Privacy Policy
Last updated: June 2025
1. Data Controller
The data controller for personal data collected through this website is:
Smartly Engineering S.r.l.
Email: privacy@smartlyeng.com
2. Project Context
The Gulliveru platform is developed as part of the NextGenGuides project, co-funded by the Calabria Region through the PR Calabria FESR-FSE 2021/2027 – Action 1.1.1 programme, managed by Fincalabra S.p.A. All personal data processing is carried out in compliance with EU Regulation 2016/679 (GDPR) and Italian Legislative Decree 196/2003 as amended.
3. Data Collected
Through the waitlist sign-up form on this website, we collect exclusively:
- Name and Email address, voluntarily provided by the user.
We do not collect browsing data, do not use profiling cookies, and do not employ third-party analytics tools or tracking pixels.
4. Purposes and Legal Basis
| Purpose | Legal basis |
|---|---|
| Managing the pre-launch waitlist and sending updates about the Gulliveru service | Consent of the data subject (Art. 6(1)(a) GDPR) |
| Sending launch updates and platform news | Consent of the data subject (Art. 6(1)(a) GDPR) |
Providing your data is optional. Failure to provide it simply means you will not be able to join the waitlist.
5. Processing Methods
Data is processed using electronic tools in compliance with the security measures required by the GDPR. The sign-up form is managed through Formspree (Formspree Inc., USA), acting as a data processor pursuant to Art. 28 GDPR. Data transfers to the USA are carried out in compliance with GDPR safeguards (Standard Contractual Clauses). For more information: formspree.io/legal/privacy-policy.
6. Data Retention
Data will be retained until consent is withdrawn by the user, or until the launch of the Gulliveru platform and for a maximum of 12 months thereafter, unless the user requests earlier deletion.
7. Data Sharing and Disclosure
Your data will not be shared with, sold to, or disclosed to any third party, with the exception of Formspree Inc. as described in section 5. Data will not be subject to automated decision-making or profiling.
8. Your Rights
Under Arts. 15–22 of the GDPR, you have the right to:
- Access: obtain confirmation of whether your data is being processed and receive a copy.
- Rectification: request correction of inaccurate or incomplete data.
- Erasure ("right to be forgotten"): request deletion of your personal data.
- Restriction: request restriction of processing in certain circumstances.
- Objection: object to the processing of your data.
- Portability: receive your data in a structured, machine-readable format.
- Withdraw consent: withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please send a request to privacy@smartlyeng.com. We will respond within 30 days of receiving your request.
9. Right to Lodge a Complaint
You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali — www.garanteprivacy.it) if you believe that the processing of your data violates the GDPR.
10. Cookies and Tracking Technologies
This website does not use profiling cookies, analytics cookies, or third-party tracking pixels. Only strictly necessary technical cookies may be present, for which consent is not required under Art. 122 of Italian Legislative Decree 196/2003.
11. Changes to This Policy
We reserve the right to update this Privacy Policy at any time. Changes will be published on this page with an updated date at the top. In the event of material changes, waitlist subscribers will be notified by email.