Privacy Policy

Data Controller: Oncode S.r.l. (single-shareholder), Piazza Maestri del Lavoro 7, 20063 Cernusco sul Naviglio (MI), Italy, VAT IT09903240969.

Data Protection Officer (DPO): reachable at [email protected].

• Browsing data: IP addresses, access logs, user-agent, visited pages, technical cookies and — with consent — analytics.
• Data provided voluntarily: name, surname, business email, company name, role, phone, content of inquiries via contact forms.
• Contractual and billing data: company name, VAT, address, recipient code/PEC, banking details, contractual contacts.
• Marketing data (with consent or B2B soft opt-in): preferences, email and content engagement.

• Service delivery and contract management — basis: Art. 6(1)(b) GDPR (contract performance).
• Tax, accounting and administrative obligations — basis: Art. 6(1)(c) GDPR (legal obligation).
• Responding to contact and support requests — basis: Art. 6(1)(b) GDPR (pre-contractual measures) or 6(1)(f) (legitimate interest).
• Direct marketing on similar products to existing customers (B2B soft opt-in) — basis: Art. 130(4) Italian Privacy Code. Opt-out always available.
• Newsletter and promotional communications — basis: Art. 6(1)(a) GDPR (explicit consent).
• Security, fraud prevention, incident management — basis: Art. 6(1)(f) GDPR (legitimate interest in secure operations).
• Compliance with authorities' requests — basis: Art. 6(1)(c) GDPR.

Data are processed by electronic means, applying technical and organisational measures appropriate to GDPR Art. 32 and aligned with Oncode S.r.l.'s ISO/IEC 27001 certification.

Onwork and main sub-processors' servers are located in the European Union (Ireland — AWS eu-west-1). For details and extra-EU transfer mechanisms, see the next section.

• Contractual and tax data: 10 years after contract termination (statutory obligation).
• Lead/sales contact data: up to 24 months from last interaction, unless marketing consent is granted.
• Newsletter: until consent is withdrawn or after 24 months of inactivity.
• Application logs: max 12 months, except for security or legal needs.
• Cookies: as indicated in the Cookie Policy.

Data may be shared with qualified vendors appointed as Processors under GDPR Art. 28 (cloud, email marketing, observability, AI). The current list is at Sub-processors.

Where needed to deliver the Service, some data may be transferred to vendors located outside the European Economic Area. In such cases we adopt the safeguards of GDPR Chapter V: European Commission adequacy decisions, Standard Contractual Clauses (EU Decision 2021/914), Data Privacy Framework (USA) and — where needed — Transfer Impact Assessments.

You may exercise the rights under GDPR Articles 15–22 at any time:

• Right of access and copy (Art. 15)
• Right to rectification (Art. 16)
• Right to erasure (Art. 17)
• Right to restriction (Art. 18)
• Right to data portability (Art. 20)
• Right to object, including direct marketing (Art. 21)
• Right not to be subject to automated decision-making (Art. 22)

Requests can be sent to [email protected]. We respond within 30 days (extendable in complex cases).

If you believe the processing of your data violates the GDPR or the Italian Privacy Code, you have the right to lodge a complaint with the Italian Data Protection Authority — Piazza Venezia 11, 00187 Rome.

This Privacy Policy is subject to update. Previous versions are retained for audit purposes. Substantive changes are communicated to data subjects via the most appropriate means.