Privacy Policy

1. Data controller

TriesteVillas srl · Via Milano 5, 34132 Trieste (TS), Italia · C.F./P.IVA 01235580329 · Email richieste@triestevillas.com · PEC milou@pec.emailc.it

2. Data we process

Contact details you voluntarily provide through the forms (name, email, phone, any message and the property of interest) and technical browsing data (e.g. IP address, browser type) collected via technical cookies required for the site to work.

3. Purposes and legal basis

We process the data to respond to your requests and manage the relationship (pre-contractual measures and your consent) and to comply with legal obligations. Providing data is optional, but without contact details we cannot follow up on your request.

4. Processing and retention

Data is processed with electronic tools and appropriate security measures, and kept for as long as needed to handle the request and for subsequent legal obligations, after which it is deleted or anonymised.

5. Recipients and processors

Data may be handled by our authorised staff and by suppliers acting as data processors: the provider of the database of our management system (CRM), where the requests sent through the forms are recorded; Vercel, for hosting the site and the management system; an email provider for sending emails; the providers of the artificial intelligence tools used in the management system. Some historical archives of the group, being phased out, remain on Airtable. For calls to the agency's number, Twilio (the phone system) and ElevenLabs (the voice and transcript of the assistant that may answer the phone) are added, as explained in section 10. Data is not disseminated.

6. Non-EU transfers

Some suppliers may process data outside the European Union; where this happens, the transfer is based on an adequacy decision of the European Commission (for the United States, the EU-U.S. Data Privacy Framework, for suppliers certified under it) or on appropriate safeguards (e.g. the European Commission's standard contractual clauses).

7. Your rights

You may at any time exercise the rights of access, rectification, erasure, restriction, objection and portability, and withdraw consent, by writing to richieste@triestevillas.com. You also have the right to lodge a complaint with the Italian Data Protection Authority.

8. Cookies

The site uses technical cookies required for operation and, only with your consent, Google Analytics 4 statistics cookies (Google Ireland Ltd) to understand how the site is used. No statistics cookie is set until you choose: through Google's consent mode (Consent Mode v2), Google only receives technical signals without cookies and without persistent identifiers (for example that a page was opened, with the time and the type of browser), used for aggregate estimates that do not allow you to be recognised. You can change your mind at any time via the “Cookie preferences” link at the bottom of every page. No advertising, no profiling. Third-party services (e.g. maps, video) may set their own cookies when you activate their content. The technical cookie "contatore_no" (12 months) is set only if you ask not to be counted in the visit statistics, and it stores that choice.

9. Visit statistics without cookies

To know how many people visit our sites and which pages they read, we count page visits ourselves, without cookies and without needing your consent. For each page we record only the day, the page address (without parameters), the country, the type of device (computer, phone or tablet), whether it is the first page opened or a move within the site, the language of the page and, if you arrive from another site, its domain and the kind of source (for example a search engine or an email) and, if the link you followed carries a campaign name, that name (for example which of our emails or which video on our YouTube channel brought you here). We count a page only when there is a sign that a person is looking at it: a first gesture (tapping or clicking, moving the mouse, pressing a key, scrolling the page) or five seconds with the page visible on screen. The browser tells us so with a minimal request that contains no identifiers, as it does for every move from one page to another. In the same way we count, only as totals, clicks on the phone, WhatsApp and email buttons and the enquiries sent through the forms. Pages closed before a gesture or the five seconds, and everything reported by a browser that declares it is controlled by a program, are kept apart, only as totals, and do not enter the visit statistics. Of the page requests that reach the site's server we keep only the number, by country and type of device: it shows us how many come from automated programs. To estimate how many different visitors arrive in a day, the site computes a temporary code from your shortened IP address (without its last part) and your browser type, mixed with a random value that changes every day: the code is valid only for this site and that day, and at the end of the day it is deleted together with the random value, so that it can no longer be linked to anyone. The full IP address is never stored. We use this data only for aggregate statistics on the use of our sites: we do no profiling or advertising and we do not link it to the contact details you leave us. The legal basis is our legitimate interest in knowing how our sites are used (Art. 6(1)(f) GDPR); as first-party statistics treated like technical tools (Italian Data Protection Authority guidelines of 10 June 2021, section 7.2), no consent is required. The aggregate, anonymous counts are kept for 25 months. The data is processed on our behalf by Vercel Inc. (hosting, United States, under the Standard Contractual Clauses) and Neon Inc. (database, United Kingdom, a country covered by a European Commission adequacy decision). If your browser sends the Global Privacy Control signal, or if you use the link below to ask us not to count you, we do not compute the daily code and your pages remain only in the anonymous totals; the link stores your choice in a technical cookie for 12 months. The rights described in this notice still apply.

Don't count my visits · Count them again

10. Phone calls to the agency

When you call the agency's number, +39 331 8940822, and none of us can answer (outside office hours, on public holidays, or when no colleague is available at that moment), an artificial intelligence assistant may answer instead of the voicemail: Claude, by Anthropic, with voice and speech recognition by ElevenLabs; the call goes through our phone system, run by Twilio. The assistant says so straight away, in its greeting, and tells you that the conversation is transcribed: that is the short notice, and this is the full one. In these calls with the assistant your voice is not recorded (for the calls we make to you, see «When we call you»): neither the phone system nor ElevenLabs keeps the audio, and ElevenLabs deletes its own copy of the transcript after one day. What remains is the text of the conversation, which we save in our management system, in the call log and in your contact record; if your number is not already among our contacts, the record is created with the call. From the text, an artificial intelligence model produces a summary and extracts the details you give us on the phone: your name, your email if you leave it, the property you are interested in, what you are looking for, a viewing time to be confirmed and when to call you back. A colleague is notified so that they can call you back. The assistant does not take decisions on our behalf: the viewing times it suggests are confirmed by a person. We process these data to answer your request and call you back (pre-contractual measures taken at your request, Art. 6(1)(b) GDPR) and keep them like the other contact data (section 4). They are processed on our behalf by Twilio (the phone system), ElevenLabs (the voice and the transcript), Anthropic (the assistant and the summary), Neon and Vercel (the management system) and Google (the internal email and chat we use to notify the colleague). For transfers outside the European Union the safeguards in section 6 apply: Twilio and ElevenLabs are certified under the EU-U.S. Data Privacy Framework, and for Anthropic the transfer is based on the European Commission's standard contractual clauses. If you prefer not to talk to the assistant, you can end the call and write to us at richieste@triestevillas.com.

11. When we call you

When one of our colleagues calls you from our management system, the call comes from +39 331 8940822 and goes through our phone system, run by Twilio. The call may be recorded and transcribed: we do not keep an archive of recordings, we only use them to take notes. If you prefer it not to be recorded, just tell the colleague: at the end of the call they delete the recording and the transcript. We record so that we remember precisely what we discussed (requests, figures, appointments, commitments) without having to ask you again: the legal basis is our legitimate interest in documenting negotiations (Art. 6(1)(f) GDPR) and, when the call concerns a request of yours, pre-contractual measures taken at your request (Art. 6(1)(b)). Twilio turns the audio into the text of the conversation, and an artificial intelligence model by Anthropic writes a summary of it and updates your contact record: text and summary stay in our management system, in the call log and in your contact record, and are kept like the other contact data. The audio, instead, stays on Twilio's servers in the United States for 30 days and is then deleted automatically; it is deleted straight away if you ask us or if your data are erased. Only the colleague who called you can listen to it; an administrator can do so only for a reason that is written down, and every listen is logged. Twilio is certified under the EU-U.S. Data Privacy Framework; for Anthropic the transfer is based on the European Commission's standard contractual clauses. The rights described in this policy (access, erasure, objection) also apply to the recording and the transcript.

12. Changes

We may update this policy; the current version is always published on this page.