Privacy Policy

1. Introduction

Capitaly Group is a trademark of 1402 Celsius Ltd ("we", "our", or "us"). We are committed to protecting your privacy and handling your data in an open and transparent manner. This privacy policy explains how we collect, use, and protect your personal information when you use our website and services.

2. Information We Collect

Personal Information

We may collect the following types of personal information:

• Name and contact details (email address, phone number)
• Investment preferences and interests
• Communication preferences
• Information you provide when downloading our investment guide
• Correspondence and feedback you provide to us

Technical Information

We automatically collect certain technical information when you visit our website:

• IP address and browser type
• Device information and operating system
• Pages visited and time spent on pages
• Referring website and clickstream data

3. How We Use Your Information

We use your personal information for the following purposes:

• To provide you with information about investment opportunities in Italy
• To send you our investment guide and related resources
• To respond to your inquiries and provide customer support
• To send you marketing communications (with your consent)
• To improve our website and services
• To comply with legal obligations

4. Legal Basis for Processing

We process your personal data based on:

• Consent: When you provide explicit consent (e.g., subscribing to our newsletter)
• Contractual necessity: To provide services you have requested
• Legitimate interests: To improve our services and communicate relevant opportunities
• Legal compliance: To comply with applicable laws and regulations

5. Data Sharing and Disclosure

We do not sell your personal information. We may share your data with:

• Service providers: Third-party providers who help us operate our website and services (email delivery, analytics, hosting)
• Professional advisors: Lawyers, accountants, and consultants when necessary
• Legal authorities: When required by law or to protect our legal rights

All third-party service providers are required to maintain the confidentiality and security of your personal information.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Secure servers and encrypted data transmission (SSL/TLS)
• Regular security assessments and updates
• Access controls and authentication procedures
• Staff training on data protection

7. Your Rights

Under applicable data protection laws (including GDPR), you have the following rights:

• Access: Request access to your personal data
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal data
• Restriction: Request restriction of processing
• Portability: Request transfer of your data to another service provider
• Objection: Object to processing of your personal data
• Withdraw consent: Withdraw consent at any time (where processing is based on consent)

To exercise any of these rights, please contact us at info@1402celsius.com

8. Cookies and Tracking

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small text files stored on your device that help us:

• Remember your preferences
• Understand how you use our website
• Improve website functionality
• Deliver relevant marketing messages

You can control cookies through your browser settings. However, disabling cookies may affect website functionality.

9. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required by law. Typically:

• Contact information: Retained while you are an active subscriber or client, plus 3 years
• Transaction records: Retained for 7 years for legal and accounting purposes
• Marketing data: Retained until you unsubscribe or withdraw consent

10. International Data Transfers

Your personal information may be transferred to and processed in countries outside your country of residence. We ensure appropriate safeguards are in place to protect your data, including:

• Standard contractual clauses approved by the European Commission
• Transfers to countries with adequate data protection laws
• Your explicit consent where required

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us immediately.

12. Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by posting a notice on our website or sending you an email. Your continued use of our services after such modifications constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions about this privacy policy or our data practices, please contact us:

14. Supervisory Authority

If you are located in the European Economic Area, you have the right to lodge a complaint with your local data protection supervisory authority if you believe we have not complied with applicable data protection laws.