1. Data Controller

The Data Controller is:

This Privacy Notice describes how PALUMBO SUPERYACHTS S.r.l. processes the personal data of users who browse the website, use contact forms, request information, send communications or interact with any online services made available through the website.

2. Data Protection Officer — DPO

PALUMBO SUPERYACHTS S.r.l. has appointed Engineer Francesco Cinotti as its Data Protection Officer pursuant to Articles 37 et seq. of the GDPR.

The DPO may be contacted at the following addresses:

The DPO may be contacted regarding any matter relating to the processing of personal data and the exercise of the rights provided under the GDPR.

3. Categories of Personal Data Processed

Through the website, PALUMBO SUPERYACHTS S.r.l. processes only ordinary personal data, meaning personal data that does not fall within the special categories referred to in Article 9 of the GDPR.

For illustrative purposes, the following data may be processed:

a) Browsing Data

During their normal operation, the IT systems and software procedures used to maintain the website may acquire certain data which transmission is implicit in the use of Web communication protocols.

This category may include:

• IP addresses;
• date and time of access;
• pages visited;
• type of browser used;
• operating system;
• domain names and addresses of the websites from which access was made;
• technical information related to browsing activity.

Such data is used to ensure the proper operation of the website, maintain IT security, obtain aggregated and anonymous statistical information regarding website use and establish liabilities in the possibility of cybercrime or unlawful activity.

b) Data Voluntarily Provided by the User

The voluntary sending of communications to the addresses indicated on the website or the completion of online forms may involve the processing of personal data provided by the user, including:

• first name and surname;
• company or organisation;
• corporate role or position;
• email address;
• telephone number;
• content of the request or communication;
• any other personal data voluntarily included in the message.

Users are requested not to submit data unnecessary for the purpose of the request being made.

c) Data Relating to Commercial or Pre-contractual Relationships

Whenever a user contacts PALUMBO SUPERYACHTS S.r.l. to request a quotation, commercial information, assistance, collaboration or the provision of services, personal data connected with the management of the request, the pre-contractual stage or any subsequent contractual relationship may be processed.

4. Special Categories of Personal Data

PALUMBO SUPERYACHTS S.r.l. does not request the provision of special categories of personal data through the website within Article 9 of the GDPR, including, for instance, data concerning health, political opinions, religious or philosophical beliefs, trade union membership, biometric data or data concerning a person’s sex life or sexual orientation.

Whenever a user voluntarily submits special categories of personal data that have not been requested, PALUMBO SUPERYACHTS S.r.l. may, where possible, delete or anonymise such data, unless its retention is necessary to comply with legal obligations, exercise rights or protect legitimate interests in judicial or out-of-court proceedings.

5. Purposes and Legal Bases of Processing

Personal data is processed for the following purposes.

5.1 Website Browsing and Technical Operation

Browsing data is processed to ensure the proper operation of the website, maintain system security and prevent abuse, cyberattacks or unauthorised access.

5.2 Management of Requests Submitted through the Website, by Email or through Contact Forms

Data provided by users is processed to respond to requests for information, quotations, assistance, appointments, job applications, commercial communications or other requests voluntarily submitted.

5.3 Administrative, Accounting, Tax and Legal Obligations

Whenever an online contact results in a contractual, commercial or administrative relationship, personal data may be processed to comply with obligations arising from laws, regulations or applicable tax and accounting legislation.

5.4 Protection of the Data Controller’s Rights

Personal data may be processed to establish, exercise or defend the rights of PALUMBO SUPERYACHTS S.r.l. in judicial, out-of-court or administrative proceedings, or during the preliminary stages of litigation.

5.5 Share of Informational Communications, Newsletters or Promotional Material

Wherever the website includes forms for subscribing to newsletters or receiving commercial communications, personal data will be processed only after the user has given specific consent.

The data subject may withdraw consent at any time, without affecting the lawfulness of the process carried out before consent was withdrawn.

5.6 Statistical Analysis and Website Improvement

PALUMBO SUPERYACHTS S.r.l. may process aggregated or anonymised data to understand how the website is used and improve its content, structure and functionality.

Whenever non-anonymised analytics tools or third-party tools involving user tracking are used, processing will take place only after consent has been obtained.

6. Nature of the Provision of Data

The provision of browsing data is necessary to enable the technical operation of the website.

The provision of data through contact forms, email or other communication channels is optional. However, failure to provide the necessary data may prevent PALUMBO SUPERYACHTS S.r.l. from responding to the user’s request or providing the requested service.

Consent for marketing, newsletters, non-technical analytics or profiling purposes is always optional. Failure to provide consent will not affect the user’s ability to browse the website or access essential services.

7. Methods of Processing

Personal data is processed using IT, electronic and, where necessary, paper-based tools, in accordance with the principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity and confidentiality.

PALUMBO SUPERYACHTS S.r.l. adopts appropriate technical and organisational measures to protect personal data against loss, unlawful or improper use, unauthorised access, disclosure, alteration or destruction.

Processing is carried out by authorised and appropriately instructed personnel, within the limits of their respective duties and in accordance with internal procedures consistent with applicable legislation.

8. Data Retention Period

Personal data is retained for no longer than is strictly necessary to achieve the purposes for which it was collected, unless longer retention periods are required by law or are necessary to protect the Data Controller’s rights.

In particular:

Once the applicable retention period has expired, personal data will be deleted, anonymised or retained only where necessary to comply with legal obligations or protect the Data Controller’s rights.

9. Recipients of Personal Data

Personal data may be processed by:

• personnel authorised by PALUMBO SUPERYACHTS S.r.l.;
• parties providing hosting, maintenance, website management, IT security and technical support services;
• providers of email, certified email, CRM, management platforms or digital services;
• consultants, professionals and legal, tax or administrative firms;
• public bodies, competent authorities or supervisory bodies, where required by law;
• parties acting as Data Processors pursuant to Article 28 of the GDPR.

Personal data will not be made publicly available or disseminated indiscriminately.

10. Transfers of Personal Data outside the European Economic Area

PALUMBO SUPERYACHTS S.r.l. gives preference to providers and infrastructure located within the European Economic Area.

Whenever, for technical or organisational reasons, it becomes necessary to transfer personal data to countries outside the European Economic Area, the transfer will take place in accordance with Articles 44 et seq. of the GDPR, on the basis of a European Commission adequacy decision, standard contractual clauses, supplementary measures or other safeguards provided for under applicable legislation.

11. Cookies and Tracking Tools

The website may use cookies and similar technologies to ensure the proper operation of its pages, improve the browsing experience, collect statistical information or, where applicable, provide personalised content.

11.1 Technical Cookies

Technical cookies are necessary for the operation of the website and do not require the user’s consent.

They enable, for example, website navigation, session management, the storage of technical preferences and website security.

11.2 Analytics Cookies

The website may use analytics cookies to collect statistical information regarding website use.

Where analytics tools are configured in an anonymised form and do not allow users to be directly identified, they may be treated in the same manner as technical cookies.

Where analytics tools enable user tracking or are provided by third parties without adequate anonymisation, they will be installed only after the data subject has given consent.

11.3 Marketing or Profiling Cookies

Any marketing, profiling, remarketing or advertising-tracking cookies will be used only after the user has given express consent.

Users may accept, reject or change their preferences through the cookie banner or the dedicated consent management panel.

11.4 Consent Management

When first accessing the website, users are shown a banner allowing them to:

• accept all cookies;
• reject non-essential cookies;
• manage their preferences individually.

Users may amend or withdraw their consent at any time.

11.5 Cookie Table

The complete table of cookies used must be kept updated and made available to users.

12. Links to Third-party Websites

The website may contain links to third-party websites, platforms or services.

PALUMBO SUPERYACHTS S.r.l. is not responsible for personal data processing activities carried out by such third parties.

Users are encouraged to read the privacy notices of third-party websites before providing personal data or using the relevant services.

13. Plug-ins, Maps, Videos and External Content

Whenever the website embeds third-party content, such as maps, videos, social media widgets, external fonts or similar tools, such services may collect users’ personal data, including browsing data and IP addresses.

Where such tools are not strictly necessary for the operation of the website, they will be activated in accordance with applicable legislation and, where required, only after the user has given consent.

14. Minors

The website is not specifically intended for minors, and PALUMBO SUPERYACHTS S.r.l. does not intentionally collect minors’ personal data through the website.

Whenever a minor has submitted personal data, the person exercising parental responsibility may request its deletion by contacting the Data Controller or DPO using the contact details provided in this Privacy Notice.

15. Automated Decision-making and Profiling

PALUMBO SUPERYACHTS S.r.l. does not use automated decision-making processes through the website that produce legal effects concerning data subjects or similarly affect them.

Any profiling activities carried out through cookies or marketing tools will take place only after the data subject has given consent and in accordance with the information provided in the Cookie Policy.

16. Data Subject Rights

Within the cases and limitations provided for under the GDPR, data subjects may exercise the following rights:

• the right to access their personal data;
• the right to rectify inaccurate data or complete incomplete data;
• the right to erasure of personal data;
• the right to restriction of processing;
• the right to data portability, where applicable;
• the right to oppose the processing;
• the right to withdraw consent at any time, where processing is based on consent;
• the right not to be subject to a decision based solely on automated processing, including profiling, where applicable.

Requests to exercise these rights may be submitted by contacting:

or the DPO:

The Data Controller will respond within the time limits established by applicable legislation.

17. Complaint to the Supervisory Authority

Data subjects who believe that the processing of their personal data infringes the GDPR have the right to lodge a complaint with the Italian Data Protection Authority— or to seek a judicial remedy before the competent courts.

18. Updates to this Privacy Notice

PALUMBO SUPERYACHTS S.r.l. reserves the right to amend or update this Privacy Notice at any time, including following regulatory, technical or organisational changes or changes to the services offered through the website.

The updated version will be published on the website alongside its latest revision date.

19. Summary of Privacy Contact Details

For requests concerning the processing of personal data: