1. Who we are
This Privacy Policy explains how personal data is collected and used when you visit our websites, fill in one of our forms, request the Italian Castle Acquisition Playbook, book a call or contact us. It applies to info.chineurdechateaux.com, to our Italian website chineurdechateaux.com and to the communications that follow.
The data controller is Immobiliare Emozionale S.r.l.s., which operates under the brand Chineur de Châteaux.
- Registered office: Viale Abruzzi 37, 20131 Milan, Italy
- VAT number: 13846290966
- REA: Milano (MI) 2747119
- PEC: immobiliareemozionale@pec.it
- Privacy contact: gianluca@chineurdechateaux.com
We have not appointed a Data Protection Officer, as we are not required to. For anything concerning your personal data, please write to the privacy contact above.
2. The data we collect
We collect only what we need, and what that is depends on the form you fill in and on how you get in touch with us.
- Identification and contact details: for example first name, last name, title, email address, phone number, country of residence.
- Information about your property or your search: the details you choose to share, for example the type of property, location, features, indicative budget, timeline, and any message you write.
- Booking a call: name, email address, phone number (if provided), and the date and time you choose.
- Correspondence: the content of your messages, and whether you open our communications and click the links in them.
- Website usage: pages viewed, device and browser information, approximate location and referring source, collected through cookies and similar technologies (see section 10).
The examples above are illustrative, not exhaustive: the actual fields vary from one form to another, and each form indicates which information is needed.
We do not ask for special categories of data, such as data about health, beliefs or sexual orientation, and we ask you not to send them to us.
3. Why we use your data and on what legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Replying to your requests and sending you the information and materials you asked for | Steps taken at your request (Art. 6(1)(b)) |
| Arranging and holding a call or a meeting with you | Steps taken at your request (Art. 6(1)(b)) |
| Assessing and handling a sale mandate or a property search | Steps taken at your request, or performance of a contract (Art. 6(1)(b)) |
| Sending you further insights and information about properties, the purchase process and our services, by email, SMS or WhatsApp | Your consent (Art. 6(1)(a)), which you can withdraw at any time |
| Analytics and advertising cookies and similar technologies | Your consent (Art. 6(1)(a)) |
| Managing contracts, invoicing and accounting if you become a client | Contract and legal obligation (Art. 6(1)(b) and (c)) |
| Keeping our systems secure and preventing spam and abuse | Our legitimate interest (Art. 6(1)(f)) |
| Establishing, exercising or defending legal claims | Our legitimate interest (Art. 6(1)(f)) |
4. Is providing your data compulsory?
Name and email address are needed to reply to you or to send you the materials you request. Without them we cannot provide the service. All other fields are optional, and each form indicates which information is required.
Agreeing to receive our marketing communications is always optional and separate: declining does not affect your access to the materials you requested, nor our reply to your enquiry.
5. Marketing communications, email, SMS and WhatsApp
If you give your consent, we will send you communications about historic and character properties in Italy, the buying and selling process and our services. These may reach you by email and, if you have given us a phone number, also by SMS or WhatsApp. The consent we ask for covers all of these channels, and you can ask us at any time to use only some of them.
Every email contains an unsubscribe link. You can withdraw your consent, in full or for a single channel, by writing to gianluca@chineurdechateaux.com, or by replying to a message asking not to be contacted again. Withdrawal does not affect the lawfulness of what we did before it.
Operational contact is separate from this purpose: if you ask us for information or book a call, we may reply and write to you to arrange it even without your marketing consent, because that contact follows up on your own request.
6. Who receives your data
We share data only with providers that help us run the service, who act on our instructions as data processors, and only as far as needed.
- HubSpot (customer database, forms, sending communications, meeting scheduling, website pages and analytics)
- Google (website analytics)
- Meta (advertising measurement, where you have consented, and WhatsApp messaging where that channel is used)
- OVH (website hosting and email)
- Our accountant, legal advisers and other professional consultants, where needed to meet legal obligations or manage a contract
- Public authorities, where required by law
We do not sell your data. Independent professionals such as lawyers, notaries, tax advisers and architects are involved only at your request, and we do not pass them your data without telling you first.
7. Transfers outside the European Economic Area
Some of our providers, including HubSpot, Google and Meta, may process data in the United States or other countries outside the European Economic Area. Where this happens, the transfer relies on an adequacy decision, such as the EU-US Data Privacy Framework for certified recipients, or on the European Commission's Standard Contractual Clauses, together with additional safeguards where needed. You can ask us for a copy of the safeguards in use.
8. How long we keep your data
| Data | Retention |
|---|---|
| Requests for information and materials, property enquiries and booking records | 36 months from our last interaction with you, then deleted or anonymised |
| Marketing subscriptions | Until you withdraw consent, or 36 months without any interaction |
| Client contracts, invoices and accounting records | 10 years, as required by Italian law |
| Data needed to handle a dispute | Until the dispute is closed and the limitation period has ended |
| Cookies | For the period shown for each cookie in the cookie settings |
We keep contacts for longer than a typical newsletter because buying or selling a historic property is a decision that often takes years. The period runs from our last interaction, not from collection: every contact with us renews it, and prolonged silence leads to deletion.
9. Your rights
Under the GDPR you have the right to:
- access your data and receive a copy;
- have inaccurate data corrected;
- have your data erased;
- restrict how we use your data;
- receive your data in a portable format;
- object to processing based on legitimate interest;
- withdraw consent at any time.
To exercise any of these rights, write to gianluca@chineurdechateaux.com. We will reply within one month. You also have the right to lodge a complaint with the Italian data protection authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or with the authority in your own country of residence.
10. Cookies, tracking and profiling
Our website pages use cookies and similar technologies. Strictly necessary cookies keep the site working. Analytics and advertising cookies are used only if you accept them in the cookie banner, and you can change your choice at any time through the cookie settings or your browser. A full description of the cookies in use is set out in our cookie policy.
With your consent, HubSpot records which pages you visit and how you interact with our communications, so that we can send messages that are relevant to you. Advertising tools may also measure the effect of our campaigns and build audiences of people with similar interests. We do not take decisions based solely on automated processing that produce legal effects on you.
11. Security
We use technical and organisational measures to protect your data against loss, misuse and unauthorised access, and we choose providers that offer appropriate security.
12. Changes to this policy
We may update this policy when our services or the applicable law change. The date of the latest update is shown at the top of this page.
13. Contact
For any question about this policy or your data, write to gianluca@chineurdechateaux.com, or send a message to our certified email address immobiliareemozionale@pec.it.