests are free of charge and handled within 30 days unless they are particularly complex.
10) Information for users in Switzerland
For users in Switzerland, the Federal Act on Data Protection (FADP) applies. Rights are similar to those under the GDPR (access, rectification, erasure, objection, portability within statutory limits). Requests can be sent to webmaster-d10s@tramefuture.com.
11) Users outside the EU/EEA
Depending on the applicable local laws, you may have additional privacy rights. Upon request, the Controller will provide information about the relevant legal framework and how to exercise your rights.
Note: if the Website is not specifically targeted at the US market, this general clause is normally sufficient.
12) Defence in legal proceedings and system logs
Personal data may be used by the Controller in court or in the stages leading to possible legal action arising from improper use of the Website. For technical and security reasons, the Website and third-party services may collect system logs that could include the IP address.
13) Changes to this policy
The Controller may modify this policy at any time. Updates will be posted on this page indicating the revision date. If changes concern processing based on consent, new consent will be requested where necessary.
14) Contact
Trame Future s.r.l.s.
Email: webmaster-d10s@tramefuture.com
Website: https://www.d10s.org