Table of Contents
CONSTRVCTOR — PRIVACY NOTICE
Information pursuant to arts. 13 and 14 of Regulation (EU) 2016/679 (GDPR) and D.Lgs. 196/2003 as amended by D.Lgs. 101/2018
Version 2.0 · Effective 31/08/2026
1. DATA CONTROLLER
Constrvctor by Mariia Gudova, libero professionista P.IVA 02500970971 Registered address: Piazza dell’Ospedale,8, 59100 Prato PO, Italy Email: hello@constrvctor.com
We have not appointed a Data Protection Officer, as we are not required to under art. 37 GDPR. All privacy enquiries go to the address above.
2. WHAT WE COLLECT
You give us: name, business name, email, telephone/WhatsApp number, business address, delivery address, VAT number, business registration details, website and social media links, and the content of your enquiries, briefs and correspondence.
Collected automatically: IP address, device and browser information, pages viewed, referring source, and cookie identifiers (see section 8).
From third parties: publicly available business information, and information from Suppliers relating to your orders.
We do not knowingly collect special categories of data (art. 9 GDPR). Please do not send us any.
We do not collect or store payment card or bank credentials. Payments for fabrics are made by you directly to Suppliers. Payments to us are made by bank transfer; we see only what appears on the bank statement.
3. PURPOSES AND LEGAL BASES
|
Purpose |
Legal basis |
Retention |
|---|---|---|
|
Responding to enquiries and preparing quotations |
Pre-contractual steps — art. 6(1)(b) |
24 months from last contact |
|
Providing sourcing services and coordinating orders |
Contract — art. 6(1)(b) |
Duration of relationship + 10 years |
|
Passing your details to Suppliers to place and fulfil orders |
Contract — art. 6(1)(b) |
Duration of relationship + 10 years |
|
Invoicing, accounting and tax |
Legal obligation — art. 6(1)(c); art. 2220 Italian Civil Code; D.P.R. 600/1973 |
10 years from the end of the tax year |
|
Newsletter and marketing emails |
Consent — art. 6(1)(a) |
Until withdrawal, or 24 months of inactivity |
|
Fraud prevention, credit and sanctions screening |
Legitimate interest — art. 6(1)(f) |
Duration of relationship + 5 years |
|
Website analytics and performance |
Consent — art. 6(1)(a) via cookie banner |
See section 8 |
|
Establishing, exercising or defending legal claims |
Legitimate interest — art. 6(1)(f) |
Until the limitation period expires |
[IMPORTANT CORRECTION] Your current terms state that order history is kept for 2 years for legal and tax reasons. That is wrong under Italian law. Art. 2220 of the Civil Code and Italian tax rules require accounting records and invoices to be kept for 10 years. Publishing a 2-year retention period commits you to something you cannot lawfully do. This is corrected above.
4. IS PROVISION MANDATORY?
Providing the data needed to conclude and perform a contract is necessary: without it we cannot provide the Services. Providing data for marketing is entirely optional and refusal has no consequence for the Services.
5. WHO WE SHARE DATA WITH
- Suppliers, mills and warehouses in Italy — to quote, place and fulfil your orders.
- Carriers, freight forwarders and customs brokers — where you ask us to coordinate logistics.
- Our accountant and tax adviser in Italy.
- IT and business service providers, acting as processors under art. 28 GDPR: website hosting and WordPress/WooCommerce infrastructure; email; Mailchimp (newsletter); Google (Analytics, Tag Manager, Forms, Site Kit); Meta/Instagram (social plugin and advertising); messaging platforms (WhatsApp, Telegram).
- Professional advisers, banks and public authorities, where legally required.
We do not sell personal data and we do not share it for third-party marketing.
6. TRANSFERS OUTSIDE THE EEA
Some providers (Mailchimp/Intuit, Google, Meta, WhatsApp) process data in the United States or elsewhere outside the EEA. Such transfers are made under the EU–US Data Privacy Framework adequacy decision where the provider is certified, or otherwise under the European Commission’s Standard Contractual Clauses together with supplementary measures. You may request a copy of the safeguards at hello@constrvctor.com.
Where you ask us to arrange shipping to a non-EEA destination, your delivery details are transmitted to carriers and customs authorities in that country as necessary to perform the contract (art. 49(1)(b) GDPR).
7. SECURITY
We apply measures appropriate to the risk under art. 32 GDPR: TLS/SSL encryption on our website, access controls and strong authentication on business accounts, two-factor authentication where available, limited access on a need-to-know basis, and reputable providers for hosting and payments. No system is perfectly secure; we do not guarantee absolute security.
8. COOKIES
Our website uses technical cookies, and — with your consent — preference, statistical and marketing cookies, including Google Analytics/Tag Manager and Meta tools. Technical cookies are strictly necessary and require no consent. All others are set only after you accept them via the cookie banner, and you may change or withdraw your choices at any time through the “Manage cookies and consent” control on any page.
9. YOUR RIGHTS
Under arts. 15–22 GDPR you may: access your data; rectify inaccurate data; request erasure; restrict processing; receive your data in portable form; object to processing based on legitimate interest; and withdraw consent at any time, without affecting the lawfulness of prior processing.
Marketing: unsubscribe using the link in any email, or write to us. This takes effect immediately.
To exercise any right, email hello@constrvctor.com. We respond within one month, extendable by two further months for complex requests. We may ask for proof of identity. Exercising these rights is free unless a request is manifestly unfounded or excessive.
Right to complain: you may lodge a complaint with the Italian supervisory authority — Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, garante@gpdp.it, www.garanteprivacy.it — or with the authority in your country of residence or workplace.
10. AUTOMATED DECISION-MAKING
We do not carry out automated decision-making or profiling producing legal or similarly significant effects.
11. CHANGES
We may update this Notice. The current version is always published at https://constrvctor.com/privacy-policy-customer-terms/ with its effective date. Material changes affecting your rights will be notified by email.
Constrvctor by Mariia Gudova · P.IVA 02500970971 · hello@constrvctor.com