Privacy & Cookie Policy
Information on personal-data processing related to browsing in2pm.com, the optional use of Google Analytics, and messages voluntarily sent by users.
1. Data controller
in2pm di Paolo Maffi
Marone (BS), Italy
VAT No. IT01753040938
Email: paolo.maffi@in2pm.com
2. Data processed while browsing
The website is static and does not use backend contact forms, embedded social widgets, maps or third-party videos. The hosting infrastructure may process technical data required for communication and security, such as IP address, date and time of the request, requested resource, user agent and log information.
Purposes: technical delivery of the website, security, abuse prevention and troubleshooting. Legal basis: the Controller’s legitimate interest in the security and proper operation of the website (Article 6(1)(f) GDPR).
3. Google Analytics 4
The website uses Google Analytics 4 (measurement ID G-MH43LE3N2J) solely for website-usage statistics and only after the user has consented. Before acceptance, the Google Analytics tag is not loaded and no data are sent to Analytics.
The current configuration keeps Google Signals, user-provided data collection, ads personalisation and granular location/device data collection disabled. Standard statistical measurements are enabled, including page views, scrolls, outbound clicks and file downloads.
Legal basis: the data subject’s consent (Article 6(1)(a) GDPR and applicable ePrivacy rules). Consent is optional and can be withdrawn at any time through the “Cookie settings” link in the footer.
Google Analytics is a Google service. For information on Google’s processing, see the Google Privacy Policy and Google cookie information.
4. Data voluntarily provided when contacting in2pm
The website does not collect data through forms. Email links open the user’s email client; personal data are processed only if the user chooses to send a message. This may include name, surname, email address, organisation, role and information included in the request.
Purposes: responding to the request, assessing a possible engagement or collaboration, preparing information, proposals or quotations, and managing any requested follow-up.
Legal basis: steps at the data subject’s request prior to entering into a contract (Article 6(1)(b) GDPR) or, for general professional enquiries, legitimate interest in handling professional correspondence (Article 6(1)(f) GDPR).
Contact data will not be used for newsletters or direct marketing without a separate legal basis and, where required, specific consent.
5. Provision of data
Providing data by email is voluntary. Consent to Google Analytics is also voluntary: refusing Analytics does not prevent access to or use of the website.
6. Recipients and service providers
To the extent necessary, data may be processed by technical service providers used for hosting, email, security, backup and IT support and, where Analytics consent is given, by Google in connection with Google Analytics. Personal data are not publicly disclosed.
7. International transfers
Where a service provider involves transfers outside the European Economic Area, such transfers take place in accordance with Chapter V GDPR and the applicable safeguards. For European data processed in connection with Google services, Google’s applicable contractual terms and safeguards apply.
8. Retention
Hosting technical data and logs are retained for the period needed for technical and security purposes according to the hosting configuration. Contact messages are retained for the time needed to manage the request and related follow-up; if no relationship follows, normally no longer than 12 months, unless longer retention is required by law or to protect legal rights.
For Google Analytics, the GA4 property is configured with 14 months retention for user and event data. Analytics cookies installed after consent have durations defined by Google and the service configuration.
9. Data subject rights
Where applicable under the GDPR, data subjects may request access, rectification, erasure, restriction and portability and may object to processing based on legitimate interests. Consent may be withdrawn at any time without affecting the lawfulness of prior processing. Requests may be sent to paolo.maffi@in2pm.com. Data subjects also have the right to lodge a complaint with the competent supervisory authority.
10. Cookies and other tracking technologies
By default, the website does not load Google Analytics. On the first visit, users can choose between continuing without Analytics and accepting Analytics; closing the banner is equivalent to continuing without Analytics. The choice is stored locally to avoid showing the banner on every visit and is requested again after approximately 180 days or when the consent configuration version changes.
| Tool | Purpose | When used | Indicative duration |
|---|---|---|---|
Local preference in2pm_analytics_consent | Store the Analytics choice | Necessary to manage the preference | Up to 180 days |
Google Analytics cookies _ga and _ga_* variants | Usage statistics and visit distinction | Only after consent | According to Google configuration; the _ga cookie may last up to 2 years |
Consent can be changed at any time using the button below. On withdrawal, the website deletes Analytics cookies accessible from the domain and, on the next page load, no longer loads the Analytics tag.
11. Links to external websites
The website contains links to external services, including LinkedIn and paolomaffi.it. A simple link does not load content from those services inside in2pm.com; when users choose to visit them, data processing is governed by the relevant external privacy notices.
12. Changes to this notice
This notice is updated when services, purposes, tracking tools or other relevant processing characteristics change.