PRIVACY POLICY

Information pursuant to Articles 12 and 13 of Regulation (EU) 2016/679 (GDPR) and Italian Legislative Decree 196/2003, as amended by Legislative Decree 101/2018

Last updated: 19 September 2026

1. Data Controller

The Data Controller for personal data collected through the website https://wingtsundamante.com is Master SiFu Luca Damante, with registered office at Via Benedetto Croce, 10 – 93012 Gela (CL), Italy.

Contact: info@wingtsundamante.com.

2. Scope of this Privacy Policy

This Privacy Policy describes how personal data relating to users who visit and use wingtsundamante.com and its online services are processed.

It covers data collected during browsing, data voluntarily provided by users through contact forms or e-mail and, where applicable, data connected with the use of cookies or other tracking technologies.

3. Categories of Personal Data Processed

a) Browsing data. The IT systems and software procedures used to operate the website may, during their normal operation, acquire data whose transmission is inherent in the use of Internet communication protocols, such as IP addresses, technical logs, the date and time of requests, browser and device type, requested pages and similar information. These data are used to enable the operation and security of the website, obtain aggregate statistical information, and identify anomalies or abuse.

b) Data voluntarily provided by the user. Voluntarily sending messages through contact forms or by e-mail results in the acquisition of the data necessary to respond to the request. Depending on the form used, the following data may be requested, for example: name, e-mail address, telephone number, city, school or organization, website or social media profile, area of interest and message content.

c) Comments and interactions. Where the website enables comments or other forms of public interaction, the data entered by the user and the technical data necessary to manage the service and prevent spam or abuse may be processed.

d) Cookies and similar technologies. The website uses technical cookies and may use, subject to consent where required, third-party cookies or tools for additional features, embedded content, analytics or other services. Detailed information, purposes, cookie categories and methods for managing preferences are provided in the Cookie Policy and in the consent management system available on the website.

4. Purposes of Processing and Legal Bases

Website operation, security and maintenance. Technical data may be processed to ensure the delivery, security, stability and proper maintenance of the website, on the basis of the Controller’s legitimate interest in protecting its systems and online services (Article 6(1)(f) GDPR).

Handling contact requests and collaborations. Data provided through forms, e-mail or other channels are processed to respond to requests, provide information about WTDS courses, seminars, activities and professional collaborations, and to take any pre-contractual steps requested by the data subject (Article 6(1)(b) GDPR).

Compliance with legal obligations. Data may be processed where necessary to comply with obligations arising from applicable European Union or national law (Article 6(1)(c) GDPR).

Promotional communications. Any promotional or informational communications not strictly connected with a user’s request will be sent only where an appropriate legal basis exists and, where necessary, with the data subject’s prior consent (Article 6(1)(a) GDPR). Consent may be withdrawn at any time.

Non-essential cookies and tracking technologies. The use of cookies or other tracking technologies that are not strictly necessary takes place, where required by law, on the basis of the user’s consent. Refusing consent does not prevent browsing those parts of the website that do not require such technologies.

5. Nature of Data Provision

Providing data through contact forms is voluntary. Fields marked as mandatory are necessary to handle the request; failure to provide them may make it impossible to respond or provide the requested service.

For processing based on consent, providing data is optional and consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal.

6. Processing Methods and Security Measures

Personal data are processed using electronic tools and, where necessary, paper-based tools, in accordance with the principles of lawfulness, fairness, transparency, data minimization and storage limitation.

Reasonable technical and organizational measures are adopted to reduce the risks of loss, unlawful or improper use, unauthorized access, disclosure, alteration or destruction of data.

7. Recipients and Parties That May Process the Data

Data may be processed by the Controller and by authorized persons acting under the Controller’s responsibility.

Where necessary for the operation of the website or the provision of services, data may also be processed by external providers carrying out technical or organizational activities, such as hosting, maintenance, e-mail services, IT support, anti-spam services, cookie management or other services strictly connected with the website. Where applicable, such parties act as processors pursuant to Article 28 GDPR or as independent controllers for processing activities falling within their own responsibilities.

Data may be disclosed to public authorities or other parties where required by law or necessary to protect rights in legal proceedings. Personal data are not sold to third parties.

8. Third-Party Content and Services

The website may embed content or services provided by third parties, such as maps, videos, social media content or other external tools. These services may involve the processing of personal data by the relevant providers in accordance with their own privacy policies.

Where activation of such services requires the user’s consent, the website uses the consent management system to prevent or restrict their activation until the user makes a choice.

9. Transfers of Data to Countries Outside the EEA

Some IT service providers or third-party content providers may process data in countries outside the European Economic Area (EEA). In such cases, transfers take place in accordance with Chapter V GDPR, on the basis of an adequacy decision by the European Commission or other appropriate safeguards provided by applicable law, where required.

10. Retention Period

Personal data are retained only for the time strictly necessary to achieve the purposes for which they were collected.

In particular, data relating to contact requests are retained for the time necessary to handle the request and any resulting relationship, and thereafter only for the period necessary to comply with legal obligations or protect possible rights. Technical and security data are retained for the periods necessary for the operation, security and management of the systems. Data processed on the basis of consent are retained until consent is withdrawn or until they are no longer necessary for the stated purpose.

Retention periods relating to cookies and other tracking technologies are indicated in the Cookie Policy or in the consent management panel.

11. Automated Decision-Making and Profiling

The Controller does not make decisions based solely on automated processing that produce legal effects concerning the data subject or similarly significantly affect the data subject within the meaning of Article 22 GDPR.

Any profiling or tracking activities for non-technical purposes, if introduced, will be carried out only in compliance with applicable law and, where required, with the user’s prior consent.

12. Children’s Data

The website is not intended to knowingly collect personal data from children. With regard to the direct offering of information society services based on consent, the age thresholds and rules provided by applicable Italian law apply. For children under 14 years of age, where processing is based on consent pursuant to Article 6(1)(a) GDPR, consent from the holder of parental responsibility is required.

13. Rights of the Data Subject

Where provided for by the GDPR, the data subject may exercise the rights set out in Articles 15-22, including the right to:

  • obtain confirmation as to whether personal data are being processed and access such data;
  • request rectification or updating of inaccurate or incomplete data;
  • request erasure of data in the cases provided by law;
  • request restriction of processing;
  • receive data in a structured format and transmit them to another controller, where the requirements for data portability are met;
  • object to processing in the cases provided by law;
  • withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

Requests may be sent to info@wingtsundamante.com.

14. Complaint to the Supervisory Authority

The data subject has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), in accordance with the procedures indicated on the Authority’s official website, or to contact the competent supervisory authority under the GDPR.

15. Cookie Policy

For detailed information about the cookies and other tracking technologies used by the website, their purposes and how to modify or withdraw preferences, please refer to the Cookie Policy and the consent management panel available on the website.

16. Changes to this Privacy Policy

This Privacy Policy may be amended or updated over time to reflect legal, technical or organizational changes. The updated version will be published on this page together with the date of the latest update.

Privacy contact: info@wingtsundamante.com