Privacy Policy

1. DATA CONTROLLER

The Data Controller is Downhero.com

2. TYPE OF PERSONAL DATA COLLECTED

Website navigation is free and does not require registration. The Website primarily provides informational content.

During Website browsing, Downhero may collect the following personal data (hereinafter “Personal Data”):

Navigation data

The computer systems and software procedures used for operating this Website acquire, during their normal functioning, certain personal data whose transmission is implicit in the use of the Internet. This category of data includes IP addresses or domain names of the computers used by users who connect to the site, URI (Uniform Resource Identifier) addresses of requested resources, and timestamps of requests. These data are not collected for the purpose of being associated with identified individuals but, by their very nature, could allow user identification through processing and association with data held by third parties.

Voluntarily provided data by the User

If the user sends data and/or information voluntarily and explicitly to the contact addresses provided on the Website, such data will be acquired to process requests and/or provide services, including identifying and contact information (name, surname, email), and any additional data included in the message. The user assumes responsibility for any third-party personal data shared and declares that they have the right to disclose or disseminate such data, relieving the Data Controller from any responsibility toward third parties.

3. PURPOSES, LEGAL BASES OF PROCESSING AND NATURE OF DATA PROVISION

In accordance with Article 6 of the GDPR and the principles of fairness, transparency, and data minimization, personal data collected through the Website may be processed for the following purposes:

• a) Providing the Website’s functionalities
• b) Responding to user requests received via the contact information on the Website

Legal basis: performance of pre-contractual or contractual obligations (Art. 6, lit. b GDPR); and/or legitimate interest of the Data Controller (Art. 6, lit. f GDPR) in ensuring efficiency and communication regarding the services offered.
Failure to provide the data mentioned under a) and b) may result in the inability to use the Website or obtain the requested service.

c) Ensuring correct operation of the Website and improving user experience

Legal basis: legitimate interest of the Data Controller (Art. 6, lit. f GDPR).
Failure to provide such data may result in the inability to access or properly use the Website.

4. DATA RETENTION PERIOD

In compliance with Article 5(1)(e) of the GDPR, personal data will be retained for as long as strictly necessary to fulfill user requests or provide services. Subsequently, data will be deleted or anonymized unless further retention is required by law or for legitimate administrative, fiscal, or contractual reasons.

5. DATA COMMUNICATION AND DISCLOSURE

Personal data will not be disseminated but may be communicated to:

• (i) Third parties that perform processing or auxiliary activities on behalf of the Data Controller (e.g., IT or communication service providers);
• (ii) Consultants or professional service firms;
• (iii) Competent authorities or public entities, as legally required.

These parties will process data as independent controllers, joint controllers, or processors duly appointed by the Data Controller. An up-to-date list of processors is available upon request.

6. DATA TRANSFER

Downhero may transfer personal data to third parties located in non-EU countries, only in compliance with Articles 44–49 of the GDPR. These transfers are based on adequacy decisions, standard contractual clauses, or binding corporate rules.

7. RIGHTS OF THE DATA SUBJECT

Pursuant to Articles 15–22 of the GDPR, the user may at any time exercise the following rights:

• Right of access
• Right to rectification
• Right to erasure (right to be forgotten)
• Right to restriction of processing
• Right to object
• Right to data portability

Requests to exercise these rights can be submitted:

• By email to: info@downhero.com

Additionally, users have the right to lodge a complaint with the competent supervisory authority (for Italy, the Italian Data Protection Authority: www.garanteprivacy.it).

8. LINKS AND THIRD-PARTY PLUGINS

The Website may contain links to external websites that are not controlled by the Company. These are provided solely for user convenience. Downhero is not responsible for the content of external sites and declines all liability for any resulting damage. The reproduction or use of any company trademarks, intellectual property, or copyrighted content found on the Website or linked sites is prohibited.

9. CHANGES TO THIS PRIVACY POLICY

Downhero reserves the right to update this Privacy Policy at any time, with changes effective upon publication on this page. Users are encouraged to consult this page regularly. Continued use of the Website following updates constitutes acceptance of those changes.

Last updated: 28/07/2025