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Privacy Policy

Home / Privacy Policy

Last updated: 5 October 2026

This notice explains how personal data of users who visit www.gianlu.it and use its services is processed, pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and Italian Legislative Decree 196/2003 (Privacy Code).

1. Data controller

Gianluca Bonomo, sole proprietorship
Registered office: Str. del Cardine, 18 - 10080 Feletto (TO), Italy
VAT ID: IT08954710011 - REA registration: TO-1015464
Email for any privacy request: info@gianlu.it

No Data Protection Officer (DPO) has been appointed, as the cases under Article 37 GDPR do not apply.

2. Data processed, purposes, legal bases and retention

ActivityData processedPurpose and legal basisRetention
Contact requests (website form, email, WhatsApp, phone)Full name, email, phone number, preferred contact method, message contentTo reply to your request for information, quotes or courses. Legal basis: pre-contractual measures taken at your request (Art. 6.1.b GDPR)For the time needed to reply to the request. If a contract follows, the retention periods of the next row apply
Purchase of books, courses and services on requestPersonal and contact details, shipping address and billing data, where neededTo perform the requested contract (Art. 6.1.b) and to comply with accounting and tax obligations (Art. 6.1.c)For the duration of the relationship; accounting and tax records for 10 years (Art. 2220 Italian Civil Code)
Account and monthly subscription (managed through Memberstack)Email, name, login credentials, subscription status and history. Payment card data is handled directly by the payment provider and is neither known nor stored by the controllerTo create the account, provide the features reserved to subscribers and manage payment (Art. 6.1.b); to comply with tax obligations (Art. 6.1.c)Until the account is deleted or you ask for deletion; accounting and tax records for 10 years
AI virtual assistants (ChatBookAI and the articles assistant)The text of the questions you type in the chat. A local counter of questions asked is saved in your browser (see Cookie Policy). For subscribers, the access token is verifiedTo generate the answer of the service you requested (Art. 6.1.b)The site does not store conversation history on its own server. Texts are sent to Google to generate the answer (see section 4)
Browsing data (technical server logs)IP address, date and time, pages requested, browser type and operating systemTo ensure the site works and is secure and to prevent abuse, including a daily request counter (stored as a non-reversible code derived from the IP, in a temporary file deleted within 2 days) that limits repeated submissions of the contact form and chats. Legal basis: legitimate interest (Art. 6.1.f)For the period set by the hosting provider, limited to what is needed for security

The site does not use statistical analytics, profiling or behavioural advertising tools.

Providing data is optional, but fields marked as required are necessary to reply to your request or activate the subscription. Without them the service cannot be provided.

3. Recipients of the data

Data is not disseminated. It may be shared, only as needed, with:

  • Aruba S.p.A., hosting and email provider (data processor);
  • Memberstack and its payment provider, for managing accounts, access and subscriptions (data processors); hCaptcha (Intuition Machines, Inc.) for anti-bot protection of login forms; Google if you choose to log in with your Google account;
  • Google (Gemini API), to generate the answers of the virtual assistants, and YouTube, for embedded videos;
  • tax and accounting advisers, for legal compliance;
  • public authorities, where required by law.

If you choose to contact me through WhatsApp, the service is provided by WhatsApp Ireland Ltd (Meta group), which processes data under its own notice as an independent controller.

4. Transfers outside the European Economic Area

Some providers (Google, Memberstack and the payment provider) may process data in the United States. Transfers take place with the safeguards of Chapter V GDPR, i.e. the adequacy decision on the EU-US Data Privacy Framework or the European Commission's standard contractual clauses.

Virtual assistants: the questions typed in the chat are sent to the Google Gemini API to obtain the answer. Please do not enter personal, sensitive or confidential data (yours or other people's) in your messages. Answers are generated by an artificial intelligence system and may contain errors: they are not professional advice.

5. Your rights

At any time you can ask for access to your data, rectification, erasure, restriction of processing, portability, and object to processing based on legitimate interest (Arts. 15-22 GDPR). Where processing is based on consent, you may withdraw it at any time, without affecting the lawfulness of the processing carried out before.

To exercise your rights write to info@gianlu.it. You will receive a reply within one month. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante) or with the authority of your country of residence.

6. Automated decision-making

No profiling or decision based solely on automated processing producing legal effects on the user is carried out. Answers of the virtual assistants are generated automatically, but they do not lead to any decision about you.

7. Minors

The services of the site are not aimed at children under 14. If you believe a minor has provided data without the consent of the holder of parental responsibility, write to info@gianlu.it and the data will be deleted.

8. Security

The site uses the HTTPS protocol and appropriate technical and organisational measures are adopted to protect data against unauthorised access, loss or disclosure. In case of a personal data breach, the controller makes the notifications required by Arts. 33 and 34 GDPR.

9. Cookies

For information on the cookies and storage technologies used, see the Cookie Policy.

10. Changes

This notice may be updated. The version in force is always the one published on this page, with the date of the last update.

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Gianluca Bonomo - Sole proprietorship - Str. del Cardine, 18, 10080 Feletto (TO), Italy - VAT ID IT08954710011 - REA TO-1015464
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