Privacy Policy

1. Introduction

Welcome to InvestInPuglia, operated by 1402 Celsius Ltd ("we", "our", or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our investment advisory and consultancy services for property and business investments in Puglia, Italy.

2. Information We Collect

2.1 Personal Information

• Full name, email address, and phone number
• Nationality, residency status, and preferred language
• Investment preferences, financial capacity, and objectives
• Business information for corporate clients
• Communication preferences and consultation history
• Financial information relevant to investment planning

2.2 Investment Information

• Property preferences and investment criteria
• Business sector interests and investment timeline
• Budget ranges and financing requirements
• Risk tolerance and investment experience
• Documents related to investment projects

2.3 Technical Information

• IP addresses and browser information
• Device information and operating system
• Website usage patterns and page interactions
• Cookies and similar tracking technologies
• Analytics data about service usage

3. Legal Basis for Processing

We process your personal data under the following legal bases:

• Contract Performance: To provide our advisory and consultancy services
• Legitimate Interests: To improve our services and protect our business
• Legal Obligations: To comply with anti-money laundering and other regulations
• Consent: For marketing communications and certain data processing activities

4. How We Use Your Information

4.1 Service Delivery

• Provide investment advisory and consultancy services
• Analyze investment opportunities and prepare recommendations
• Manage investment projects and business development initiatives
• Facilitate communications with partners and service providers
• Process payments and maintain service records

4.2 Business Operations

• Improve and personalize our advisory services
• Conduct market research and investment analysis
• Ensure security and prevent fraud
• Maintain client relationships and provide support
• Send relevant investment opportunities and updates

4.3 Compliance and Legal

• Comply with anti-money laundering (AML) requirements
• Meet know-your-customer (KYC) obligations
• Respond to legal requests and regulatory inquiries
• Protect our legal rights and interests
• Maintain required business records

5. Information Sharing

5.1 Service Partners

We may share your information with trusted partners to facilitate investments, including:

• Legal professionals and notaries
• Property developers and real estate agents
• Financial institutions and lenders
• Due diligence and valuation experts
• Italian government agencies as required

5.2 Professional Advisors

We work with professional service providers including accountants, lawyers, and consultants who are bound by confidentiality obligations.

5.3 Legal Disclosure

We may disclose information when required by law, court order, or regulatory authority, or to protect our rights and the safety of our clients.

6. Data Security

We implement robust security measures to protect your personal and financial information:

• End-to-end encryption for sensitive data transmission
• Secure data storage with access controls
• Regular security audits and vulnerability assessments
• Employee training on data protection and confidentiality
• Incident response procedures for data breaches
• Physical security for document storage

7. Your Rights (GDPR)

Under the General Data Protection Regulation (GDPR), you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Restriction: Limit how we process your data
• Right to Portability: Receive your data in a structured format
• Right to Object: Object to certain types of processing
• Right to Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at privacy@investinpuglia.eu

8. Cookies and Tracking

We use cookies and similar technologies to enhance your experience:

• Essential Cookies: Required for website functionality
• Analytics Cookies: Help us understand website usage
• Performance Cookies: Improve website performance
• Marketing Cookies: Deliver relevant advertisements

You can manage cookie preferences through your browser settings. For detailed information, see our Cookie Policy.

9. Data Retention

We retain your personal information based on legal and business requirements:

• Client records: 10 years after last transaction (legal requirement)
• Investment documentation: 10 years for tax and regulatory purposes
• Marketing lists: Until you unsubscribe or 3 years of inactivity
• Website analytics: 26 months
• Communication records: 7 years

10. International Transfers

As we operate between the UK and Italy, your data may be transferred internationally. We ensure appropriate safeguards are in place:

• Standard Contractual Clauses for transfers outside the EEA
• Adequacy decisions where applicable
• Encryption for all data transfers
• Agreements with processors ensuring GDPR compliance

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware of such collection, we will promptly delete the information.

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last updated" date
• Sending email notifications for significant changes

Continued use of our services after changes constitutes acceptance of the updated policy.

13. Contact Information

For privacy-related questions or to exercise your rights, contact us: