1. Data Controller Identification & Contact Information
The Data Controller responsible for the processing of personal data collected through the website zonagioco-it.it is ZonaGioco Strategic Advisory S.r.l., an Italian limited liability company with registered office at Via Mike Bongiorno 13, 20124 Milano (MI), Italia, registered in the Milan Companies Register under REA MI-2694182, Tax Code and VAT number IT12984570962 (hereinafter referred to as "ZonaGioco", the "Controller", "we", "us", or "our").
Official corporate contact points for privacy matters:
Corporate Email: [email protected]
Certified Electronic Mail (PEC): [email protected]
Telephone: +39 02 8719 8452
Postal Address: ZonaGioco Strategic Advisory S.r.l., Torre Diamante - Business District Porta Nuova, Via Mike Bongiorno 13, Piano 16, 20124 Milano (MI), Italia.
2. Data Protection Officer (DPO) Contact Details
In accordance with Article 37 of Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR"), ZonaGioco has appointed an independent Data Protection Officer (DPO). The DPO oversees ongoing regulatory compliance, audits data security practices, and serves as the primary liaison for data subjects and supervisory authorities.
You may contact our Data Protection Officer directly regarding any processing inquiries or rights requests at: [email protected] or by marking postal mail to "Attention: Data Protection Officer" at our registered address.
3. Categories of Personal Data Processed
ZonaGioco operates exclusively in a B2B (business-to-business) consultative capacity. We do not offer consumer gambling, games of chance, or player account management. The categories of personal data processed are restricted to professional interactions:
- Technical Browsing Data: IP addresses, browser types and versions, operating systems, referring URLs, timestamps of requests, network routing telemetry, and essential device identifiers necessary for HTTPS transmission.
- B2B Inquiry and Contact Data: Full name, professional corporate email address, business telephone number, company/operator name, job position, and professional correspondence submitted via our corporate contact forms.
- Contractual and Administrative Data: Representative identification data, corporate billing details, VAT numbers, payment clearing confirmations, and corporate master records necessary to execute advisory agreements.
- Preference & Consent Telemetry: Records of user consent, cookie category preferences, and opt-out timestamps captured via our consent management interface.
4. Sources of Personal Data
Personal data is obtained through the following lawful channels:
- Directly provided by the user when completing inquiry forms, requesting corporate whitepapers, or emailing our practice directors;
- Automatically collected by our web hosting infrastructure during HTTP/HTTPS transactions for fundamental network integrity and security monitoring;
- Verified via public corporate registers (such as InfoCamere, Registro delle Imprese, or official iGaming regulatory licensing databases) during enterprise onboarding due diligence.
5. Purposes and Legal Bases for Processing
In compliance with Article 6 of the GDPR, personal data is processed under specific, legitimate legal bases:
- Responding to Corporate Inquiries (Art. 6(1)(b) GDPR): Processing contact information to assess enterprise requests, schedule advisory consultations, or provide requested payment architecture insights prior to formal contractual engagement.
- Contract Performance & Professional Advisory (Art. 6(1)(b) GDPR): Fulfilling deliverables, advisory milestones, and payment consulting agreements entered into with corporate clients.
- Legal & Regulatory Compliance (Art. 6(1)(c) GDPR): Complying with statutory Italian and EU obligations, including anti-money laundering (AML) client verification, corporate taxation, and administrative record-keeping.
- Legitimate Interests of the Controller (Art. 6(1)(f) GDPR): Ensuring network security, preventing distributed denial-of-service (DDoS) attacks, defending legal claims, and analyzing aggregate website usability.
- Consent (Art. 6(1)(a) GDPR): Administering optional analytics tracking technologies subject to explicit consent collected via our cookie management interface.
6. Legitimate Interests Pursued by the Controller
Where processing relies on Article 6(1)(f) GDPR, our legitimate interests have been balanced against the fundamental rights of data subjects. These interests encompass maintaining robust cybersecurity across our infrastructure, safeguarding confidential consulting methodologies, asserting legal claims, and optimizing the delivery of B2B intelligence to regulated gaming executives.
7. Processing Methods & Technical Security Architecture
Data processing is conducted using computerized, cloud-based, and manual systems strictly configured according to principles of data minimization (Art. 5(1)(c) GDPR) and storage limitation (Art. 5(1)(e) GDPR). ZonaGioco enforces state-of-the-art security measures:
- TLS 1.3 cryptographic protocols with HSTS preloading for all client-to-server transmissions;
- AES-256 encryption at rest for database repositories, client archives, and backup snapshots;
- Multi-factor authentication (MFA) and strict role-based access control (RBAC) across all corporate terminals;
- Regular vulnerability scanning, automated penetration testing, and isolated containerized deployment nodes.
8. Data Retention Periods & Deletion Criteria
Personal data is retained only for the duration strictly necessary to fulfill the underlying operational purpose, in accordance with European and Italian statutory benchmarks:
- Contact Form Inquiries: Retained for up to 12 months following the last communication, after which records are purged unless an enterprise advisory mandate is initiated.
- Contractual & Advisory Records: Retained for 10 years following contract termination to satisfy Italian Civil Code requirements (Article 2220 C.C.) and tax audit statutes.
- Technical Server Logs: Automatically rotated, overwritten, and deleted every 30 to 90 days.
- Cookie Preferences: Stored locally in the user's browser for up to 6 months or until cache clearing.
9. Categories of Data Recipients & Processors
ZonaGioco does not sell, rent, or trade personal data to consumer marketing brokers. Data may be shared exclusively with verified recipients acting as Data Processors under Article 28 GDPR:
- Cloud hosting providers and infrastructure operators located within the European Economic Area (EEA);
- Certified email delivery and CRM software providers bound by strict Data Processing Agreements (DPAs);
- External certified legal, tax, accounting, and audit professionals registered in Italy;
- Competent judicial, regulatory, or tax authorities upon formal, lawful administrative request.
10. Cross-Border International Data Transfers (Third Countries)
All primary processing nodes and server infrastructures utilized by ZonaGioco are situated within the European Economic Area (specifically within Italy and Germany). In instances where auxiliary enterprise software operates cloud services outside the EEA, transfers occur strictly pursuant to:
- European Commission Adequacy Decisions under Article 45 GDPR (e.g., the EU-U.S. Data Privacy Framework);
- Standard Contractual Clauses (SCCs) adopted by the European Commission pursuant to Article 46(2)(c) GDPR, augmented by Transfer Impact Assessments (TIAs) and supplementary technical encryption safeguards.
11. Automated Decision-Making & Profiling Exclusions
ZonaGioco does not deploy automated decision-making systems, machine learning scoring algorithms, or automated profiling mechanisms (as defined in Article 22 GDPR) that produce legal or similarly significant effects concerning the data subject.
12. Data Subject Rights Under GDPR (Articles 15–22)
Pursuant to Chapter III of the GDPR, you are entitled to exercise the following statutory rights free of charge:
- Right of Access (Art. 15 GDPR): Obtain confirmation as to whether your personal data is being processed and receive a structured copy of that data.
- Right to Rectification (Art. 16 GDPR): Request the correction of inaccurate personal data or completion of incomplete records.
- Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR): Request the deletion of data where legal grounds for retention no longer apply.
- Right to Restriction of Processing (Art. 18 GDPR): Request temporary freezing of processing under statutory dispute scenarios.
- Right to Data Portability (Art. 20 GDPR): Receive data provided to us in a structured, commonly used, and machine-readable format.
- Right to Object (Art. 21 GDPR): Object at any time, on grounds relating to your particular situation, to processing based on legitimate interests.
- Right to Withdraw Consent (Art. 7(3) GDPR): Revoke consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.
13. Procedure for Exercising Data Subject Rights
To exercise any statutory data subject rights, you may submit a formal request to our privacy team via email at [email protected] or to our DPO at [email protected]. In accordance with Article 12(3) GDPR, we will acknowledge receipt and provide a substantive response within 30 calendar days. If requests are complex, this timeframe may be extended by up to two additional months, with prompt formal notification of the reasons for delay.
14. Right to Lodge a Complaint with a Supervisory Authority
If you believe that the processing of your personal data violates the GDPR or Italian privacy legislation, you have the right, under Article 77 GDPR, to lodge a complaint with a competent supervisory authority. In Italy, the supervisory authority is the Garante per la protezione dei dati personali:
Garante per la Protezione dei Dati Personali
Piazza Venezia 11, 00187 Roma (RM), Italia
Telephone: (+39) 06.696771 | Website: www.garanteprivacy.it
Certified Email: [email protected]
15. Protection of Minors & Age Verification Requirements
Our website and professional advisory services are directed exclusively at corporate executives, enterprise gaming operators, payment institutions, and adult professionals aged 18 years or older. We do not intentionally solicit or process personal data relating to minors under 18 years of age. If we ascertain that personal data from a minor has been inadvertently transmitted, we will immediately delete such information from our records.
16. Policy Amendments, Versioning & Review Frequency
ZonaGioco reserves the right to amend this Privacy Policy periodically to reflect technological advancements, operational changes, or new regulatory guidelines issued by the European Data Protection Board (EDPB) or the Italian Garante. Material changes will be highlighted prominently on this page with an updated version and revision date. Continued engagement with our digital services following the publication of revisions indicates acknowledgment of the updated terms.