Privacy Policy

Introduction

Riccardo Ongaro, operating under the brand SUBLIME ("we," "our," or "us"), is committed to protecting your privacy and ensuring the security of your personal data. As the Data Controller (Titolare del trattamento), we are responsible for how your personal information is collected, used, and protected. This Privacy Policy explains our practices when you visit our website and use our services.

1. Information We Collect

1.1 Information You Provide

When you contact us through our forms, we collect:

• Name (first and last name)
• Email address
• Company name
• Your inquiry or message
• Area of interest

1.2 Information We Collect Automatically

When you visit our website, we may automatically collect:

• Browser type and version
• Pages you visit and time spent on pages
• Referring website
• IP address (anonymized)
• Device information
• Interaction data (clicks, scrolls, form submissions)

2. How We Use Your Information

We use your information to:

• Respond to your inquiries and provide requested services
• Improve our website and user experience
• Analyze website traffic and user behavior
• Send you relevant information (with your consent)
• Comply with legal obligations

3. Cookies and Tracking Technologies

3.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. We use cookies to improve your experience and understand how you use our site.

3.2 Types of Cookies We Use

3.3 Cookie Consent

When you first visit our website, you'll see a cookie consent banner. You can choose to:

• Accept: Allow all cookies, including analytics
• Decline: Only essential cookies will be used, no tracking

You can change your cookie preferences at any time by clearing your browser's local storage and refreshing the page.

4. Third-Party Services

4.1 PostHog Analytics (EU Hosted)

We use PostHog for website analytics. PostHog is hosted in the EU (Frankfurt, Germany) and is fully GDPR compliant. Analytics are only active if you accept cookies.

4.2 HubSpot CRM (EU Region)

When you submit a contact form, your information is sent to HubSpot CRM (EU region) for lead management. This happens regardless of cookie consent as it's necessary to process your inquiry.

4.3 Strapi CMS

We use Strapi as our content management system to deliver articles and tools. No personal data is collected through Strapi.

5. Data Protection and Security

We take data security seriously:

• EU Data Hosting: All analytics and CRM data is stored in the European Union
• Encryption: Data is transmitted over secure HTTPS connections
• Access Control: Only authorized personnel have access to your data
• Data Minimization: We only collect data necessary for our services
• Regular Audits: We regularly review our security practices

6. Your Rights (GDPR)

Under GDPR, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate personal data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Object to processing of your personal data
• Right to Withdraw Consent: Withdraw consent for data processing

To exercise any of these rights, please contact us at riccardo@sublime.ventures

7. Data Retention

We retain your personal data only as long as necessary:

• Contact Form Data: Retained in HubSpot CRM for business relationship purposes
• Analytics Data: Retained for 90 days in PostHog (configurable)
• Cookie Preferences: Stored locally until you clear browser data

8. Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children.

9. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top will reflect any changes. We encourage you to review this policy periodically.