This document is a working draft pending final review by legal counsel. Company registration details and the Data Protection Officer (if appointed) will be completed before go-live.
The data controller for personal data processed through the Site is OnTrade. Contact: privacy@ontrade.xyz.
Contact data (name, work email, company, role, message content). Technical data (IP address, browser and device information, pages visited, referrer, timestamps). Cookie data (identifiers and preferences stored in cookies and similar technologies). Commercial data (information shared during pre-sales or partnership conversations, including NDAs and meeting notes).
We process personal data to: (i) respond to your inquiries and manage pre-sales or partnership conversations, legal basis: performance of pre-contractual measures and our legitimate interest in running our business (Art. 6(1)(b) and (f) GDPR); (ii) operate, secure, and improve the Site, legitimate interest (Art. 6(1)(f) GDPR); (iii) use analytics and non-essential cookies, only with your consent (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code); (iv) comply with legal obligations (Art. 6(1)(c) GDPR).
We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Contact and pre-sales data are retained for up to 24 months after the last meaningful interaction, unless a contractual relationship requires longer retention. Server logs are retained for up to 12 months.
We share personal data with trusted service providers acting as data processors, including hosting, email, analytics, and CRM providers, under written data-processing agreements. Where personal data is transferred outside the European Economic Area, we rely on adequacy decisions or Standard Contractual Clauses and implement supplementary measures where appropriate.
You have the right to access, rectify, erase, restrict, or object to processing of your personal data, as well as the right to data portability and to withdraw consent at any time without affecting the lawfulness of processing before withdrawal. To exercise these rights, contact privacy@ontrade.xyz. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it).
We implement technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, or destruction, proportionate to the risks of processing.
We may update this Privacy Policy from time to time. Material changes will be signaled on the Site. Please review it periodically.