Draft to review This text is a draft prepared for the controller (and, if needed, a legal adviser) to check before final publication. The highlighted parts in square brackets still need to be completed or confirmed.

Privacy notice

Last updated: 17 October 2026 (draft)

Data controller

The data controller is Adem — Upmarkpro, reachable at [email protected]. [Address and VAT number: to be added once the business is registered]

What data we collect and how

Contact form. The form does not send data to an Upmarkpro server. When you press “Send via WhatsApp”, the site prepares a message with what you entered (name, email, business name, service of interest and message) and opens WhatsApp: the data reaches us only if you tap Send in the app.

Direct messages. If you write to or call us on WhatsApp, by email or by phone, we process your number or address and the content of the conversation.

The “missed calls” calculator. The values you enter stay in your browser. If you choose to send the audit on WhatsApp, it counts as a direct message.

Browsing data. The site’s hosting provider (Cloudflare) may log technical data such as IP address, date and time and the page requested, to run the service and protect it from abuse.

The site uses no profiling cookies or analytics tools: see the Cookies page.

Why we use it and on what basis

To answer your requests and prepare a proposal if you want one: pre-contractual steps you asked for (Art. 6(1)(b) GDPR).
To get back to you after your request: your consent, given with the checkbox on the form (Art. 6(1)(a) GDPR), which you can withdraw at any time.
Security and technical operation of the site: legitimate interest (Art. 6(1)(f) GDPR).
Legal obligations if we end up working together, such as invoicing (Art. 6(1)(c) GDPR).

Providing your data is optional, but without the essential details we cannot answer your request. We do no profiling and no automated decision-making.

Who receives the data

The technical providers needed to run the service: Cloudflare (website hosting), Meta Platforms / WhatsApp (messaging, which has its own privacy notice) and [email provider: to be confirmed]. We do not sell or pass your data to third parties for marketing.

Transfers outside the European Economic Area

Some providers may process data outside the EEA. In that case they rely on the safeguards provided by the GDPR, such as standard contractual clauses or adequacy decisions (for example the EU-US Data Privacy Framework). [to be verified with the chosen providers]

How long we keep it

Request data is kept for as long as needed to answer and, if no working relationship follows, no longer than [12 months: period to be confirmed]. If we work together, we keep it for the duration of the relationship and for the periods required by law (for example accounting records). Technical logs follow the hosting provider’s policies.

Your rights

You can ask at any time for access to your data, correction, erasure, restriction of processing and portability, and you can object to the processing. You can also withdraw your consent, without affecting processing already carried out.

To exercise your rights write to [email protected]. If you believe the processing breaches the rules, you can complain to the Italian Garante per la protezione dei dati personali or to the supervisory authority of your country.

Cookies

The site sets no cookies. More details on the Cookies page.