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PRIVACY POLICY

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Virgili Studio

Last updated: 18 August 2026

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This Privacy Policy explains how personal data is collected and processed through the Virgili Studio website and in connection with enquiries, assessments, professional communications and potential or existing business engagements.

Personal data is processed in accordance with Regulation (EU) 2016/679 (“GDPR”) and applicable Italian and European data protection legislation.

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1. Data Controller

The Data Controller is:

Criterio S.r.l.
operating under the name Virgili Studio
Email: info@virgiliconsulting.com

Requests concerning personal data or the exercise of data protection rights may be submitted to the email address above.

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2. Personal Data We May Collect

Depending on how a visitor interacts with the website or with Virgili Studio, we may process:

  • identification data, such as name and surname;

  • contact details, such as email address and telephone number;

  • company, professional role and other business information;

  • information voluntarily submitted through contact forms, assessment tools, enquiries or direct communications;

  • information and responses submitted through professional or executive assessments made available on the website;

  • correspondence and information exchanged in connection with potential or existing professional engagements;

  • technical and security information generated through the operation of the website, such as IP address, browser and device information, technical logs and similar information necessary for website delivery, security and functionality.

Virgili Studio does not intentionally request special categories of personal data through this website.

Users should not submit sensitive or special-category personal information unless specifically requested and legally appropriate.

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3. How Personal Data Is Collected

Personal data may be collected:

  • directly from users when they contact Virgili Studio;

  • through website contact forms or assessment tools;

  • through email or other professional communications;

  • in connection with enquiries, prospective engagements or existing professional relationships;

  • automatically through technical mechanisms necessary for the operation, security and delivery of the website.

The website currently uses only strictly necessary technical cookies and technologies.

Further information is available in the Cookie Policy.

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4. Purposes and Legal Bases for Processing

Personal data may be processed for the purposes described below.

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Responding to enquiries and evaluating potential engagements

To respond to requests, assess potential assignments or collaborations, provide requested information and conduct communications prior to entering into a professional relationship.

Legal basis: Article 6(1)(b) GDPR where processing is necessary to take steps at the request of the data subject prior to entering into a contract and, where applicable, Article 6(1)(f) GDPR based on the legitimate interest in managing professional and business communications.

Assessments and professional evaluations

Where users voluntarily submit information through an assessment or diagnostic tool, such information may be processed to analyse the request, generate the relevant assessment output and determine whether further professional engagement may be appropriate.

Legal basis: Article 6(1)(b) GDPR where the assessment is requested by the user as part of pre-contractual activities and, where applicable, Article 6(1)(f) GDPR based on the legitimate interest in responding to professional enquiries and evaluating potential engagements.

Providing professional services and managing contractual relationships

To establish, perform, administer and manage professional, advisory, consulting or other agreed engagements.

Legal basis: Article 6(1)(b) GDPR.

Business and professional communications

To manage relationships and communications with clients, prospective clients, professional partners, suppliers, collaborators and institutional stakeholders.

Legal basis: Article 6(1)(b) GDPR where connected to contractual or pre-contractual activities and Article 6(1)(f) GDPR where processing is necessary for legitimate professional, organisational or relationship-management purposes.

Legal, accounting and regulatory obligations

To comply with applicable legal, regulatory, tax, accounting or administrative obligations.

Legal basis: Article 6(1)(c) GDPR.

Website operation, integrity and security

To operate, protect, maintain and secure the website, prevent misuse, detect technical problems and ensure the integrity and availability of the website and associated systems.

Legal basis: Article 6(1)(f) GDPR, based on the legitimate interest in maintaining the security, integrity and proper operation of the website and digital infrastructure.

Establishment, exercise or defence of legal claims

Where necessary, personal data may be retained or processed to protect the rights and legitimate interests of Criterio S.r.l. or to establish, exercise or defend legal claims.

Legal basis: Article 6(1)(f) GDPR and, where applicable, relevant legal obligations.

Consent-based activities

Where Virgili Studio introduces an optional activity for which consent is legally required, personal data will be processed only after obtaining the relevant consent.

Legal basis: Article 6(1)(a) GDPR.

Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal.

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5. Automated Decision-Making and Profiling

Virgili Studio does not use personal data collected through this website to make decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals.

Any automated or structured assessment functionality made available through the website is intended to support informational or professional evaluation and does not constitute automated decision-making producing legal or similarly significant effects.

The website does not currently use behavioural advertising or marketing profiling technologies.

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6. Data Retention

Personal data is retained only for as long as reasonably necessary for the purposes for which it was collected and in accordance with applicable legal obligations.

Retention periods are determined according to:

  • the nature and purpose of the processing;

  • the duration of any professional or contractual relationship;

  • the period reasonably required to manage enquiries, assessments and related correspondence;

  • applicable legal, tax, accounting and regulatory retention requirements;

  • the establishment, exercise or defence of legal claims;

  • technical and security requirements relating to website operation.

Where an enquiry does not result in a professional engagement, the relevant information will not be retained longer than reasonably necessary for managing and documenting that enquiry, unless a longer period is justified by applicable law or legitimate interests.

When personal data is no longer required for the relevant purpose, it will be deleted, anonymised or otherwise securely disposed of, subject to applicable legal obligations.

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7. Recipients and Service Providers

Personal data may be disclosed, where necessary and proportionate, to:

  • website hosting, infrastructure and technology providers;

  • IT, cloud and cybersecurity service providers;

  • communications and email service providers;

  • professional advisers, including legal, accounting and tax advisers;

  • suppliers, contractors or processors supporting professional operations;

  • competent courts, regulators, public authorities or law enforcement bodies where disclosure is required or permitted by law.

This website is built and operated using Wix infrastructure. Wix and its authorised service providers may process limited personal and technical data where necessary to provide hosting, infrastructure, security and website functionality.

Where third parties process personal data on behalf of Criterio S.r.l., appropriate data-processing arrangements are applied where required by law.

Criterio S.r.l. does not sell personal data collected through the Virgili Studio website.

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8. International Data Transfers

Some technology, infrastructure or professional service providers may process or store personal data outside the European Economic Area.

Where personal data is transferred outside the EEA, appropriate safeguards will be used as required by applicable data protection legislation.

Depending on the circumstances, these safeguards may include:

  • a European Commission adequacy decision;

  • Standard Contractual Clauses approved by the European Commission;

  • supplementary safeguards where required; or

  • another lawful transfer mechanism recognised under the GDPR.

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9. Security

Criterio S.r.l. applies appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data.

Measures are selected and reviewed having regard to the nature of the processing, the technology used and the risks associated with the processing.

No method of electronic transmission or storage can guarantee absolute security, but reasonable measures are maintained to reduce identified risks.

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10. Data Subject Rights

Subject to the conditions and limitations established by applicable data protection law, individuals may have the right to:

  • obtain confirmation as to whether their personal data is being processed and obtain access to it;

  • request rectification of inaccurate or incomplete personal data;

  • request erasure of personal data;

  • request restriction of processing;

  • object to processing based on legitimate interests;

  • receive personal data in a structured, commonly used and machine-readable format where the right to data portability applies;

  • withdraw consent at any time where processing is based on consent;

  • lodge a complaint with a competent data protection supervisory authority.

Where processing is based on legitimate interests, individuals may object to such processing on grounds relating to their particular situation, subject to the conditions provided by applicable law.

Requests concerning personal data may be sent to:

info@virgiliconsulting.com

Criterio S.r.l. will respond to requests in accordance with the conditions and time limits established by applicable data protection legislation.

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11. Cookies and Similar Technologies

The website currently uses only strictly necessary technical cookies and technologies required for its operation, security and delivery.

These technologies are necessary for the website to function and are not used to create behavioural profiles or deliver personalised advertising.

Further information is available in the Cookie Policy.

If analytics, marketing, profiling or other non-essential technologies requiring consent are introduced in the future, the website's privacy documentation and consent mechanism will be updated before those technologies are activated where prior consent is required.

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12. No Sale of Personal Data

Criterio S.r.l. does not sell or rent personal data obtained through the Virgili Studio website.

Personal data is disclosed to third parties only where necessary for the purposes described in this Privacy Policy, where required by law or where another valid legal basis applies.

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13. Third-Party Websites and Services

The website may contain links to independent third-party websites, platforms or services.

Those third parties operate according to their own privacy practices and policies.

Criterio S.r.l. is not responsible for the privacy practices, security or content of independent third-party websites or services.

Users are encouraged to review the relevant privacy information before providing personal data to third-party services.

 

14. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time to reflect:

  • changes in applicable legislation or regulatory guidance;

  • changes to the website or its functionality;

  • changes to the technologies or service providers used;

  • changes to the processing activities carried out by Criterio S.r.l.

The current version will always be made available on this website.

The date shown at the beginning of this Privacy Policy indicates when it was last updated.

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15. Contact

Privacy enquiries and data protection requests:
info@virgiliconsulting.com

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