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

On your first visit, a banner asks for your consent. You can:

• Accept: allow detailed statistics and session recording
• Customize: choose detailed statistics and session recording separately; both start switched off
• Close (X): keep only the necessary cookies; your visit is counted anonymously, without cookies

You can change or withdraw your consent at any time with the "Cookie preferences" link at the bottom of every page.

4. Third-Party Services

4.1 PostHog Analytics (EU Hosted)

We use PostHog for website statistics, hosted in the EU (Frankfurt, Germany). Without consent, PostHog only counts visits anonymously and without cookies; with your consent it also uses cookies and, if you allow it, session recording. The same choice applies on the subdomains of our tools (for example canvas.sublime.ventures). Analytics requests reach PostHog through a proxy on our domain (e.sublime.ventures) that PostHog operates on Cloudflare's network; Cloudflare is a sub-processor under PostHog's data processing agreement, which covers any transfer outside the EU with the safeguards required by the GDPR.

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.

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)
• Session recordings: kept for 30 days, then deleted
• Cookie preferences: stored in the sublime_consent cookie for 12 months after you accept, or 6 months after you decline

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.