Privacy Policy

1. Data controller

• SMART Projects S.r.l.s
• Registered office: Via Tuscolana 16, 00182 Rome, Italy
• Operational office: Via dei Giubbonari 30, 00186 Rome, Italy
• VAT no. 15369511009
• Email: info@smartprojectsadvisory.com
• Certified email (PEC): smartprojects@pec.it

2. What data we process

Browsing data. The hosting provider's systems automatically record certain technical data needed for the website to work and stay secure, such as IP address, date and time of the request, page visited and browser type. This data is not used to identify users.

Data you provide. When you contact us through the website forms, WhatsApp, phone or email, we process the data you choose to share with us: full name, phone number, email, company (if any) and the content of your request.

Please do not include special categories of data (for example health information) in your messages unless strictly necessary for your request.

3. How the contact forms work

The website forms do not store or send any data to our servers. When you press “Send via WhatsApp”, your browser opens WhatsApp with a message pre-filled with the details you entered. The message is only sent to us if you choose to press Send in the app.

From that point on, communication takes place through the WhatsApp service, provided by WhatsApp Ireland Limited, which processes data under its own privacy policy. We receive the message on the business devices of the contacts listed on the Contact page.

4. Purposes and legal bases

• Answering your requests and providing information or quotes: pre-contractual measures taken at your request (Art. 6(1)(b) GDPR).
• Managing any resulting professional relationship: performance of a contract (Art. 6(1)(b) GDPR).
• Complying with legal, accounting and tax obligations (Art. 6(1)(c) GDPR).
• Keeping the website secure and preventing misuse: the controller's legitimate interest (Art. 6(1)(f) GDPR).

We do not use your data for marketing purposes without your explicit consent, and we do not carry out profiling.

5. Providing your data

Providing your data is optional. Without your contact details, however, we cannot respond to your request.

6. Who we share data with

Data is processed by authorised and instructed SMART Projects staff and collaborators. It may also be shared, only to the extent necessary, with:

• licensed professionals, bodies and partners involved in your project (for example real estate agencies, financial institutions, certification bodies, security firms), always after informing you and only when needed to follow up on your request;
• technical service providers, such as the website hosting provider, appointed as data processors where required;
• accounting and tax advisers and public authorities, where required by law.

Data is never published or sold to third parties.

7. Transfers outside the European Union

Some providers, such as WhatsApp and the Meta group, may also process data outside the European Union. In such cases, transfers rely on European Commission adequacy decisions (such as the EU-U.S. Data Privacy Framework) or on standard contractual clauses.

8. How long we keep data

• Contact requests not followed by an engagement: up to 24 months from the last contact.
• Data relating to engagements and professional relationships: for the duration of the relationship and thereafter for the periods required by law (usually 10 years for accounting and tax records).
• Browsing data: for the period set by the hosting provider for technical and security purposes.

9. Your rights

You may exercise the rights provided by Articles 15–22 GDPR at any time:

• access to your data and a copy of it;
• rectification of inaccurate or incomplete data;
• erasure of your data (right to be forgotten);
• restriction of processing;
• data portability;
• objection to processing based on legitimate interest;
• withdrawal of any consent given, without affecting processing already carried out.

To exercise your rights, write to info@smartprojectsadvisory.com or to the certified email address smartprojects@pec.it. We will reply within 30 days.

You also have the right to lodge a complaint with the Italian Data Protection Authority, Garante per la protezione dei dati personali (www.garanteprivacy.it).

10. Security

We take appropriate technical and organisational measures to protect data against unauthorised access, loss or disclosure. The website is served over an encrypted connection (HTTPS) and does not collect data through its own servers.

11. Changes to this notice

We may update this notice to reflect changes in the law or in our services. The current version is always published on this page, together with the date of the last update.