Privacy Policy

Privacy policy regarding the processing of personal data. In effect since April 14, 2026

INTRODUCTION

This privacy policy takes into account the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR) and the Privacy Code (Legislative Decree No. 196 of June 30, 2003). The document has also been drafted based on the Guidelines of the Privacy Guarantor (specifically the Guidelines on combating spam issued by the Privacy Guarantor on July 4, 2013).

Data Controller: EPStudios di Pietrobon Enrico, Via Filippo Beltrami, 9 - 28844 Villadossola (VB), VAT No. 02433550031, Phone: +39 351 893 0930, Email: info@interlyo.com

Website to which this privacy policy refers: https://interlyo.com/ (Website).

The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, you may send any request for information directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Website.

The main processing activities of your personal data are described below. In particular, the legal basis for processing is explained, whether the provision of data is mandatory, and the consequences of failing to provide personal data. To best describe your rights, where necessary, we have specified if and when a particular processing of personal data is not carried out. On the Website, you have the possibility to enter personal data of third parties. In this case, you guarantee that you have obtained consent from these subjects for the entry of such personal data. Therefore, you agree to indemnify and hold the Data Controller harmless from any liability.

Registration on the Website

The Website does not offer the possibility of registration. Therefore, the Data Controller does not process your personal data for this purpose.

Purchases on the Website

Your personal data will be processed to allow you to make purchases on the Website. In the event of an online purchase order, to allow the conclusion of the purchase contract and the correct execution of operations related to it (and, where necessary based on sector regulations, to fulfill tax obligations). This processing of personal data also includes the possibility of sending communications (e.g., tracking, order information, and requests for a review) through automated tools such as email and/or SMS and/or WhatsApp. The legal basis for processing is the obligation of the Data Controller to execute the contract with the data subject or to comply with legal obligations. Regardless of the above (and therefore of your consent), the Data Controller may process your data for so-called "soft-spam" purposes, governed by Art. 130 of the Privacy Code. This means that, limited to the email provided by you in the context of a purchase through the Website, the Data Controller will process the email to allow the direct offering of similar products/services, provided that you do not object to such processing in the manner provided for in this policy. The legal basis for processing is the legitimate interest of the Data Controller in sending this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving "soft-spam" communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication. The Controller does not offer products or services prohibited to minors under 18. Consequently, no specific age verification system is provided, as there is no content subject to legal restrictions.

Responding to your requests

Your data will be processed to respond to your requests for information. Providing this data is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for processing is the legitimate interest of the Data Controller to follow up on user requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Data Controller.

General marketing

With your prior consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters relating to its own or third-party products. The legal basis for this processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, as well as the impossibility for the Data Controller to conduct market research, including those aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to the email address you provided on the Website. We use Google services, such as Google Ads and Google Analytics, to personalize advertisements and improve the user experience. This includes the collection of personal data and cookies, used to show you ads in line with your preferences. At the time of consent, you will be asked to authorize the use of this data. Further details on the use of cookies and consent management are available in the cookie policy of this website.

Profiling

The Data Controller does not perform "profiling" with your personal data. Therefore, it will not send you advertising material and/or newsletters relating to its own or third-party products of your specific interest.

Transfer of data

The Data Controller does not transfer your personal data to third parties.

Geolocation

The Website does not implement tools for the geolocation of the user's IP address.

Curriculum Vitae

It is not possible to send a curriculum vitae through the Website. Therefore, your data will not be processed for these purposes.

Booking appointments

There are no third-party systems active on the Website for booking appointments with the Data Controller. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contact details indicated in the introduction.

Photographs and videos

With your prior consent, the Data Controller may process photographs and/or videos depicting you, which include your physical features, personal image, and voice, for the use, publication, and reproduction of the same through the current and future social channels and websites of the Data Controller (including but not limited to the Website, Facebook, Instagram, LinkedIn, Pinterest, YouTube, TikTok) and/or on other online and offline channels of third parties and through newsletters and/or promotional and informative communications in order to promote the activity of the Data Controller. The legal basis for processing is your consent. The provision of data for this purpose is purely optional. Failure to consent to the processing of data for the purpose of use, publication, and reproduction of photographs and/or videos depicting you will make it impossible for the Data Controller to share them on the Website and/or on the social channels of the Data Controller and/or on other online and offline channels of the Data Controller and/or third parties and to use them in newsletters and/or promotional and informative communications. By providing your consent, you also consent to the storage of photographs and/or videos depicting you in the computer archives of the Data Controller and acknowledge that your personal data will be used for informative and promotional purposes.

Web scraping

The use of any automated process or system to access, acquire, copy, or monitor any part of our website, including but not limited to web scraping, crawling, or spidering techniques, is expressly prohibited. The Data Controller reserves the right to take all necessary measures, including legal action, to prevent and prosecute any unauthorized scraping activity. By using the Website, the user or any third party agrees not to: (i) use automated systems, such as bots, scrapers, or spiders, to access or interact with the Website; (ii) collect content, data, or other information present on the Website without explicit written authorization; (iii) distribute, display, publish, or otherwise use content acquired through scraping techniques without consent. Any violation of this clause will be considered a material breach of the Website's terms of use and will result in appropriate measures being taken, including the possible suspension of access to the site and the initiation of legal action to protect the interests of the Data Controller.

Communication of personal data

As part of its ordinary activity, the Data Controller may communicate your personal data to certain categories of subjects. In Article 2 you can find the list of subjects to whom the Data Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data is not communicated to third parties.

The "communication" of personal data to third parties is different from "transfer" (governed by the preceding point). In fact, in communication, the third party to whom the data is transmitted can only use it for the specific purposes described in the relationship with the Data Controller. In a transfer, however, the third party becomes an independent Data Controller of the personal data. Furthermore, your consent is always required to transfer your personal data to third parties.

Notwithstanding the foregoing, it is understood that the Data Controller may still use your personal data to correctly fulfill the obligations provided for by current laws.

SPECIFIC PRIVACY POLICY

Art. 1 Methods of processing

1.1 The processing of your personal data will mainly be carried out with the aid of electronic or otherwise automated means, according to the methods and with the tools suitable to guarantee the security and confidentiality of the personal data.

1.2 The information acquired and the methods of processing will be relevant and not excessive with respect to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances. On the Website, you will have the possibility to create a public profile in which other users can view the material published by you and your personal data (e.g., photographs or videos). Therefore, you acknowledge and accept that the Data Controller is not responsible for the use that users may make of this material and your personal data.

1.3 "Special categories of data" are not processed through the Website. Special data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, health status, and sexual life.

1.4 Judicial data are not processed through the Website.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to specific categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:

  • The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions.
  • Your personal data may also be communicated to all those public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Labor Chambers and Offices, etc.), if the communication is necessary or functional for the correct fulfillment of obligations deriving from the law.
  • The Data Controller makes use of employees and/or collaborators in any capacity. For the correct functioning of the Website, the Data Controller may communicate your personal data to these employees and/or collaborators.
  • In its ordinary management of the Website, the Data Controller makes use of companies, consultants, or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
  • For sending its communications, the Data Controller makes use of external companies in charge of sending this type of communication (CRM platforms). Your personal data (in particular your email) may therefore be communicated to these companies.
  • The Data Controller does not use external companies to provide customer care services.
  • The Data Controller makes use of banking institutions and companies that manage national and international payment circuits for online payments of products and services purchased through the Website.
  • The purchaser's personal data may be communicated to post offices, couriers, or shippers in charge of delivering the Products purchased through the Website.
  • Purchasers' personal data are not communicated to providers of technology based on generative artificial intelligence.

The Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this policy to check to which subjects the Data Controller communicates your personal data.

Art. 3 Retention of personal data

3.1 This article describes how long the Data Controller reserves the right to retain your personal data.

  • Your personal data will be kept only for the time necessary to guarantee the correct provision of the services offered through the Website.
  • For the purpose of executing the sales contract, the data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defense and to demonstrate that it has correctly executed the contract.
  • For customer care purposes, the data will be deleted once the assistance service is completed and, in any case, within a maximum period of 3 months from the last exchange of emails with the data subject.
  • For marketing purposes, unless consent is revoked earlier, the data are kept for 24 months from the provision. Following the revocation of consent or at the end of the 24-month period, the personal data will be deleted and no longer used for marketing purposes.

3.2 Notwithstanding the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is based in a country that has an adequate level of security from a regulatory point of view. If the transfer of your personal data takes place to a non-EU country for which the European Commission has expressed an adequacy decision, the transfer is considered secure from a regulatory point of view in any case. This Article 4.1 indicates from time to time the countries to which your personal data may possibly be transferred and where the European Commission has expressed an adequacy decision.

  • Your personal data may be transferred to the USA based on the provisions of the European Commission's adequacy decision. With this decision, the European Commission has decided that the USA offers a protection of personal data comparable to that offered by the European Union.

4.2 Notwithstanding what is indicated in Article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not expressed an adequacy decision. You are therefore invited to regularly view this Article 4.2 to ascertain to which of these countries your data are eventually transferred.

4.3 In this article, the Data Controller indicates the countries to which it specifically directs its activity. This circumstance may imply the application of the regulations of the reference country, together with those governing the relationship with the user based on what is indicated in the Introduction.

  • At the user's request, the Data Controller will apply the potentially more favorable regulations provided for by the user's national legislation to the processing of personal data.

Art. 5. Rights of the data subject

The Data Controller informs you that you have the right to:

  • request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of processing concerning you or to object to their processing, in addition to the right to data portability
  • withdraw consent at any time without affecting the lawfulness of processing based on consent given before the withdrawal
  • lodge a complaint with a supervisory authority.

The above rights may be exercised by making a request without formality to the contacts indicated in the Introduction.

Art. 6. Modifications and Miscellaneous

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to the users of the Website and guaranteeing in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this policy. In the event of substantial changes to this privacy policy, the Data Controller may also communicate them via email.