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Privacy policy

Draft updated on 1 October 2026

Working document drafted from the actual site code: it is not legal advice. At the bottom you will find the points to have reviewed by a professional.

Data controller and contact

[TO COMPLETE: name/legal entity]

info@ondera.it

Registered office and VAT number: to be added once available.

Data we collect

By filling in the demo request form you provide: full name, work email, agency, message and site language. If the link you arrived from contains the campaign tracking (tag) parameters utm_source, utm_medium and utm_campaign, we also store those (up to 64 characters each) to understand where requests come from. To prevent repeated submissions we process your connection's IP address as the rate-limit key (5 submissions per minute): it is used only in that check and is never saved in the stored records. Nothing else: the site does not collect data from third parties and does not enrich contact lists.

Purpose

We use the data solely to respond to your demo request and to get back to you about it. No profiling, no automated marketing communications: replies come from a person.

Retention

Stored requests automatically expire after 12 months (DEMO_REQUEST_TTL_DAYS constant). In system logs, on success, we only record key, language and masked email; the full payload is logged only if storage fails, because in that case the log is the only copy of the request.

Recipients and transfers outside the EEA

Hosting, runtime and storage are managed by Cloudflare, Inc. (Workers and Workers KV). By default, KV entries replicate across Cloudflare's entire network with no jurisdictional restriction: data may therefore also be processed outside the European Economic Area. For such transfers Cloudflare relies on the Standard Contractual Clauses as described in its Privacy Policy, and processing is governed by Cloudflare's Data Processing Addendum. No other recipient receives the data.

Your rights (GDPR)

You have the right to access, rectification, erasure, restriction, objection and portability of your data. You can exercise your rights by writing to us through the demo request form and you can lodge a complaint with the data protection authority (Garante).

Technical elements only and, with your consent, anonymous visit measurement. Choose from the banner or from “Cookie settings” at the bottom of the page.

  • ondera-locale (first-party cookie): set automatically on first visit, 365-day duration, Path=/, SameSite=Lax, Secure. It remembers the language.
  • ondera-theme (localStorage): set when you choose light/dark theme; stays in your browser and is never sent to the server.
  • ondera-consent (localStorage): your cookie category choices (necessary, preferences, analytics, marketing); stays in your browser and can be changed at any time.
  • Cloudflare Web Analytics (cookieless measurement tag): loaded ONLY if you consent to the analytics category. It collects visits in aggregate form (pages visited, referrer, browser and device type) with no cookies and no cross-site tracking. Before you choose, or with “Necessary only”, no external script is loaded at all.
  • No profiling or marketing cookies, no advertising identifiers.

Official references

Cloudflare (hosting and KV) publishes its own reference policies:

To be reviewed by a professional

Open points to validate with a lawyer/privacy consultant before final publication:

  • Controller details (legal entity, registered office, VAT number) and a dedicated privacy email address.
  • Specific legal basis for each processing activity (Art. 6 GDPR).
  • Transfers outside the EEA: validate Cloudflare's SCCs and Data Processing Addendum for your case.
  • Retention of Cloudflare platform logs versus the 12 months declared for the archive.
  • Legal basis for the analytics beacon (consent in the banner) and retention of Cloudflare statistics.