Privacy Policy
Introduction
This Privacy Policy describes how Studio Associato NetworkDev processes personal data collected through the website wabbe.io.
WABBE is a product brand of Studio Associato NetworkDev. WABBE does not constitute a separate legal entity: all data processing performed in connection with wabbe.io is carried out by Studio Associato NetworkDev as data controller.
This Policy is issued under Regulation (EU) 2016/679 (GDPR) and the Italian Data Protection Code (Legislative Decree 196/2003 as amended).
This Policy applies exclusively to wabbe.io. It does not apply to websites operated by Studio Associato NetworkDev clients, even when technically managed by Studio Associato NetworkDev. For comprehensive information about Studio Associato NetworkDev's general data processing practices, infrastructure, sub-processors and applicable regulatory framework, please refer to the authoritative Italian version published at networkdev.it/legal/privacy, which prevails in case of interpretive discrepancy.
1. Data controller
Studio Associato NetworkDev
Registered office: Via Giuseppe Parini 26, Rome, Italy
VAT and fiscal code: IT10287091002
Email: [email protected]
Phone: +39 06 98358635
For any privacy-related request and to exercise your rights, please contact [email protected].
Studio Associato NetworkDev has not appointed a Data Protection Officer (DPO) as it is not required under article 37 GDPR.
2. What data we collect
Data you provide
| Data | Source |
|---|---|
| Email address | Contact form on wabbe.io |
| Business sector (e.g. agency, real estate, consulting, other) | Drop-down selection in contact form |
| Optional free-text content | If included in your message (not requested as a separate field) |
Data collected automatically
| Data | Tool | Purpose |
|---|---|---|
| IP address, browser, device | Server logs | Security, technical operation |
| Access timestamps, pages visited | Server logs | Diagnostics, abuse prevention |
Data we do not collect
- We do not systematically collect special categories of personal data (ethnic origin, political opinions, health data, etc.). Any such data inadvertently provided in voluntary communications is processed only as strictly necessary to handle the communication and, where possible, anonymised or deleted at the end of processing.
- We do not knowingly collect data of minors under the age of 14 (digital consent threshold in Italy).
- We do not perform automated profiling with significant legal effects.
3. Purposes and legal basis
| Purpose | Legal basis |
|---|---|
| Responding to your inquiry submitted via the contact form | Pre-contractual measures at your request (Art. 6.1.b GDPR) |
| Sending you product information you have requested about WABBE solutions | Pre-contractual measures at your request (Art. 6.1.b GDPR) |
| Keeping the site secure and preventing abuse | Legitimate interest (Art. 6.1.f GDPR) |
| Complying with legal obligations | Legal obligation (Art. 6.1.c GDPR) |
We do not perform automated profiling. We do not sell your data. We do not share identifiers with advertising platforms.
4. How we process your data
Your data is processed by electronic means, with technical and organisational measures appropriate to the risk: access control, robust authentication on sensitive systems, encryption in transit, periodic backups, environment separation, systematic security updates, retention of system access logs and tracking of critical administrative operations for security, diagnostics and compliance demonstration purposes.
Navigation data (IP addresses, logs) is used for technical purposes, where possible in aggregated or minimised form.
5. Who we share your data with
Your data may be communicated to the following categories of recipients, each for purposes within their respective scope:
- Authorised internal personnel, bound by confidentiality
- Professional advisors (accountant, occasional legal or labour advisor) for adherence to their professional duties
- Technical sub-processors acting as Data Processors under Art. 28 GDPR (cloud infrastructure, CDN, backup, transactional email — primarily EU-based; for the full list see networkdev.it/legal/privacy section 5)
- Competent authorities in case of legal obligations
The specific and up-to-date list of active sub-processors is available, upon written request, to clients and data subjects, within the limits of the relevance of the request, within 15 (fifteen) business days.
We do not sell, transfer or share your data for third-party marketing purposes.
6. International transfers
Processing takes place primarily within the EU/EEA. Any transfers to third countries take place through legitimate mechanisms: EU Commission adequacy decisions, EU-US Data Privacy Framework for certified providers, or Standard Contractual Clauses.
7. Data retention
| Data type | Retention criterion |
|---|---|
| Contact form submissions and inquiries not leading to a contract | Up to 24 months from last contact, after which data is deleted or anonymised |
| Contractual and billing data (for actual clients) | Civil, fiscal and accounting obligations period (typically 10 years) |
| Communications with active clients | For the duration of the relationship and the time needed to handle disputes |
| Navigation data and technical logs | Up to 12 months, unless extended due to incidents, anomalies, ascertainment of unlawful conduct or rights protection |
At expiry, data is irreversibly deleted or anonymised.
8. Your rights
You have the right, at any time, to:
| Right | Meaning |
|---|---|
| Access | Know what data we hold about you and obtain a copy |
| Rectification | Correct inaccurate or incomplete data |
| Erasure | Request deletion of your data, in cases provided for by law |
| Restriction | Limit the use of your data in specific cases |
| Data portability | Receive your data in a structured, machine-readable format |
| Objection | Object to processing based on legitimate interest |
| Withdrawal of consent | Withdraw consent at any time, without affecting the lawfulness of prior processing |
How to exercise them: write to [email protected]. We will respond without undue delay and in any case within 30 days, subject to motivated extension.
You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali, www.garanteprivacy.it) or with the data protection authority of your country of residence within the EU.
9. Minors
WABBE services are intended for professionals, businesses and entities. We do not knowingly collect data of minors under 14. Where involuntary processing of such data is detected, we proceed to delete it without undue delay, subject to retention obligations or rights protection needs.
10. Security and data breaches
We adopt technical and organisational measures reasonably appropriate to protect your data from unauthorised access, loss or disclosure.
In case of a personal data breach, Studio Associato NetworkDev performs the assessments required by applicable law and, where the prerequisites are met, proceeds with notification to the supervisory authority and/or communication to data subjects within the deadlines set by Articles 33–34 GDPR.
11. Changes to this Policy
We may update this Policy over time to reflect regulatory, organisational or technological changes. The current version, with its last update date, is always published at the URL indicated at the top.
For substantial changes affecting your rights or processing modalities, we provide prior notice through appropriate means (notice on the website, email notification to active clients).
The Italian version published at networkdev.it/legal/privacy is the authoritative source in case of interpretive discrepancy between this English version and the Italian one.
12. Contacts
Studio Associato NetworkDev
Via Giuseppe Parini 26, Rome, Italy
Privacy requests: [email protected]
General contact: [email protected]
For privacy-related requests, please use the subject line "Privacy Request".
Studio Associato NetworkDev — wabbe.io Privacy Policy v1.0, effective from 22 May 2026.