Privacy notice
Last updated: October 2026
This notice is provided 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, to visitors of elemarholding.com.
1. Data controller
The data controller is Elemar Holding S.r.l., with registered office at Galleria San Babila 4/B, 20122 Milan, Italy, tax code and VAT no. 14454170961, certified e-mail elemar.holding@pec.it, e-mail info@elemarholding.com. The controller has not appointed a Data Protection Officer, as the conditions of Article 37 GDPR do not apply.
2. Categories of data processed
Browsing data. The IT systems and software procedures used to operate this website acquire, during their normal operation, certain data whose transmission is implicit in the use of Internet communication protocols: IP addresses, domain names of the devices used, URI addresses of the requested resources, time of the request, method used, size of the file obtained, numerical code indicating the status of the response and other parameters relating to the operating system and IT environment. This data is necessary to use the web services and is processed solely to ensure the proper functioning and security of the website; it is retained for the time strictly necessary, save for any need to investigate offences by the judicial authorities.
Data provided voluntarily by the user. The optional, explicit and voluntary sending of messages to the contact addresses shown on the website entails the acquisition of the sender's address and of any other personal data included in the message, which are necessary to reply to the request.
The website has no registration forms, newsletters or reserved areas and carries out no profiling.
3. Purposes and legal basis
Browsing data is processed to allow use of the website and to ensure its security, on the basis of the controller's legitimate interest (Art. 6(1)(f) GDPR). Data provided voluntarily is processed to respond to the data subject's requests (Art. 6(1)(b) GDPR) and, where necessary, to comply with legal obligations (Art. 6(1)(c) GDPR).
4. Recipients
Data may be processed by the controller's staff authorised under Article 29 GDPR and by third parties acting as processors under Article 28 GDPR, in particular the hosting and e-mail provider (Register S.p.A., with servers located in the European Union). Data is not disseminated.
The website's photographs are served by Unsplash (Unsplash Inc., Montréal, Canada): requesting the images entails transmitting the visitor's IP address to the provider, as described in Unsplash's privacy policy. Canada is covered by an adequacy decision of the European Commission. The website does not load fonts, scripts or other content from third-party servers.
5. Transfers outside the EU
Except as described in section 4, data is not transferred outside the European Union.
6. Retention period
Browsing data is retained for the time technically necessary and in any event no longer than permitted by applicable law. Data contained in messages received is retained for the time necessary to reply and, thereafter, for the period required by legal obligations or to protect the controller's rights.
7. Rights of the data subject
Data subjects may at any time exercise the rights set out in Articles 15–22 GDPR: access, rectification, erasure, restriction, portability and objection. Requests may be sent to info@elemarholding.com or to the certified e-mail address elemar.holding@pec.it. Data subjects also have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
8. Nature of the provision of data
The provision of browsing data is implicit in the use of the website. The provision of data in messages sent to the controller is optional; failure to provide it may make it impossible to respond to the request.
9. Changes
The controller reserves the right to update this notice. The current version is the one published on this page, with the date of last update.