Privacy Policy

1. Data controller

The controller of your personal data is:

• ORIA 1.618 SAS — registered in Italy
• EXTELAR MARKET SL — registered in Barcelona, Spain (Tax ID: B-XXXXXXXX)

Contact: info@oriatoscana.com

2. Data we collect

We collect the following types of personal data:

• First and last name
• Email address
• Phone number
• Country of residence
• Browsing data (cookies, IP address, pages visited)
• Data voluntarily provided through forms or WhatsApp

3. Purpose of processing

Your data is processed for the following purposes:

• Handling enquiries and requests for information about memberships
• Managing co-ownership contracts
• Sending commercial communications and updates (with consent)
• Statistical analysis of web traffic to improve our services
• Compliance with legal obligations

4. Legal basis

The processing of your data is based on:

• Explicit consent of the data subject (Art. 6.1.a GDPR)
• Performance of a contract (Art. 6.1.b GDPR)
• Legitimate interest in providing the service (Art. 6.1.f GDPR)

5. Data recipients

Your data may be shared with the following third-party service providers:

• HubSpot, Inc. — CRM management and contact forms
• Stripe, Inc. — payment processing and KYC verification
• Google LLC — web analytics (Google Analytics / Google Tag Manager)
• Twilio Inc. — WhatsApp communications (Giulia)
• Anthropic PBC — AI processing for the Giulia agent

All providers are subject to data processing agreements compliant with the GDPR.

6. Data retention

We retain your data for as long as necessary to fulfil the purposes of processing or until you request its deletion, and in any case for the applicable legal periods (a minimum of 5 years for contractual documentation).

7. Your rights

Under the GDPR, you have the right to:

• Access: to know what data we hold about you
• Rectification: to correct inaccurate data
• Erasure: to request the deletion of your data
• Portability: to receive your data in a structured format
• Objection: to object to processing for marketing purposes
• Restriction: to request the restriction of processing

To exercise these rights, contact info@oriatoscana.com. You may also lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.

8. Cookies

This website uses first-party and third-party cookies for traffic analysis (Google Analytics / GTM) and basic functionality. You can configure your browser to reject cookies, although this may affect the functionality of the site. By continuing to browse, you accept the use of essential technical cookies.

9. International transfers

Some of our providers (HubSpot, Stripe, Google, Twilio, Anthropic) are established in the United States. Transfers are carried out under adequacy mechanisms compliant with the GDPR (Adequacy Decisions, Standard Contractual Clauses).

10. Amendments

We reserve the right to update this policy at any time. The current version will always be available on this page. We will notify you of significant changes by email.