INFORMATION ON THE PROCESSING OF PERSONAL DATA
(pursuant to Art. 13 of EU Regulation 2016/679)
This information notice describes the methods for processing the personal data of users who consult the
Etenim S.r.l. website, accessible at the address https://etenim.it (hereinafter “Site”).
This information is provided pursuant to Article 13 of Regulation (EU) 2016/679 (hereinafter “GDPR”) and
does not apply to other websites, pages, or online services reachable via hypertext links that may be
published on the Site but refer to resources external to the Controller’s domain.
1. Data Controller
The Controller of the personal data processing is:
Etenim S.r.l.
Registered Office: Via dei Coronari n. 44 – Rome
VAT Number: 16557671001
Contact details: info@etenim.it – tel. 0645473460
2. Types of Data Processed
Following navigation of the Site, the Controller processes the following categories of personal data:
a) Data provided voluntarily by the user
The optional, explicit, and voluntary sending of messages to the Controller’s contact addresses, as well as the
filling out and submission of any contact forms on the Site, involve the acquisition of the sender’s
contact data (e.g., name, surname, email address), necessary to respond, as well as all personal data
included spontaneously in the communications.
b) Navigation data
The computer systems and software procedures used to operate this Site acquire, during
their normal operation, some personal data whose transmission is implicit in the use of Internet
communication protocols. This category of data includes IP addresses or domain names of the
computers and terminals used by users, the URI/URL (Uniform Resource
Identifier/Locator) addresses of the requested resources, the time of the request, the method used to submit the
request to the server, the size of the file obtained in response, the numerical code indicating the status of the
response given by the server (successful, error, etc.), and other parameters relating to the user’s operating system and
IT environment.
c) Data collected through cookies and other tracking tools
The Site uses technical cookies, necessary for its operation, and, subject to the user’s consent, statistical
and marketing cookies. For detailed information on the type of cookies used, the purposes, and the
methods for managing consent, please refer to the specific Cookie Policy.
3. Purpose and Legal Basis of Processing
Personal data are processed for the following purposes and on the basis of the following legal grounds:
To ensure the correct functioning and security of the Site: navigation data are processed
to allow the use of the Site and to monitor its correct functioning.
Legal basis: Legitimate interest of the Controller (Art. 6, par. 1, point f) GDPR).
To manage user requests: data provided voluntarily are processed to respond to
requests for information, quotes, or other nature.
Legal basis: Execution of pre-contractual measures taken at the request of the data subject
(Art. 6, par. 1, point b) GDPR). To comply with legal obligations: data may be processed to comply with obligations arising
from national or EU regulations.
Legal basis: Compliance with a legal obligation (Art. 6, par. 1, point c) GDPR).
Statistical analysis and marketing activities: data collected through non-technical cookies are used
to analyze traffic, monitor advertising campaigns, and improve digital
communication.
Legal basis: Consent of the data subject (Art. 6, par. 1, point a) GDPR).
4. Processing Methods
Data processing is carried out using IT tools and, to a residual extent, paper-based methods, with logic
strictly related to the indicated purposes and, in any case, in such a way as to guarantee the security and confidentiality
of the data themselves, in compliance with the principles of lawfulness, fairness, transparency, minimization, and adequacy
provided for by the GDPR. Specific technical and organizational security measures are adopted to prevent the
loss of data, illicit or incorrect use, and unauthorized access.
5. Data Retention Period
Personal data are stored for the time strictly necessary to achieve the purposes for which
they were collected, and in particular:
Data relating to contact requests: up to 12 months from the management of the request, unless
a contractual relationship is established.
Customer data: for the entire duration of the contractual relationship and, subsequently, for the period
provided for by civil and tax regulations (normally 10 years from the termination of the relationship).
Navigation data: for the time necessary to ensure the security and operation of the site and
normally deleted within a short time.
Data collected through cookies: for the duration specified in the Cookie Policy.
6. Communication and Recipients of Data
Personal data are not subject to dissemination. They may be communicated to subjects acting as
Data Processors (Art. 28 GDPR), such as providers of IT services and support for the
operation of the Site. The data may also be processed by internal personnel authorized for processing.
The updated list of Data Processors is available upon request from the Controller.
For analysis and marketing purposes, data collected through cookies may be processed by third parties as
independent data controllers, including:
Google Ireland Ltd. (for Google Analytics and Google Ads services)
Meta Platforms Ireland Ltd. (for services related to Facebook and Instagram)
LinkedIn Ireland Unlimited Company (for services related to LinkedIn)
7. Transfer of Data Abroad
The use of the third-party services indicated above may involve the transfer of personal data outside
the European Economic Area (EEA), in particular to the United States. Such transfers
take place in compliance with the adequate guarantees provided for by the GDPR, such as the adoption of Standard
Contractual Clauses (SCC) approved by the European Commission, supplemented by additional measures to
guarantee a level of protection substantially equivalent to the European one.8. Rights of the Data Subject
As a data subject, the user may exercise at any time the rights provided for by Articles 15-22 of the
GDPR, and in particular:
Right of access (Art. 15): obtain confirmation as to whether or not personal data
concerning them are being processed and, if so, access the data.
Right to rectification (Art. 16): obtain the correction of inaccurate personal data.
Right to erasure (“right to be forgotten”, Art. 17): obtain the erasure of personal
data, in the cases provided for by law.
Right to restriction of processing (Art. 18): obtain the restriction of processing, upon
the occurrence of certain hypotheses.
Right to data portability (Art. 20): receive in a structured, commonly used, and
machine-readable format, the personal data concerning them and transmit them to another
controller.
Right to object (Art. 21): object at any time to the processing of personal data
for marketing purposes or based on legitimate interest.
Right to withdraw consent (Art. 7): withdraw the consent given at any time, without
affecting the lawfulness of processing based on consent before its withdrawal.
The data subject also has the right to lodge a complaint with the Data Protection
Authority.
9. Methods for Exercising Rights
Requests for the exercise of rights can be sent to the Data Controller at the following
email address: info@etenim.it.
10. Updates to the Information Notice
This Privacy Policy may be subject to changes and updates. The user is invited to consult it
periodically to be informed about the methods of processing their personal data.
Last update: February 02, 2026
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COOKIE POLICY
(pursuant to Art. 13 of EU Regulation 2016/679 and the Provision of the Data Protection
Authority n. 231 of June 10, 2021)
This Cookie Policy integrates the Privacy Policy of the website https://etenim.it (hereinafter “Site”) and
describes in detail the types of cookies used and the ways in which the user can manage their
preferences.
1. Data Controller
The Data Controller is Etenim S.r.l., with registered office in Via dei Coronari n. 44 – Rome (VAT No.
16557671001), contactable at the email address info@etenim.it.
2. What are Cookies
Cookies are small text files that the sites visited by the user send and record on their computer or
mobile device, to be then retransmitted to the same sites at the next visit. Thanks to cookies, a site
remembers the user’s actions and preferences (such as, for example, login data, the chosen language, font sizes, other display settings, etc.) so that they do not have to be
indicated again when the user returns to visit said site or navigates from one page to another of it.
3. Types of Cookies used by the Site
The Site uses the following types of cookies:
a) Technical Cookies
These cookies are strictly necessary for the correct functioning of the Site and to allow
navigation. They do not require the user’s consent as they are essential to provide the service
requested. This category includes navigation or session cookies and functionality cookies (e.g.,
to store the choice on language or on the cookies themselves).
b) Statistical Cookies (or Analytics)
These cookies, including third-party ones, are used to collect information in aggregate and
anonymous form on the number of users and how they visit the Site, in order to improve its content and
performance. The Site uses the Google Analytics 4 service (provider: Google Ireland Ltd.). The installation
of such cookies and the related data processing take place only with the user’s explicit consent.
c) Marketing and Profiling Cookies
These cookies, from third parties, are used to track the user’s navigation on the network and create profiles
on their tastes, habits, choices, etc. With these cookies, advertising messages in line with the preferences already expressed by the same user in online navigation can be transmitted to the user’s terminal.
The Site uses digital marketing and online advertising tools through: The use of such cookies is
subject to the user’s prior consent.
4. Legal Basis of Processing
4. Legal Basis of Processing
For technical cookies: the legitimate interest of the Controller to ensure the correct functioning and
security of the Site (Art. 6, par. 1, point f) GDPR).
For statistical and marketing/profiling cookies: the user’s consent (Art. 6, par. 1, point a)
GDPR).
5. Consent Management
Upon first access to the Site, the user sees an information banner that allows them to make a choice
regarding the use of cookies. The user can:
Accept all cookies, giving consent to the installation of all types of cookies.
Reject non-necessary cookies, continuing navigation with default settings only
(technical cookies only).
Manage preferences in a granular way, choosing which specific categories of cookies
to authorize.
The consent given can be modified or withdrawn at any time through the appropriate preference
management panel, accessible from a permanent link in the footer of the Site.
6. Recipients and Transfer of Data
Data collected through cookies may be processed by authorized personnel of the Controller and by providers of
technical services. For third-party cookies, data are processed by the respective providers (Google, Meta, LinkedIn)
as independent controllers. The use of such services may involve the transfer of data outside
the European Economic Area, based on the guarantees provided for by the GDPR (e.g., Standard Contractual
Clauses), as better specified in the Privacy Policy.7. Retention Period
The duration of each cookie is variable. Session cookies expire when the browser is closed, while
permanent cookies have a predefined expiration date. For details on the retention duration of
each cookie, please refer to the information available in the preference management panel.
8. User Rights
The user may exercise the rights provided for by Arts. 15-22 of the GDPR (access, rectification, erasure,
restriction, portability, objection, withdrawal of consent) by contacting the Controller at the address
info@etenim.it. It is also possible to lodge a complaint with the Data Protection
Authority.
Last update: February 02, 2026
