This Privacy Policy explains how your personal data is collected, used, and protected when you interact with the davidemit.it website, in both its Italian and English versions, and with the davidemit.it/dal-mio-tavolo blog.
Data Controller
The Data Controller is Davide Mitscheunig. For any privacy-related request you can write to privacy@davidemit.it.
Data collected and purposes
The website collects personal data in three distinct situations: when you browse the pages, when you submit one of the forms, and when you click on links that take you outside the website.
Website browsing
When you browse the website, two tools are activated that involve the processing of data.
The first is the Meta Pixel, the tracking tool provided by Meta Platforms (Facebook and Instagram). The Pixel collects information about your visit to the website — pages viewed, events, IP address, browser identifiers — and transmits it to Meta to measure the effectiveness of advertising campaigns and for marketing activities. The Pixel is only activated after you have given your consent through the cookie banner: the legal basis for the processing is your consent under Article 6(1)(a) of the GDPR. The particular nature of this processing is described in the "Meta Pixel and Joint Controllership" section below.
The second is Google Fonts. The website pages load typographic fonts (Geist and Geist Mono) from Google's servers, and this involves the transmission of your IP address to Google when a page is loaded. Google Fonts does not set cookies on your device. The legal basis is the legitimate interest of the Controller in providing a reading experience consistent with the website's identity (Article 6(1)(f) of the GDPR).
Contact form
The website includes a form that allows you to leave your contact details to receive content or to be contacted again. The data collected is: name, surname, email address, language of the page from which you submitted the request, confirmation of acceptance of this Privacy Policy, timestamp of acceptance, and user agent of your browser. The data is transmitted via Google Apps Script and stored in a private Google Sheet managed by the Controller. The legal basis is your consent given at the time of submission (Article 6(1)(a) of the GDPR) and — for any subsequent contact arising from it — the execution of pre-contractual measures at your request (Article 6(1)(b) of the GDPR).
Contact request form
The website also includes a contact request form dedicated to those who wish to propose a professional collaboration. The data collected is: name, email address, company, role, strategic challenge, area of interest, time horizon, and confirmation with timestamp of acceptance of this Privacy Policy. The data is transmitted via Google Apps Script and stored in a private Google Sheet managed by the Controller. The legal basis is the execution of pre-contractual measures at your request (Article 6(1)(b) of the GDPR), as you are requesting a professional evaluation that could lead to a working relationship.
Links to external platforms
The website contains links that redirect you to external platforms. The newsletter link points to the Controller's Substack channel, where subscription and subscriber management take place directly on the Substack platform: please refer to Substack's privacy policy at substack.com. The link to download the book leads to the product page on Amazon, where the purchase is managed directly by Amazon: please refer to Amazon's privacy policy at amazon.it. Once you click these links and leave the davidemit.it website, the Controller no longer has any control over or visibility into your data: the privacy policies of the respective platforms apply in full.
Meta Pixel and joint controllership with Meta Platforms
The Meta Pixel requires a dedicated section because the data processing it produces has a particular legal structure.
When the Pixel is activated on the website, Meta Platforms Ireland Ltd (registered office at 4 Grand Canal Square, Dublin 2, Ireland) receives the data relating to your browsing and processes it. Under Article 26 of the GDPR, and consistent with the judgment of the Court of Justice of the European Union C-210/16 (Wirtschaftsakademie), the Controller of this website and Meta Platforms Ireland Ltd act as joint controllers of the processing, limited to the activities of the Pixel. Meta has published a joint controllership agreement ("Controller Addendum") that governs the respective responsibilities, available at facebook.com/legal/controller_addendum. In short: the Controller of this website determines the purposes of the Pixel — measurement and marketing — and obtains your consent; Meta determines the technical means of processing, guarantees the exercise of your rights with respect to data processed on its systems, and manages the security of the infrastructure.
The data collected by the Pixel is transferred from Meta Platforms Ireland Ltd to Meta Platforms, Inc. in the United States, within the Meta group. This transfer is protected by the EU-US Data Privacy Framework 2023, to which Meta Platforms, Inc. has adhered, and — in the alternative — by the Standard Contractual Clauses adopted by the European Commission under Article 46 of the GDPR. The current status of Meta's adherence to the DPF can be verified on the public register at dataprivacyframework.gov.
Cookies and tracking technologies
The website uses technical, preference, and marketing cookies. The Meta Pixel installs marketing cookies (_fbp, fr, tr). Technical cookies are necessary for the operation of the website and are activated by default. Marketing cookies are only activated after your express consent given through the cookie banner. You can manage your preferences at any time through the "Manage cookies" link available in the footer of the website. For the full details of the cookies installed, their duration and their purposes, please consult the Cookie Policy.
Recipients of the data
The data collected on the website is accessible to the Controller and to the following parties, each with a specific role.
Google LLC and Google Ireland Ltd act as data processors under Article 28 of the GDPR for the storage of form data (Google Apps Script and Google Sheet) and for the loading of fonts (Google Fonts).
Meta Platforms Ireland Ltd and Meta Platforms, Inc. act as joint controllers under Article 26 of the GDPR, limited to the activity of the Pixel, as explained above.
The website does not share your data with any other third parties for commercial purposes.
Transfers outside the EU
Some of the processing activities described involve a transfer of your data outside the European Union, in particular to the United States. This concerns Google LLC, as part of the group of which Google Ireland Ltd is a member, and Meta Platforms, Inc., as part of the group of which Meta Platforms Ireland Ltd is a member. In both cases the transfer is protected by the EU-US Data Privacy Framework 2023, to which both companies have adhered, and — in the alternative — by the Standard Contractual Clauses adopted by the European Commission under Article 46 of the GDPR.
Data retention
Data collected through the contact form is retained for the time necessary to give you a reply or to send you the requested content. If there is no follow-up, it is deleted within 36 months.
Data collected through the contact request form is retained for the time necessary for the evaluation and, in the event of a professional engagement, for the duration of the relationship and for the time legally required after its conclusion. If there is no follow-up, it is deleted within 36 months.
Data collected by the Meta Pixel is retained by Meta according to its own retention policies, which the Controller does not control.
Security measures
Appropriate technical and organisational measures are in place to protect your data from unauthorised access, loss, disclosure or alteration. These include: restriction of access to the Google Sheet to accounts authorised by the Controller only, encrypted transmission of data (HTTPS), and periodic review of the third parties involved.
Your rights
You have the right to access your personal data, to rectify it, to erase it, to restrict its processing, to object to the processing, and to obtain the portability of the data. You also have the right to withdraw at any time the consent you have given, without this affecting the lawfulness of any processing carried out before the withdrawal.
To exercise these rights you can write to privacy@davidemit.it. For rights relating to data processed through the Pixel — access, deletion, portability with respect to data residing in Meta's systems — you can contact Meta directly through the procedures indicated in its Privacy Centre.
You also have the right to lodge a complaint with the competent supervisory authority. In Italy, the authority is the Garante per la Protezione dei Dati Personali (garanteprivacy.it).
Updates
This Privacy Policy may be updated if the tools used on the website or the applicable laws change. Material changes are communicated on the website prominently and, where required by law, involve a new request for consent. The version currently in force is v2.0 of June 4, 2026 and supersedes all previous versions.
Contact
For any questions relating to this Privacy Policy or to the exercise of your rights, please write to privacy@davidemit.it.
