Privacy Policy

Last updated: July 29, 2026

1. Data Controller

Quattuordecim S.p.A. Benefit, registered office at Via Montenapoleone 8, 20121 Milan, Italy, VAT and tax code 14314550964, is the data controller for personal data collected through this website and the group's internal platforms.

Privacy contact: [email protected]

2. Data Collected Through the Website

The gruppotamburro.com website is a corporate showcase. It does not automatically collect user personal data. If you fill out the contact form, we process your name, email, and message solely to respond to your inquiry, retained only for as long as necessary.

3. VOLT — Competitor Intelligence

As part of its strategic marketing activities, Quattuordecim S.p.A. Benefit uses an internal platform called VOLT to analyze publicly available content published by competitor business pages.

Through Meta Graph API (App ID 836393422803485), VOLT reads from publicly available Facebook and Instagram pages of market competitors, manually curated by our marketing team, exclusively the following public data:

  • Text of public posts
  • Publication date and time
  • Aggregate reaction count
  • Aggregate public comment count
  • Content type (post, reel, photo, video)

VOLT does NOT collect:

  • Personal data of Meta users (name, email, profile picture)
  • Private messages or direct messages
  • Non-public content or content restricted to friends/followers
  • Data of minors

The data is aggregated into internal reports used exclusively by authenticated group staff for marketing decisions (identifying industry trends, high-performing formats, typical publishing frequency).

Retention: 24 months in a private internal Postgres database.

Third-party sharing: none.

4. WhatsApp Business Channel

The group uses a single business WhatsApp number, +39 346 097 5530, to receive and reply to messages from customers and from anyone asking about our services. The channel runs on Meta's WhatsApp Business API.

When you message us on WhatsApp we process:

  • your phone number and WhatsApp profile name
  • the content of the messages you send and of our replies, including any attachments
  • date, time and delivery or read status of the messages

Purposes and legal basis: we reply to your requests and, at your request, take pre-contractual or contractual steps (Art. 6(1)(b) GDPR). The conversation is recorded in the group's internal CRM and linked to your contact record, so you do not have to repeat the same information to different people (Art. 6(1)(f), legitimate interest in orderly relationship management). Promotional messages initiated by us require your consent (Art. 6(1)(a)), which you can withdraw at any time by replying STOP to the same number.

Provider and transfers: messages transit through WhatsApp Ireland Limited and Meta Platforms Ireland Limited, acting as processors on our behalf. Any transfers to third countries are covered by the standard contractual clauses adopted by the European Commission. Meta also processes data transiting its APIs under its own terms, which we invite you to read.

Retention: we keep conversations for 24 months from the last contact, except those needed to perform an ongoing contract or to establish or defend a legal claim.

We do not use WhatsApp to collect special categories of data (for example health data). If you need to share such information, please write to us by email.

5. Data Deletion

To request deletion of any data related to you or your business page processed via VOLT, write to [email protected]. We will respond within 30 days as required by GDPR.

Meta Platforms may send automated data deletion requests to the endpoint https://gruppotamburro.com/api/meta/data-deletion as required by the Platform Policy.

6. Data Subject Rights

Under Articles 15-22 of GDPR (EU Regulation 2016/679), you have the right to: access, rectification, erasure, restriction, portability, and objection to processing. You may exercise these rights by writing to [email protected]. You also have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

7. Security

We adopt appropriate technical and organizational measures to protect data: TLS encryption in transit, JWT-authenticated access to internal platforms, audit logs, role separation, encrypted backups, and hosting in ISO 27001 certified EU data centers.

8. Changes to This Policy

Quattuordecim S.p.A. Benefit reserves the right to update this policy to comply with regulatory or operational changes. The current version is always published at this URL with the last update date shown at the top.