Privacy Policy
How we handle personal data when you visit witted.digital or write to us, under Regulation (EU) 2016/679 (GDPR) and the Italian Data Protection Code (Legislative Decree 196/2003).
Who is responsible
The data controller is A5 S.R.L., which runs the Witted Digital brand.
VAT IT-02594460228 · Email: build@witted.digital
We have not appointed a Data Protection Officer, as the law does not require one for our activity. Write to the email address above for any question about your data.
What data we process
- When you write to us: your name, email address, company and role if you give them, and the content of your message and any attachments.
- When you visit the site: the server that hosts the site records technical data in its logs: IP address, date and time of the request, page requested, browser and operating system. We do not use these data to identify you.
The site has no analytics, no advertising, no tracking pixels and no social media plug-ins, and it does not profile visitors. See Cookie Settings.
Why we process it, and on what legal basis
| Purpose | Legal basis |
|---|---|
| Answering your message and preparing a proposal or estimate | Steps taken at your request before a contract, Art. 6(1)(b) GDPR |
| Running and securing the site, and preventing abuse | Our legitimate interest in a working, secure site, Art. 6(1)(f) GDPR |
| Keeping accounting and tax records if a contract follows | Legal obligation, Art. 6(1)(c) GDPR |
| Establishing, exercising or defending legal claims | Our legitimate interest, Art. 6(1)(f) GDPR |
Giving us your data is up to you. Without an email address we cannot reply to you. We make no decisions about you based solely on automated processing.
How long we keep it
- Correspondence: up to 24 months after our last exchange, unless a contract follows.
- Contract and accounting records: 10 years, as Italian law requires (Art. 2220 of the Civil Code).
- Server logs: up to 30 days, longer only when needed to investigate a security incident.
Who can see it
Only people at A5 S.R.L. who need it for the purposes above, bound by confidentiality. We also use service providers for hosting and email, who process data on our behalf under a data processing agreement (Art. 28 GDPR). We do not sell or rent personal data.
Transfers outside the European Economic Area
We choose providers that keep data in the European Economic Area. If a provider transfers data outside it, the transfer relies on an adequacy decision of the European Commission or on the Standard Contractual Clauses.
Your rights
You can ask us at any time to:
- access your data and get a copy of it (Art. 15)
- correct it (Art. 16) or delete it (Art. 17)
- restrict its processing (Art. 18)
- receive it in a portable format (Art. 20)
- object to processing based on our legitimate interest (Art. 21)
Write to build@witted.digital. We reply within one month. You also have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali, or with the authority of the EU country where you live or work.
Changes to this policy
We will update this page if the way we handle data changes. The date below shows the latest version.
Last updated: 24 October 2026