Privacy & Cookie Policy

1. Data Controller

The data controller for this website is Paolo Chignoli, independent professional with registered office in Milan, Italy.

Contact: info@paolochignoli.it

2. What Data We Collect

This website is designed to minimize data collection. We process the following information:

• Anonymous usage analytics — We use Vercel Web Analytics, which collects aggregated, non-personally-identifiable page view data. It does not use cookies, does not track users across sites, and does not store IP addresses. Data is processed in accordance with Vercel's privacy policy.
• AI chat messages — If you use the on-site AI assistant, your messages are sent to our server and processed via Google Gemini to generate responses. Messages are not stored persistently and are not linked to your identity. Your IP address may be temporarily processed for rate limiting purposes.
• Voluntary communications — If you contact us via email or booking links, we process the personal data you provide (name, email, message content) solely to respond to your inquiry.

3. Cookie Policy

This website uses only strictly necessary technical cookies (or equivalent local storage mechanisms) required for the website to function correctly, such as storing your cookie consent preference.

We do not use profiling cookies, advertising cookies, or third-party tracking cookies. Vercel Web Analytics operates without cookies.

4. Legal Basis for Processing

• Legitimate interest (Art. 6(1)(f) GDPR) — for anonymous usage analytics and website security (rate limiting).
• Consent (Art. 6(1)(a) GDPR) — for processing AI chat messages.
• Pre-contractual measures (Art. 6(1)(b) GDPR) — for responding to inquiries about consulting services.

5. Data Sharing and Transfers

Your data may be processed by the following third-party service providers, acting as data processors:

• Vercel Inc. (USA) — website hosting and anonymous analytics. Data transfers are covered by the EU-US Data Privacy Framework.
• Google LLC (USA) — AI chat processing via Google Gemini API. Data transfers are covered by the EU-US Data Privacy Framework.

We do not sell, rent, or share your personal data with any other third parties.

6. Data Retention

Anonymous analytics data is retained by Vercel for up to 30 days. AI chat messages are processed in real-time and not stored persistently. Email communications are retained for the duration of the business relationship and deleted upon request.

7. Your Rights

Under the GDPR and Italian privacy law (D.Lgs. 196/2003, as amended), you have the right to:

• Access the personal data we hold about you
• Request rectification or erasure of your data
• Restrict or object to data processing
• Request data portability
• Withdraw consent at any time
• Lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali — garanteprivacy.it)

To exercise any of these rights, contact us at info@paolochignoli.it.

8. Changes to This Policy

We may update this policy to reflect changes in our practices or applicable law. The “last updated” date at the top of this page indicates the most recent revision. Continued use of the website after changes constitutes acceptance of the updated policy.