Privacy Policy

1. Data controller

The data controller is Gianluca D'Avino, as principal of GD International Consulting ("GD IC"), with operating offices in Milan (Italy) and Dubai (UAE).

Contact: gianluca.davino@gdiconsulting.it

2. Data processed

The gdiconsulting.it website is an informational showcase site. We do not directly collect or store any personal data from visitors via forms, registrations or profiling.

Only the following data is processed:

• Browsing data (server logs) — The hosting server (Aruba S.p.A., Italy) automatically records technical logs containing IP addresses, browser, OS, pages visited and timestamps. This data is used exclusively for IT security, technical diagnostics and anonymous aggregate statistics. It is retained for a maximum of 30 days.
• Contact data provided voluntarily — If you email us or use the Calendly link, we store the data you communicate (name, email, request content) for the time necessary to handle the conversation and/or the resulting professional relationship.
• Data collected through LinkedIn Lead Gen campaigns — When you fill out a contact form associated with one of our LinkedIn ads, we collect the data you provide (first name, last name, work email, job title, company) for the purpose of sending you the requested resource and contacting you for any commercial follow-up. The legal basis is your explicit consent (Art. 6(1)(a) GDPR) and pre-contractual measures at your request (Art. 6(1)(b) GDPR). Data is retained for the time necessary to manage the relationship and in any case no longer than 24 months from the last contact, unless you request deletion earlier.

3. Legal basis and purpose

• Server logs: legitimate interest of the controller in the security and technical functioning of the site (Art. 6(1)(f) GDPR).
• Email/contact data: pre-contractual measures at the request of the data subject (Art. 6(1)(b) GDPR) and/or explicit consent (Art. 6(1)(a) GDPR).

4. Third-party services

The site uses the following external services as external links only, not as embedded components:

• Calendly (Calendly LLC, USA) — used for call scheduling. When you click the Calendly link, you are redirected to calendly.com, where the Calendly Privacy Policy applies.
• LinkedIn (LinkedIn Ireland Unlimited Company, Ireland) — used for links to profile and articles. When you click, you are redirected to linkedin.com.

The site does not integrate widgets, tracking pixels, embeds or third-party scripts that would set cookies or transfer data outside the European Union without your consent.

5. Cookies

The site does not use first-party or third-party cookies for analytics, profiling or marketing. See the Cookie Policy for details.

6. Processing and storage

Data is processed using electronic tools, with appropriate security measures to prevent unauthorized access, loss or alteration. Data is stored on Aruba S.p.A. servers located in Italy (European Union).

7. Non-EU transfers

No visitor data is transferred outside the European Union for the operation of the site. Any interactions with external services (Calendly, LinkedIn) only happen after your voluntary click.

8. Data subject rights

You have the right, at any time, to:

• Access your personal data (Art. 15 GDPR)
• Rectify it (Art. 16 GDPR)
• Erase it (Art. 17 GDPR)
• Restrict processing (Art. 18 GDPR)
• Object to processing (Art. 21 GDPR)
• Data portability (Art. 20 GDPR)
• Withdraw consent where required (Art. 7 GDPR)

To exercise these rights, write to gianluca.davino@gdiconsulting.it. You also have the right to lodge a complaint with the Italian Data Protection Authority.

9. Changes

This Privacy Policy may be updated periodically. The date of last update is shown at the top of the document.