Legal
Privacypolicy
Pursuant to Articles 13-14 of EU Regulation 2016/679 (GDPR) and the Italian Privacy Code.
Updated 29 September 2026 · version 1.1
01Data Controller
CLDev SRL
Via S. Martini 88, 50142 Florence (FI), Italy
VAT: IT07198690484 · REA: FI 686625 · Share capital: €10,000.00 fully paid
- Email: info@cldev.it
- Certified email (PEC): cldev@pec.it
- Website: https://www.cldev.it
02Data Protection Officer (DPO)
Email: privacy@cldev.it
The DPO can be contacted for any matter relating to the processing of personal data and the exercise of data subject rights.
03Data Collected and Purposes of Processing
3.1 Contact Form
When you submit the contact form, we collect the following personal data:
| Field | Data Type | Required |
|---|---|---|
| Name | Identifier | Yes |
| Contact data | Yes | |
| Service of interest | Preference | Yes |
| Product (conditional) | Preference | No |
| Subject (conditional) | Free text | No |
| Message | Free text | Yes |
| Language | Preference (auto-detected) | No |
Purpose: Handle your inquiry, reply to you, send a confirmation email, and maintain an internal record of received communications.
Legal basis (Art. 6 GDPR):
- Art. 6(1)(b): performance of pre-contractual measures taken at the request of the data subject
- Art. 6(1)(f): legitimate interest of the Controller in properly managing received inquiries
3.2 Preferences Stored in the Browser
The site writes two values to browser localStorage: your language preference (key i18nextLng) and whether the cookie notice has already been read (key cldev_cookie_notice_seen).
Purpose: Display the site in your preferred language on return visits, and avoid showing the same notice on every visit.
Legal basis: Art. 6(1)(f) - legitimate interest. Both values stay only on your device and are never transmitted to CLDev SRL servers.
3.3 Server Log Data
Like all websites, our servers automatically collect standard log data including IP addresses, browser type, operating system, referring URL, and timestamps.
Legal basis: Art. 6(1)(f) - legitimate interest in website security and proper functioning.
04Data Processing and Retention
4.1 Contact Database
Contact form submissions are stored in a protected MySQL database for 12 months from the date the request was received, after which they are deleted or anonymised.
4.2 Email Communications
Upon form submission:
- A notification email is sent to info@cldev.it (internal use)
- A confirmation email is sent to the address you provided
Emails are transmitted via Aruba S.p.A. SMTP infrastructure (see section 5).
4.3 Security Measures
- HTTPS/TLS encrypted communications
- HTTP security headers (HSTS, Content-Security-Policy, X-Frame-Options, etc.)
- Encrypted email transport (SMTP with STARTTLS/SSL)
- Database access restricted to authorised systems only
05Data Processors and Third Parties
5.1 Aruba S.p.A. - Email Infrastructure
Notification and confirmation emails are sent via Aruba S.p.A. SMTP servers.
- Role: Data Processor (Art. 28 GDPR)
- Address: Via San Clemente 53, 24036 Ponte San Pietro (BG), Italy
- Privacy policy: aruba.it/privacy
5.2 Hosting Provider
The website is hosted on a server managed by Aruba S.p.A. – via San Clemente, 53 – 24036 Ponte San Pietro (BG) – VAT IT01573850516 – CF 04552920482, acting as Data Processor under Art. 28 GDPR.
5.3 External Fonts
The site’s typefaces are served by Google Fonts, and that request transmits your IP address to the provider. It is the only resource that comes from a third party: the application code, the stylesheets, the images and the translation files are all served directly from www.cldev.it.
| Service | Provider | Resource | Location |
|---|---|---|---|
| Google Fonts | Google LLC | Sora and Work Sans typefaces | USA (Data Privacy Framework) |
Google LLC is certified under the EU-US Data Privacy Framework, and the transfer rests on that basis under Arts. 44-45 GDPR.
06International Data Transfers
Data transfers to third countries occur only as described in section 5, and are based on:
- European Commission adequacy decisions (EU-US Data Privacy Framework, where applicable)
- Standard Contractual Clauses (SCCs) per Art. 46(2)(c) GDPR
07Your Rights
Under Arts. 15–22 GDPR, you have the right to:
| Right | GDPR Ref. | Description |
|---|---|---|
| Access | Art. 15 | Obtain confirmation of processing and access your personal data |
| Rectification | Art. 16 | Have inaccurate data corrected |
| Erasure | Art. 17 | Have your data erased ("right to be forgotten") |
| Restriction | Art. 18 | Restrict the processing of your data |
| Portability | Art. 20 | Receive your data in a structured, machine-readable format |
| Objection | Art. 21 | Object to the processing of your data |
| Withdraw consent | Art. 7(3) | Withdraw consent at any time where processing is consent-based |
To exercise your rights, contact us at:
- Email: privacy@cldev.it
- Certified email (PEC): cldev@pec.it
We will respond within 30 days of receiving your request.
Right to Lodge a Complaint
You have the right to lodge a complaint with the Italian Data Protection Authority (Garante Privacy):
- Website: garanteprivacy.it
- Email: garante@gpdp.it
- Address: Piazza Venezia 11, 00187 Rome, Italy
08Changes to This Policy
CLDev SRL reserves the right to update this policy at any time. Changes will be posted on this page with an updated date. Material changes will be communicated to registered users.
