Privacy & Cookies Policy

Last updated November 2026

This policy explains how Zanklon processes the personal data of users of zanklon.com (the "Website"), pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (the "GDPR") and Legislative Decree no. 196 of 30 June 2003, as amended by Legislative Decree no. 101 of 10 August 2018 (the "Privacy Code").

DATA CONTROLLER

The data controller is Zanklon Capital S.r.l., with registered office at Via Carlo Pisacane 47, 20129 Milan, Italy, tax code and VAT number 13053240969 ("Zanklon", "we" or "us"). Email: info@zanklon.com. Certified email (PEC): zanklon@pec.it.

DATA WE PROCESS

Browsing data. The systems that operate the Website collect, in the ordinary course of their operation, data whose transmission is implicit in the use of internet protocols, such as IP addresses, browser type, operating system, the pages requested and the date and time of access. This data is used to operate the Website and to ensure its security.

Data you provide. If you write to us, including at the addresses shown on the Website, we process your contact details and the information contained in your message. The Website has no contact forms and does not collect special categories of personal data; please do not send us such data.

PURPOSES AND LEGAL BASIS

We process personal data: (a) to operate and secure the Website, on the basis of our legitimate interest (Article 6(1)(f) GDPR); (b) to respond to your enquiries and manage any resulting relationship, on the basis of pre-contractual or contractual measures taken at your request (Article 6(1)(b) GDPR) or of our legitimate interest in handling business correspondence (Article 6(1)(f) GDPR); (c) to comply with legal obligations, including anti-money laundering obligations where applicable, and to establish, exercise or defend legal claims (Article 6(1)(c) and (f) GDPR). Providing data under (b) is optional, but without it we cannot respond to you.

RECIPIENTS

Personal data is processed by authorised Zanklon personnel and may be disclosed to: providers of IT, hosting and email services acting as processors under Article 28 GDPR, including Google, which hosts the Website on Google Sites; professional advisers bound by confidentiality obligations; public authorities, where required by law. Personal data is not disseminated.

TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA

Some service providers may process personal data outside the European Economic Area, including in the United States. Any such transfer takes place on the basis of an adequacy decision of the European Commission, including the EU-U.S. Data Privacy Framework, or of the standard contractual clauses approved by the European Commission (Articles 45 and 46 GDPR).

RETENTION

Browsing data is kept for the limited period required for security purposes. Correspondence is kept for the time needed to handle the enquiry and any resulting relationship and, thereafter, for the period required by law, including the ten-year period under Article 2220 of the Italian Civil Code, or until the applicable limitation period expires.

COOKIES

The Website is hosted on Google Sites and uses only technical cookies necessary for its operation and security. Under Article 122 of the Privacy Code and the Guidelines on cookies and other tracking tools of the Italian Data Protection Authority of 10 June 2021, technical cookies do not require consent. The Website does not use profiling cookies or analytics cookies. Third-party websites linked from the Website, such as LinkedIn, apply their own cookie policies. You can manage or delete cookies through your browser settings.

YOUR RIGHTS

Under Articles 15 to 22 GDPR you have the right to access your personal data, to obtain its rectification or erasure, to restrict its processing, to data portability, and to object at any time to processing based on our legitimate interest. You may exercise your rights by writing to info@zanklon.com or zanklon@pec.it. 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).

SECURITY

We adopt appropriate technical and organisational measures to protect personal data in accordance with Article 32 GDPR. No transmission of data over the internet is completely secure.

CHANGES TO THIS POLICY

We may update this policy from time to time. The current version is always published on this page, with the date of the last update.