Privacy

Privacy and Cookie Policy

pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) and Italian Legislative Decree 196/2003, as amended by Legislative Decree 101/2018

Last updated: 9 November 2026

1. Data Controller

The Data Controller is Ditta Pasolini Dall'Onda Violante, Vicolo dei Catinari 9, 00186 Rome (RM), Italy. VAT no. 16820361000.
Phone: +39 06 68135740. Email: [email protected]

The Controller has not appointed a Data Protection Officer (DPO), as it is not required to do so.

2. Data we process

Browsing data. When you visit the website, our IT systems collect certain technical data: IP address, browser type, operating system, date and time of access, pages visited and referring site. This data is used to run the website, keep it secure and produce anonymous statistics.
Data you provide voluntarily. This is the data you give us when you email us, call us or contact us via Facebook: first and last name, contact details, property preferences and any other information included in your message.
Client and counterparty data. This concerns people who entrust us with a brokerage, sale or rental assignment, or who are interested in a property. It includes personal details, identity document details, tax data, property data and the information needed to negotiate and conclude the contract.
Cookies. For cookies, please see the Cookie Policy below.

We do not request special categories of personal data (Art. 9 GDPR). Please do not include such data in your communications with us.

3. Purposes and legal bases

Purpose	Legal basis
Responding to enquiries about properties and services	Pre-contractual measures requested by the data subject (Art. 6(1)(b))
Managing brokerage assignments, negotiations, viewings and sale or rental contracts	Performance of a contract or pre-contractual measures (Art. 6(1)(b))
Complying with legal obligations: tax, accounting and anti-money-laundering (Legislative Decree 231/2007), as well as the rules on real estate brokerage (Law 39/1989)	Legal obligation (Art. 6(1)(c))
Ensuring the operation and security of the website and protecting the Controller's rights, including in legal proceedings	Legitimate interest (Art. 6(1)(f))
Sending, with your consent, promotional communications and new property alerts by email, phone, SMS or post	Consent (Art. 6(1)(a)), which may be withdrawn at any time

Your data is not sold or passed on to third parties for their own marketing purposes. No decisions are made based solely on automated processing, including profiling.

4. Whether providing data is mandatory

For pre-contractual, contractual and legal purposes, providing your data is necessary: without it we cannot answer your enquiries or carry out the assignment. For marketing purposes, providing your data is optional, and refusing has no effect on the services you request.

5. How data is processed

Data is processed electronically and on paper by authorised and trained staff. We apply appropriate technical and organisational measures, as required by Art. 32 GDPR, to prevent loss, unlawful use or unauthorised access to the data.

6. Recipients

Your data may be disclosed to:

the agency's associates and agents;
consultants (accountants, lawyers, technical experts);
notaries, banks and the other parties to the negotiation, to the extent necessary to complete the transaction;
IT service providers, including website maintenance (ITALA Tecnologia Informatica S.r.l.), hosting and CDN (Cloudflare) and real estate management software (Realgest);
public authorities, where required by law.

Providers that process data on the Controller's behalf are appointed as Data Processors under Art. 28 GDPR. An up-to-date list is available from the Controller on request.

7. Transfers outside the EU

Some providers, such as Google and Cloudflare, may process data in the United States. In such cases, transfers take place on the basis of the EU-U.S. adequacy decision (EU-U.S. Data Privacy Framework) or the Standard Contractual Clauses approved by the European Commission (Art. 46 GDPR).

8. Retention

Enquiries not followed up: 24 months from the last contact.
Contractual, accounting and tax data: 10 years (Art. 2220 of the Italian Civil Code).
Data collected for anti-money-laundering due diligence: 10 years from the end of the relationship (Legislative Decree 231/2007).
Marketing data: until consent is withdrawn, and in any case no longer than 24 months from the last contact.
Browsing data: for the time technically necessary, unless needed to investigate offences.

9. Your rights

You may at any time request access to your data, its rectification or erasure, restriction of processing and data portability. You also have the right to object to processing and to withdraw any consent given, without affecting the lawfulness of processing carried out before withdrawal (Arts. 15-22 GDPR).

Requests should be sent to [email protected] or by post to the Controller's address. You always have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it).

What cookies are

Cookies are small text files that a website sends to the user's browser, where they are stored and then read again on later visits. They may be “session” cookies, deleted when the browser is closed, or “persistent” cookies, kept until they expire.

Cookies used on this website

Technical cookies. These are needed for the website to work, for example to manage the session, language and security via Cloudflare. They do not require consent.
Analytics cookies: Google Analytics (Google Ireland Limited). These produce aggregate statistics on website use, with the IP address minimised. They are set only with the user's consent. Google's privacy policy: policies.google.com/privacy
Third-party cookies: Google Maps. The Contact page shows a Google map, which may set Google cookies. Privacy policy: policies.google.com/privacy

The link to our Facebook page is a plain link: it does not load any Facebook plugin or cookie unless the user opens it.

Managing consent

On your first visit, a banner lets you accept or reject non-technical cookies. You can change your choice at any time via the “Cookie preferences” link at the bottom of the page. Alternatively, cookies can be blocked or deleted in your browser settings (Chrome, Firefox, Safari, Edge). Disabling technical cookies may affect some website functions.