PRIVACY POLICY

Effective Date: August 25, 2025

This Privacy Policy describes how Sagewill SRL ("we," "us," or "our") collects, uses, and protects information when you visit the Palpaca website at palpaca.app ("Website"). This policy applies only to the Website and not to the Palpaca application itself.

1. INFORMATION WE COLLECT

1.1 Information You Provide

When you interact with our Website, you may provide:

Email address (when joining the waitlist)
Name and company information (optional)
Any information submitted through contact forms

1.2 Information Automatically Collected

We use HubSpot tracking code to collect:

IP address
Browser type and version
Device information
Pages visited and time spent
Referring website
Geographic location (country/city level)

1.3 Cookies and Tracking Technologies

Our Website uses cookies through HubSpot's tracking system:

HubSpot Cookies:

__hssc: Session cookie that keeps track of sessions (expires after 30 minutes)
__hssrc: Used to determine if the visitor has restarted their browser (session cookie)
__hstc: Main cookie for tracking visitors (expires after 13 months)
hubspotutk: Used to keep track of a visitor's identity (expires after 13 months)
__cf_bm: Cloudflare bot management cookie (expires after 30 minutes)

These cookies help us:

Understand Website usage patterns
Improve user experience
Track marketing campaign effectiveness
Remember your preferences

2. HOW WE USE YOUR INFORMATION

We use collected information to:

Send you updates about Palpaca (if you join the waitlist)
Respond to your inquiries
Analyze Website performance and user behavior
Improve our Website and services
Send relevant marketing communications (with your consent)

3. DATA STORAGE AND LOCATION

All marketing data collected through the Website is:

Stored in EU data centers
Maintained in an isolated HubSpot instance
Limited to email addresses for marketing purposes
Not combined with any customer CRM data

4. THIRD-PARTY SERVICES

4.1 HubSpot

We use HubSpot for:

Website analytics
Contact management
Email marketing
Form submissions

HubSpot's privacy policy: https://legal.hubspot.com/privacy-policy

4.2 No Other Third Parties

We do not use:

Third-party advertising networks
Social media tracking pixels
Other analytics tools beyond HubSpot
Retargeting or behavioral advertising services

5. DATA SHARING

We do not sell, rent, or trade your personal information. We may share information only:

With your explicit consent
To comply with legal obligations
To protect our rights and safety
With service providers under confidentiality agreements (currently only HubSpot)

6. YOUR RIGHTS

Under GDPR, you have the right to:

Access your personal data
Correct inaccurate data
Request data deletion
Object to data processing
Data portability
Withdraw consent at any time

To exercise these rights, contact us at arrigo@palpaca.app.

7. DATA RETENTION

We retain:

Historic website analytics data
Waitlist emails until you unsubscribe or request deletion
Contact form submissions for as long as necessary to fulfill the purpose

8. SECURITY

We implement appropriate technical and organizational measures to protect your information, including:

Encrypted data transmission (HTTPS)
Access controls
Regular security assessments
Secure data center facilities (via HubSpot)

9. CHILDREN'S PRIVACY

Our Website is not intended for children under 16. We do not knowingly collect information from children under 16.

10. INTERNATIONAL TRANSFERS

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for such transfers in compliance with GDPR.

11. MARKETING COMMUNICATIONS

11.1 Opt-In

By joining our waitlist, you consent to receive marketing communications about Palpaca.

11.2 Opt-Out

You can unsubscribe from marketing emails:

Using the unsubscribe link in any email
Contacting us at arrigo@palpaca.app

12. DO NOT TRACK

Our Website respects Do Not Track browser signals.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. We will notify you of material changes by:

Posting the new policy on the Website
Updating the "Effective Date"
Sending email notification (for substantial changes)

14. LEGAL BASIS FOR PROCESSING

We process your data based on:

Consent (for marketing communications)
Legitimate interests (for analytics and Website improvement)
Legal obligations (when required by law)

15. DATA PROTECTION OFFICER

For privacy concerns, contact our data protection team:

Email: sagewillsrl@legalmail.it

Address: Sagewill SRL, Via Panciatichi 16, 50141, Firenze (FI), Italy

16. SUPERVISORY AUTHORITY

You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or your local supervisory authority.

17. COOKIE MANAGEMENT

You can control cookies through:

Browser settings
Our cookie banner (when implemented)
Contacting us to opt-out of tracking

Note that disabling cookies may affect Website functionality.

18. CONTACT INFORMATION

For questions about this Privacy Policy or our privacy practices:

Sagewill SRL

Via Panciatichi 16

50141, Firenze (FI), Italy

Email: sagewillsrl@legalmail.it

VAT: IT07481150485

By using our Website, you acknowledge that you have read and understood this Privacy Policy.