Privacy Policy

1. Introduction

Welcome to "Carlo Sacchi - Your Next IT Coach" ("I", "my", or "the Site"). I respect your privacy and am committed to protecting your personal data. This privacy policy describes how I collect, use, store, and share your data when you visit my website or interact with me.

2. Data Controller

The data controller is Carlo Sacchi (trading as «CareerUp+ Mentoring»), a professional established in the Netherlands:

• Dutch Chamber of Commerce registration (KvK): [KvK: _____________]
• Dutch VAT number (BTW-nummer): [BTW: NL_____________]
• Registered office: [Full address in the Netherlands]
• Contact email: [official email]

3. Data I Collect

When you use the contact form, I collect the following data:

• Full name
• Email address
• Subject of the message
• Content of the message
• Date and time of submission

When you purchase a program and sign the acceptance form, for the conclusion of the contract, invoicing and compliance with tax obligations I also collect:

• First and last name
• Tax code (codice fiscale)
• Residential and/or billing address
• Phone number
• Payment and installment data (transaction data is handled directly by the payment provider; I do not store full card numbers)
• Purchased package and session-related data

The site consists of static pages and does not use analytics or profiling tools (such as Google Analytics) nor tracking cookies. No user profiling is carried out.

To provide the coaching services I also process the data needed to: book sessions (via Calendly), handle payments (via PayPal and/or bank transfer), run online sessions (Google Meet or Zoom) and communicate with you (email and, if enabled, WhatsApp). Session recordings only take place with your specific and separate consent, are intended for your use and are kept only for as long as strictly necessary.

I do not collect sensitive personal information such as credit card numbers, ID documents, or health data.

4. How I Use Your Data

I use the collected data to:

• Respond to your information requests
• Provide you with the requested coaching services
• Send you communications or newsletters (only with your explicit consent)
• Improve my website and services
• Comply with legal obligations, if necessary

5. Legal Basis for Processing

I process your personal data based on:

• The performance of the coaching contract to which you are a party and pre-contractual measures taken at your request (Art. 6(1)(b) GDPR)
• The consent you provide when submitting the contact form or subscribing to the newsletter (Art. 6(1)(a) GDPR)
• Compliance with legal obligations, in particular tax and accounting ones (Art. 6(1)(c) GDPR)

6. Data Retention

I keep your personal contact data for a maximum period of 2 years from your last interaction with me, after which it is deleted or anonymized. Tax and accounting documents (invoices, receipts) are instead kept for 7 years, in compliance with Dutch tax law obligations.

7. Who I Share Your Data With

I do not sell, rent, or transfer your personal information to third parties. To deliver the service I rely on the following providers/processors, each for its specific purpose:

• Web3Forms — processing of the site's contact forms
• Calendly — booking and scheduling of sessions
• PayPal and/or banking institution — payment handling
• Google Meet / Zoom — delivery of online sessions
• WhatsApp (Meta) — only if included in the chosen package, for inter-session support
• Public authorities, if required by law

Some of these providers may process data outside the EU/EEA: in such cases the transfer takes place on the basis of appropriate safeguards (e.g. standard contractual clauses). All providers commit to protecting your data and using it only for the agreed purposes.

8. Your Rights

In accordance with GDPR, you have the right to:

• Access your personal data
• Request the correction of inaccurate data
• Request the deletion of your data ("right to be forgotten")
• Limit or object to the processing of your data
• Request the portability of your data
• Withdraw consent at any time

To exercise these rights, contact me using the form in the contact section of the site.

9. Cookies and Tracking Technologies

My site uses only essential technical cookies necessary for the proper functioning of the site. No profiling, marketing, or third-party analytics cookies are used; for this reason no cookie consent banner is required, as technical cookies do not require prior consent.

10. Data Security

I adopt appropriate technical and organizational measures to protect your personal data against unauthorized access, modification, disclosure, or destruction.

11. Links to External Sites

My site may contain links to external websites. I am not responsible for the privacy practices of such sites.

12. Data Transfer

Your data is processed mainly within the European Union. Some providers listed in point 7 (e.g. Calendly, PayPal, Google, Zoom, WhatsApp) may involve a transfer to third countries, in particular the United States: in such cases the transfer takes place on the basis of appropriate safeguards under Articles 44 et seq. of the GDPR (e.g. the European Commission's standard contractual clauses or applicable adequacy mechanisms).

13. Changes to This Policy

I reserve the right to modify this privacy policy at any time. Changes will be posted on this page.

14. Contact

For any questions regarding this policy or the processing of your personal data, you can contact me using the contact form on the site.

15. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority. As the controller is established in the Netherlands, the lead authority is the Autoriteit Persoonsgegevens (Netherlands). You may nonetheless lodge a complaint with the authority of the Member State of your habitual residence, place of work, or place of the alleged violation: in Italy this is the Garante per la Protezione dei Dati Personali.