Privacy notice
Last updated:
This page explains what personal data is processed when you visit novior.it or write to us, and why. It is the information required by Article 13 of the EU General Data Protection Regulation (GDPR).
Who is responsible
The site is run by Emanuele Longo and Antonio Macrì, two private individuals who act as joint controllers under Article 26 GDPR.
For anything about your data, write to privacy@novior.it. It is the single contact point for both of us.
We have agreed between us how we share our obligations under the GDPR, as Article 26 requires. In short: we decide together why and how data is processed, we handle requests from data subjects together through the address above, and each of us is answerable to you. The essence of the arrangement is available on request: write to privacy@novior.it. Whatever the arrangement says, you can exercise your rights with each of us (Article 26(3)).
What data we process
When you visit the site. As with any website, the server receives some technical data with every request: your IP address, the date and time, the page or file requested and your browser's user agent. We use it to deliver the pages and to keep the site secure.
When you write to us. If you email privacy@novior.it, we receive your email address, your message and anything you attach.
That's all. No cookies, no analytics, no profiling, no forms, no advertising. Fonts, scripts and stylesheets come from this site itself: opening a page doesn't load anything from other websites.
Why, and on what legal basis
- Delivering the pages and protecting the site from abuse and attacks (browsing data): our legitimate interest in running a working, secure website (Article 6(1)(f)).
- Replying to messages (emails): our legitimate interest in answering people who write to us (Article 6(1)(f)). If your request is about a contract or preparing one, Article 6(1)(b).
- Handling requests to exercise your rights (emails): legal obligation (Article 6(1)(c)).
Browsing data is needed to show you the site. Writing to us is up to you; without your email address we can't reply.
We don't take decisions based solely on automated processing, including profiling.
Who processes the data for us, and where
We use a single provider, appointed as processor under Article 28 GDPR: Microsoft (Microsoft Ireland Operations Limited, Dublin, Ireland). It hosts the site on Azure App Service, in the Italy North region in Milan, runs the DNS of novior.it (Azure DNS) and hosts our email (Microsoft 365).
Only the two of us have access to the emails. We don't share your data with anyone else, unless the law requires it.
For some of its own business operations, such as billing or aggregated statistics on how its service runs, Microsoft acts as an independent controller under its own terms.
Transfers outside the EEA
The site is hosted in the Azure Italy North region, in Milan, and Microsoft has committed to store and process the data of these services within the EU and the EFTA countries (the EU Data Boundary (external site)); Switzerland, the only EFTA country outside the European Economic Area, is covered by an adequacy decision of the European Commission. In the limited cases that Microsoft documents, such as security operations, technical support and the routing of network traffic, personal data may be transferred outside these countries, including to the United States.
In those cases Microsoft applies the European Commission's standard contractual clauses (Decision (EU) 2021/914) and is certified under the EU-U.S. Data Privacy Framework (adequacy decision (EU) 2023/1795). The details are in Microsoft's Data Protection Addendum (external site), and we can send you a copy of the safeguards on request.
How long we keep data
- Site logs. The site's application logs don't record IP addresses, and we haven't turned on access logs on the hosting platform. Microsoft keeps its own system logs in pseudonymized form, for the minimum time set for each type of log, and uses them only to run and secure the service. We have no access to them.
- Emails. For as long as we need to handle your request, and no longer than 24 months after our last exchange, unless we need them to establish, exercise or defend a legal claim.
Your rights
You can ask us for access to your data, rectification, erasure, restriction of processing and, where it applies, data portability (Articles 15 to 20 GDPR). Write to privacy@novior.it. We reply within one month; for complex requests this can be extended by two months (Article 12(3)). We may ask for some information to confirm who you are.
Right to object. You can object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests (Article 21 GDPR). We'll stop unless there are compelling legitimate grounds, such as protecting the site from an ongoing attack. Keep in mind that the site can't deliver a page to you without processing your IP address.
You also have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (external site), or with the supervisory authority of the EU country where you live or work, or where the alleged infringement took place.
Cookies
This site doesn't use cookies or similar technologies such as local storage, tracking pixels or fingerprinting. That's why there is no cookie banner.
Like any browser, yours may keep a copy of the pages in its cache and remember that this site must be opened over HTTPS. This only serves to show you the site, and we don't use it to recognize you.
Changes
If the way we process data changes, we'll update this page and the date at the top.