Controller and privacy contact
The controller is Wake Up Italy SRL, Piazza Antonio Baldini 33, 00141 Roma, Italy, tax/VAT number 16199071008. Contact info@siti.gratis for all privacy matters; certified email: wakeupitaly@pec.it. You do not need an account to exercise your rights.
Who this notice covers
This notice covers visitors, applicants, customers, company representatives, invited colleagues and people contacting siti.gratis. When we process a customer website’s data on the customer’s instructions, that customer determines the purposes and legal bases and we act as processor within Annex D. The customer’s privacy notice and that processing agreement are separate from this notice.
Data and sources
We process contact and professional details, company and tax information, protected credentials and session data, applications, questionnaires, catalogues, files, contracts, evidence of actions, payment references, support messages and necessary technical information such as IP address and browser/device information.
Data comes from you, an organisation inviting or appointing you, its representatives and, when necessary, company documents or public business registers. Do not put passwords, authentication codes, health/criminal data or other special-category data in free-text fields without a specific agreement. For indirectly obtained data we provide the information within Article 14 deadlines, subject to applicable exceptions.
Purposes and legal bases
Reading this notice is not blanket consent. Optional purposes are separated from necessary processing.
| Purpose | Legal basis |
|---|---|
| Pre-contractual steps and services where you personally are a contracting party | GDPR Article 6(1)(b): contract or requested pre-contractual steps |
| Working with a company’s representatives and employees | Article 6(1)(f): legitimate interest in managing the professional relationship |
| Tax, accounting and legally binding requests | Article 6(1)(c): legal obligation |
| Security, abuse prevention, continuity and legal claims | Article 6(1)(f): proportionate legitimate interests; legal obligations where applicable |
| Optional marketing and traffic analytics, with separate choices | Separate withdrawable consent under Article 6(1)(a), together with applicable tracking rules |
Required and optional information
Necessary fields allow us to respond, assess an application, provide access and meet contractual or tax requirements. Without essential information the corresponding activity cannot be completed. Refusing marketing or analytics does not prevent use of the service. We do not sell the customer database for third-party advertising.
Recipients and service providers
Authorised personnel access data according to their role. Necessary providers include Cloudflare infrastructure, databases and file storage/delivery, Turnstile protection and Cloudflare email services, together with professional advisers and authorities acting within their remit. Uploading a file to the portal does not make it public. For improving bot detection through Turnstile, Cloudflare acts as an independent controller under its own notice; that purpose is not processing on the customer’s behalf.
For SHOP, the customer establishes and maintains its own relationship with Shopify for the commerce backend; Shopify is not described as a subprocessor appointed by Wake Up Italy SRL. Publishing approved website content is separate from storing private project materials.
Locations and international transfers
D1/R2 are configured for EU jurisdiction, while Workers uses a distributed network and Cloudflare, Inc. is a US company. EU storage does not mean every processing operation or access occurs exclusively in the EU. The registers identify relevant services and the provider chain.
Transfers outside the EEA require an applicable adequacy decision or GDPR Article 46 safeguards, including standard contractual clauses and necessary assessments/supplementary measures. You can request information and a relevant copy of safeguards, with other people’s data and confidential information protected. Google Analytics is provided by Google Ireland Limited, which processes data on our behalf under the applicable data processing terms. Data may also be processed outside the EEA, including in the United States. For covered transfers, Google relies on the EU–US Data Privacy Framework while the relevant adequacy decision and recipient certification apply; for other transfers it uses standard contractual clauses where required, together with any necessary additional safeguards. The versioned contractual registers govern Customer services and do not replace this notice about analytics on our public website.
Retention periods
These are organisational limits by purpose. Their management requires review and deletion procedures, including periodic or request-based deletion; they do not mean immediate automated deletion of every archive. Unnecessary data is deleted or anonymised; specific legal duties or disputes can justify a restricted, documented and reviewed hold.
The log limit concerns records managed by Wake Up Italy SRL; data and logs Cloudflare processes for its own purposes follow its own notice and retention terms.
| Category | Normal maximum period |
|---|---|
| Unverified registration | 30 days |
| Application without a contract; general enquiry | 12 months after the last meaningful interaction or closure |
| Account and operational preferences | While active plus 90 days after closure, excluding separately retained required evidence |
| Support tickets | 24 months after closure; only necessary contractual evidence follows its separate period |
| Accounting records | 10 years after the last accounting entry, subject to specific duties |
| Contracts and necessary performance evidence | 10 years after the relationship ends |
| Marketing | 24 months after affirmative consent or explicit renewal; earlier upon withdrawal |
| Limited consent and rights-request evidence | 5 years after withdrawal or request closure |
| Operational security logs | Up to 90 days; incident evidence isolated only as long as necessary |
| Backups | 30 days, with restricted access and rotation |
Customer website data at exit
Data processed for the customer follows Annex D and the transition process: a recovery period of at least 30 days following the transition, or a longer agreed period, followed by deletion of active data within 30 days. If no recovery period applies, active data is deleted within 30 days after processing ends, subject to applicable instructions and duties. Backups remain isolated and are deleted within 30 days after the active data is deleted. Retaining contract evidence for ten years does not authorise blanket retention of the customer website’s database, shoppers or orders. If a backup is restored, deletions already carried out must be reapplied.
Google Analytics and optional statistics
Analytics in Cookie settings covers Google Analytics 4, the internal comparison of public text assistant outcomes and the optional quality journal for new messages and available voice transcripts. Chat and form contents are not sent to Google Analytics. Authorized administrators review the separate journal to improve tests, knowledge and instructions; no audio is stored and no automatic model training takes place.
With Analytics consent, we measure public-page navigation, permitted client-area page categories, scroll depth, relevant clicks, opening the assistant, starting text or voice interaction, ending a voice session and application milestones. Parameters use fixed action, stage, channel, language and outcome categories, never what you type or say. The generate_lead event means the server has confirmed an actually submitted application; creating a draft, opening a form or clicking Submit is not a lead. Earlier analytics grants do not cover this expanded scope and require a new choice. Valid earlier refusals retain their original expiry and do not create a new request to delete an existing quality journal.
With your consent, we use Google Analytics 4 (GA4) to understand which public pages and documentation articles people visit and to improve them. Google Ireland Limited provides the service as a processor. We collect sanitised page addresses, technical browser/device and session information, non-granular geographic indicators and pseudonymous cookie identifiers: pseudonymous does not mean anonymous. We do not send names, email addresses, form contents or account data.
We exclude administration, login, authentication, internal search, raw private URLs and identifying page content. Permitted client-area navigation uses fixed page categories and titles, with UUIDs, customer/order identifiers and private path segments removed. Application measurement uses fixed milestones, never form answers or an application identifier. Unapproved query values and URL fragments are removed and the referrer is not sent. Only with both Analytics and the separate Google Ads measurement choice may the permitted click identifiers gclid, gbraid and wbraid and validated campaign labels in utm_source, utm_medium, utm_campaign, utm_id, utm_term, utm_content be retained for attribution. Each campaign label is limited to 100 characters and must pass character checks; recognisable URL, email and contact-like values are rejected. Do not put personal data in campaign labels. All other query values remain excluded. We send explicitly selected events; GA4 may add technical user, session and engagement events. Enhanced Measurement, Google Signals, User-ID, user-provided data, enhanced conversions, personalised advertising, remarketing and BigQuery exports remain disabled. Google Ads measurement needs the additional choice described below. Production and development use separate properties under the same consent rules.
GA4 user/event retention is set to 14 months, with reset on new activity disabled, to assess seasonal patterns and compare corresponding periods in the previous year. This is the longest option for a standard GA4 property, not a general limit imposed by EU law: retention must remain proportionate to the purpose. Google deletes expired data on its periodic cycle. Standard aggregated reports are not subject to this setting and may remain available longer; this does not automatically make underlying data anonymous.
Analytics cookies last 180 days without automatic renewal; the consent preference lasts six calendar months. Before acceptance, after refusal or withdrawal, we do not load the tag or send analytics requests to Google, and we do not collect events to replay later. You can change your choice through the cookie settings in the footer. Withdrawal stops new collection and removes analytics cookies managed by this site; contact info@siti.gratis to exercise rights over data already processed.
After Analytics consent, the main Google tag loader and GA4 event requests pass through /metrics/ on our website’s domain via Google Tag Gateway on Cloudflare and are forwarded to Google. Forwarding uses technical request information, including the visitor’s IP address and approximate geographic data from Cloudflare when available. The Google tag loaded after consent may also send individual health-check requests directly to Google domains. The gateway does not change your consent choices; Google Ads measurement still requires separate permission.
Security and decisions
Controls include role-based access, access protection, a second factor for protected actions, HTTPS and backups. No measure eliminates every risk: report suspected compromise without emailing secrets. We do not make solely automated decisions producing legal or similarly significant effects. Anti-bot checks protect forms; they are not an automated creditworthiness assessment.
Your rights
Where GDPR Articles 15–22 apply, you may request access, correction, erasure, restriction and portability; object on grounds relating to your circumstances to legitimate-interest processing and always to direct marketing; and withdraw consent without affecting earlier lawful processing. Portability concerns automated processing based on consent or your contract, not other people’s information. Erasure and objection do not remove legal retention duties or necessary legal-claim evidence.
Requests and complaints
Email info@siti.gratis with your request and the address you used. We verify identity proportionately: do not send full identity documents unprompted. We normally respond within one month; complex requests may take up to two additional months, with reasons provided within the first month. Requests are normally free, subject to GDPR exceptions.
You may complain to Italy’s Garante or the competent authority where you habitually reside, work or consider an infringement occurred, and seek a judicial remedy. Contacting us first may help but is not a condition for complaining.
Updates
The date and version identify this notice. Material changes to purposes, providers or processing conditions will be communicated appropriately, and new consent requested where necessary. A revised notice does not retrospectively legitimise processing incompatible with earlier information.
AI assistant: messages, search and voice
Updated 11 October 2026. The optional siti.gratis AI assistant is provided by Wake Up Italy SRL. Replies and public research are enabled by your separate consent when starting AI (GDPR Article 6(1)(a)). You can withdraw it in chat settings: new AI requests stop, but the saved conversation is not automatically erased. Browsing and manual applications remain available without AI; this consent does not include marketing or analytics.
OpenAI receives messages, relevant conversation context, selected application fields and authorized materials to prepare replies and unverified drafts. To help on the current page, the server may automatically supply bounded context you are authorized to view: application and project stages, recent support ticket messages, excerpts from material requests, instructions, return reasons and saved responses, file names and sizes, and order financial summaries (amounts, due dates and payment status). Permissions are checked on every request. This is not a full page or account snapshot; file contents, full contracts and payment card details are not read automatically. Public search through OpenAI and Serper (Google results) uses only a public business name, city and public URLs, not the entire private conversation, other form fields or files. Retrieved public pages may be read and supplied as AI context; the source website receives a technical request.
Voice starts only after separate confirmation and browser microphone permission. Audio is sent to OpenAI for the conversation; siti.gratis does not store a conversation audio recording. Recognized questions sent for reply preparation become chat messages; this is not a complete call transcript. Minimizing the mini-chat, ordinary internal navigation, language changes and signing in without reloading the document keep the call active with a visible microphone indicator and stop control. An inactivity warning appears after 30 seconds; the call ends after 60 seconds. The stop control, a reload, navigation to another document or hiding the tab ends the voice session. Signing out or switching users also ends the session to protect data.
History and unverified drafts stay in this browser for up to 30 days after the last change, if local storage is available; there is no cross-device synchronization. Clear chat and draft removes this local copy. Public company research saved separately for an application for up to 30 days has a separate deletion control. Clearing local chat does not erase all technical logs or provider records. Service records may be retained for security and request processing; the linked provider terms also apply. We do not promise zero provider retention or exclusively EU processing; see the international transfers section.
Do not send passwords, login codes, payment secrets or sensitive personal data. Check found details and completed fields: AI can make mistakes. Chat can help save an application only after data review, separate mandatory confirmations and your explicit command. Sending it for review still requires signing in and linking it to a company. Confirming details does not replace declarations; the assistant does not sign contracts or pay orders. For processing, withdrawal, access, correction, erasure and other rights: info@siti.gratis.
To help with a questionnaire, AI may receive saved business and project answers you are authorized to view, current values from the open form and relevant conversation context. This includes submitted questionnaires available in read-only mode; permission to read answers does not grant permission to change them. Current manual changes take precedence over saved values. The amount of fields and text sent is bounded: it may not include the entire questionnaire, and omitted answers are not treated as empty. The server may also supply a bounded summary of order stages you are authorized to access: current status, next step, actions permitted in the interface and labels of missing or invalid fields. Permissions are checked on each request. This does not authorize automatic access to passwords, login codes or payment secrets; do not put them in fields or chat. Full contracts, files, payment card details and all account contents are not uploaded automatically. The private questionnaire continuation stays only in this browser tab’s session storage, if available, and is restored after reloading or navigation only for the verified account and the same login session. Clearing chat, signing out or switching users removes this copy. It is not added to the public chat history retained for 30 days or the optional quality journal. Saving and submitting the questionnaire itself are separate actions. Ordinary conversations about basic order status in the signed-in account, without questionnaire answers, retain the current user’s local history and optional quality journal settings described above.
To prevent assistant abuse, the technical cookie __Host-sg_ai_budget stores a random signed identifier for up to 30 days, renewed when access is verified. It contains no conversation and is inaccessible to JavaScript. The server separately records AI operation costs and times, technical account or guest identifiers and a protected guest-network identifier, without raw IP addresses, messages or audio. Limits cover the last 24 hours; guests on the same network share a network allowance. Signing in links guest spending to the account; signing out or clearing chat does not reset accounting. Uncertain costs stay reserved until reconciliation. This technical security ledger is separate from the optional conversation journal and is not automatically deleted at that journal’s 90-day expiry. Data enquiries: info@siti.gratis. Confirmed cost records within their reservation are cleaned up after 30 days. Uncertain costs and overruns remain until reconciliation; the technical guest-to-account link remains while needed to enforce spending limits. This cleanup is separate from the conversation journal.
Optional assistant quality journal
The optional Analytics choice in Cookie settings allows Wake Up Italy SRL to save new text messages and available voice transcripts for quality review (consent, GDPR Article 6(1)(a)), together with Google Analytics 4 and the internal public text assistant comparison. Administrators use records for analysis, tests, knowledge and instruction improvements. Refusing does not restrict chat, search or voice. Old history is not uploaded retrospectively. No audio recording or automatic model training; transcripts may be inaccurate or incomplete and prepared replies may differ from what was spoken.
The journal is kept in private Cloudflare storage, outside ordinary application backups. Recording and administrator access end 90 days after the journal is created; new messages do not extend that period. Expired journals are removed by scheduled cleanup, so physical deletion need not occur at the exact moment of expiry. Authorized administrators with two-factor verification can access it. Records include messages, channel, language, time, knowledge version and technical quality markers, not files, audio or a full form snapshot. Recognizable secret patterns and some personal data are masked before storage; this is not a guarantee of full anonymity. Do not share confidential information.
Withdrawing Analytics stops collection immediately and requests deletion of the current user’s accessible journal text. Deletion remains pending until confirmed and is retried on return or reconnection; you can also retry it in chat. A minimal revocation marker without conversation text may remain until scheduled cleanup after the original expiry to prevent late requests restoring deleted content. Missing or expired Analytics consent stops recording without itself deleting existing journals. Journal deletion does not delete applications or local chat history. For access, erasure and other rights: info@siti.gratis.
The browser’s Analytics choice lasts six months. Each journal and access key expire within the original 90 days from activation; new messages do not extend the period. Recording stops at expiry with no automatic renewal. A new journal needs a new explicit acceptance of Analytics in Cookie settings. Earlier analytics grants do not cover this combined scope; valid refusals retain their original expiry. The separate AI service consent remains in chat. Private questionnaire continuations are excluded from this journal.
Google Ads measurement
The separate optional Google Ads measurement choice lets Wake Up Italy SRL assess which advertising visits lead to an actually submitted application, using Google Ads and the GA4 generate_lead event (consent, GDPR Article 6(1)(a)). It requires Analytics because the conversion is measured through GA4. Analytics without this additional choice does not grant advertising measurement. The site prepares this consent-controlled integration; conversion sharing starts only after Google Ads account setup and the GA4 link are completed. Draft creation and assistant activity are not advertising conversions.
With both choices enabled, consent signals permit advertising storage and advertising measurement data (ad_storage and ad_user_data). Advertising click information, validated campaign labels, pseudonymous browser/session identifiers and the submission event may support attribution. ad_personalization always remains denied: no personalised advertising, remarketing, Google Signals, User-ID or enhanced conversions. We do not send names, email addresses, phone numbers, application answers, chat contents, voice transcripts or audio to Google. The separate quality journal remains on our service as described above, not in Google Analytics or Google Ads.
You can withdraw Ads measurement alone in Cookie settings; withdrawing Analytics also turns off Ads measurement. The choices expire after six calendar months. Withdrawal stops subsequent use under these choices and does not automatically erase data already processed by Google. For information about recipients, international transfers, retention or your rights, use the relevant sections of this notice or contact info@siti.gratis.
Optional text assistant variant comparison
On siti.gratis, this consent also allows internal comparison of public text assistant variants and their link to saved, submitted and approved applications. Refusing does not restrict the assistant.
After access verification and renewed consent, we may randomly assign a first-contact and next-step variant. This tab stores a random key; a private database stores variant, language, milestone times and a technical application link, not chat or form contents. These are pseudonymous, not anonymous data. The analysis window is 90 days without renewal; expired rows are excluded from reports and removed by scheduled cleanup. Administrators see totals; submission and approval come from server events, not AI answers. The link and application outcome are not sent to Google Analytics. Withdrawal stops collection and requests deletion of the accessible link in this tab; a network error does not count as confirmed deletion. Other requests: info@siti.gratis. Existing applications and contracts are unchanged. The unified Analytics choice also controls the quality journal described in its own section; withdrawal requests its deletion for the current user. Earlier analytics grants do not cover the new scope; valid refusals remain respected. The comparison covers public text conversation only, not voice or private account workflows; results do not prove increased sales. The variant covers the first contact in the current guest session, not the customer's full history. Participation keys are not restored after reload or account sign-in. A separate deletion-only key remains in this tab until the original 90-day expiry and cannot continue tracking. Failed deletion requests are retried when returning to the app or reconnecting.