Modernize Studio

Privacy notice for business contacts

Last updated:

This notice explains what happens to your data when I contact your company by email about my services. I give it under Article 14 of the EU GDPR and of the UK GDPR, because I did not collect the data from you directly. If you write to me first, or visit this website, the same notice also gives you the information required by Article 13.

Who is responsible for your data

The controller is Riccardo (Modernize Studio), Palermo, Italy.
Email: riccardo@modernizestudio.com

I have not appointed a Data Protection Officer, as the law does not require one for an activity of this size. For any question about this notice, write to the address above.

What data I use

I use only the following:

  1. the business email address your company publishes on its website, usually a general one such as info@ or sales@;
  2. your company name, website address and country;
  3. public information from your website that I used to write the message, for example the software you sell or a job advert that mentions Access or Excel;
  4. if you reply, our correspondence and the dates of each contact;
  5. if you ask me to stop, your email address, kept on a "do not contact" list.

I do not use special categories of data, and I do not buy contact lists.

Where the data comes from

From your company's own website, where the address is published for business enquiries.

Why I use it, and on what legal basis

I use the data to contact your company about modernising older desktop software, to send at most two short follow-ups, to deal with any reply, and to respect any request to stop.

The legal basis is my legitimate interest in offering my services to businesses that may need them (Article 6(1)(f) GDPR). I have weighed that interest against your rights in a written assessment, which I can send you on request.

I only send these emails where the law allows them without prior consent: in the UK, only to companies, not to sole traders or partnerships; in France, only when the subject relates to the recipient's line of work. I do not send this kind of email to recipients in Italy.

This website

This website uses no cookies, no analytics and no tracking scripts, and it loads nothing from other websites. Like any web host, Cloudflare processes technical data such as your IP address and browser type in order to deliver the pages and protect the site from attacks. The legal basis is my legitimate interest in running a secure website (Article 6(1)(f) GDPR).

Who else sees the data

No one buys or receives your data from me. Some providers process it on my behalf, under a contract that binds them to the GDPR:

  1. email service: Zoho Corporation, with the mailbox hosted in its EU data centre;
  2. website hosting and DNS: Cloudflare.

Transfers outside Europe

The data is stored in the European Economic Area. I do not transfer it outside the EEA or the UK, except where one of the providers above does so: Cloudflare runs a global network, so the technical data of a visit to this website may be processed outside Europe. In that case the transfer relies on an adequacy decision or on the European Commission's Standard Contractual Clauses, and you can ask me for a copy of the relevant safeguards.

How long I keep it

I keep the data for 12 months after our last contact, then I delete it. If you object or ask me to stop earlier, I delete it straight away, except for your email address on the "do not contact" list, which I keep only to make sure I never write to you again.

Your right to object

You can object at any time, without giving a reason, to the use of your data for direct marketing (Article 21 GDPR). Just reply STOP to any of my emails or write to riccardo@modernizestudio.com. I will stop immediately and will not contact you again.

Your other rights

You can ask me for access to your data, for its correction, for its deletion or for its use to be restricted (Articles 15 to 18 GDPR). The right to data portability does not apply, because the processing is based on legitimate interest and not on consent or a contract. Requests are free, and I reply within one month.

If you think I have handled your data wrongly, you can complain to a supervisory authority:

  1. Italy (where I am based): Garante per la protezione dei dati personali, www.garanteprivacy.it
  2. United Kingdom: Information Commissioner's Office (ICO), www.ico.org.uk
  3. France: Commission nationale de l'informatique et des libertés (CNIL), www.cnil.fr

You can also contact the authority of the EU country where you live or work.

Automated decisions

I write every message myself. No decision about you is made by automated means, and there is no profiling with legal or similar effects on you.

Changes

If I change this notice, I will update the date at the top.