Notice on the processing of personal data under Article 13 of Regulation (EU) 2016/679 (“GDPR”)

Last updated: 30 October 2026

1. Data controller

The data controller is 4TownLab S.r.l., with registered office at Corso Vittorio Emanuele II 9, 31015 Conegliano (TV), Italy, who can be contacted by email at info@4townlab.it. The data controller has appointed a Data Protection Officer, who can be contacted at dpo@4townlab.it.

2. Categories of data processed

2.1 Browsing data

The computer systems and software procedures that run the site acquire, in the course of their normal operation, some data whose transmission is implicit in the use of Internet communication protocols. This information may include, for example, the IP address, the browser used, the operating system, the date and time of the request and the resources requested by the user. This data is processed only to keep the site working correctly, keep it secure, prevent unlawful use and allow the technical management of the infrastructure. To protect the contact forms from automated access and fraudulent activity, the site uses the Google reCAPTCHA service, which may process information about the user’s device and browsing in order to verify that the visitor is human. For more information, see Google’s privacy policy (https://policies.google.com/privacy (opens in a new tab)) and terms of service (https://policies.google.com/terms (opens in a new tab)). The site also uses Umami Analytics, a privacy-focused analytics tool that uses no profiling cookies and collects aggregated information on the use of the site, such as the number of visitors, pages viewed, approximate geographical origin, device type and browser used. This information is used only to analyse traffic and improve the services offered.

2.2 Data provided by the user

Through the contact form on the website, the data controller collects and processes the personal data the user provides voluntarily, such as first and last name, the organisation, company or body they belong to, email address, phone number (if provided), the content of the request and any other information included in the message.

3. Purposes and legal basis of processing

Personal data is processed to reply to requests for information or for a demo sent through the contact form, and to handle the follow-up contacts related to the user’s request. The legal basis for processing is Article 6(1)(b) GDPR, namely steps taken at the request of the data subject prior to entering into a contract. Providing the data marked as required is necessary to send the request and to allow the data controller to reply. If the required data is not provided, the request cannot be handled. Processing of the data collected to keep the site secure and protected is based on the data controller’s legitimate interest under Article 6(1)(f) GDPR, while the statistical data collected through Umami Analytics is processed in aggregated form and in ways that minimise the impact on the rights and freedoms of data subjects.

4. How the data is processed

Personal data is processed with electronic and paper-based tools, in line with the principles of lawfulness, fairness, transparency and minimisation, and with appropriate security measures to protect its confidentiality, integrity and availability.

5. Retention

Personal data will be kept for as long as needed to handle the request and the related follow-up contacts and, in any case, for no longer than 24 months from the last contact, unless it is needed to establish, exercise or defend a legal claim or to comply with legal obligations. Browsing data is kept only for as long as strictly necessary to keep the site working and secure and, in any case, in accordance with the hosting provider’s policies.

6. Recipients of the data

Personal data may be processed by people authorised by the data controller and by providers of IT, hosting, website maintenance and email services, appointed where necessary as processors under Article 28 GDPR. The data will not be disclosed to the public or passed on to third parties for commercial purposes. If, as part of the services used by the data controller, some data is transferred to countries outside the European Economic Area, the transfer will take place with the safeguards provided by Articles 44 et seq. GDPR.

7. Rights of the data subject

Data subjects may exercise at any time the rights provided by Articles 15–22 GDPR, including the right to:

  • obtain confirmation as to whether or not personal data concerning them is being processed;
  • access their personal data;
  • have it rectified or updated;
  • have it erased in the cases provided by law;
  • obtain restriction of processing;
  • object to processing in the cases provided by the GDPR;
  • receive the data in a structured, machine-readable format, where applicable.

To exercise these rights, write to dpo@4townlab.it.

8. Right to lodge a complaint

Data subjects who believe that their personal data is being processed in breach of the law have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or to bring proceedings before the competent courts.

9. Cookies

As of the date of this notice, the site does not use profiling cookies or tracking tools for marketing or behavioural analysis of users.