Draft privacy notice

LEGAL REVIEW REQUIRED BEFORE PUBLICATION

This draft describes the intended technical operation of the new website and is not a legally approved privacy notice.

1. Data controller

The company confirmed for this website is Manini Realty s.r.l.s., Via A. Gramsci, 3, 53049 Torrita di Siena (SI), Italy, VAT number 01538780528.

2. Data collection

The website provides two separate flows:

• consultation request: first name, last name, email, phone, budget range, interests, requested service and an optional message;
• guide request: first name, email and any phone number provided voluntarily.

Acknowledging the privacy notice is required to submit a request. Marketing consent is separate, optional and disabled by default.

3. Intended technical flow

After validation, the code records the request in the private website outbox and provides a server-side delivery and retry process to CRM MANINI. The website confirmation means local acceptance. The configuration and actual delivery in production must be verified before publishing the notice.

4. Technical outbox retention

The local technical policy deletes confirmed deliveries after 30 days and permanent failures or timestamped quarantine records after 90 days. Pending, delivering and retry records are never removed automatically. These periods apply only to the website outbox and do not establish CRM retention, which must be decided before deployment.

5. Purposes, legal bases and CRM retention

Final purposes, legal bases, CRM retention, recipients and supplier roles must be reviewed and approved as part of the legal review. This draft does not presume them.

6. International transfers

The existence, conditions and safeguards of any international transfer must be checked before deployment. This draft does not state that such transfers do or do not take place.

7. Analytics, marketing and cookies

The prepared code includes consent-dependent Google Analytics 4 as described below. This description of the code does not confirm the configuration active in production. Purposes, tools and consent management must be checked when reviewing the notice.

8. Rights and contact details

The procedure for exercising data-subject rights, operational contact details and the complete wording must be confirmed during legal review before publication.