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Privacy Policy

Effective Date: January 22, 2026

Welcome to the website of Avatar Investments S.r.l. (“Avatar,” “we,” “us,” or “our”), an engineering and transformation consulting firm based in Milan, Italy. This Privacy Policy (“Policy”) explains how we collect, use, disclose, and safeguard personal data when you visit https://avatar-investments.com/ (the “Site”).

By accessing or using the Site, you acknowledge that you have read and understood this Policy. If you do not agree, please do not use the Site.

1. Data Controller

For the purposes of Regulation (EU) 2016/679 (“GDPR”), the data controller is:

Avatar Investments S.r.l.
Milan, Italy
Email: info@avatar-investments.com

2. Personal Data We Collect

a. Information You Provide

We collect personal data that you voluntarily provide, including:

  • Name and surname
  • Email address
  • Phone number
  • Company name and job title
  • Professional or business-related information
  • Content of messages submitted through contact forms or inquiries

We do not intentionally collect sensitive personal data unless required and explicitly provided by you.

b. Information Collected Automatically

When you access the Site, we may automatically collect:

  • IP address
  • Browser type and version
  • Operating system
  • Device identifiers
  • Referring URLs
  • Pages viewed and interactions with the Site
  • Date and time of access
  • Approximate geographic location (derived from IP address)

c. Information from Third Parties

We may receive limited information from service providers or business partners acting on our behalf, in compliance with applicable law.

3. Purposes and Legal Bases for Processing

We process personal data for the following purposes and legal bases:

PurposeLegal Basis (GDPR Art. 6)Responding to inquiries and requestsLegitimate interestProviding consulting-related communicationsPre-contractual measures / ContractOperating and improving the SiteLegitimate interestSecurity, fraud prevention, and system monitoringLegitimate interest / Legal obligationCompliance with legal and regulatory requirementsLegal obligationAnalytics (aggregated or anonymized where possible)Legitimate interest

Where required, we will obtain your consent before processing.

4. Cookies and Similar Technologies

We use cookies and similar technologies to:

  • Enable core Site functionality
  • Remember user preferences
  • Analyze Site usage and performance

You can manage cookies through your browser settings. Disabling cookies may affect certain Site features.

Where required by law, cookie consent is obtained via a cookie banner.

5. Data Sharing

We may share personal data:

  • With trusted service providers acting as data processors
  • With professional advisors (legal, accounting, IT)
  • In connection with corporate transactions (e.g., merger, reorganization)
  • When required by law or public authorities
  • To protect the rights, property, or safety of Avatar Investments or others

We do not sell personal data or use it for cross-context behavioral advertising.

6. International Data Transfers

Personal data may be transferred outside the European Economic Area (EEA). When this occurs, we ensure appropriate safeguards are in place, such as:

  • Adequacy decisions by the European Commission
  • Standard Contractual Clauses (SCCs)
  • Other lawful transfer mechanisms under GDPR

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required by law or professional obligations.

8. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure. Despite these measures, no system can be guaranteed to be completely secure.

9. Your Rights (GDPR)

You have the right to:

  • Access your personal data
  • Rectify inaccurate or incomplete data
  • Request erasure (“right to be forgotten”)
  • Restrict or object to processing
  • Data portability
  • Withdraw consent at any time (where applicable)
  • Lodge a complaint with a supervisory authority

Requests can be submitted using the contact details below.

10. Children’s Privacy

The Site is not intended for children under the age of 16. We do not knowingly collect personal data from minors.

11. Third-Party Links

The Site may contain links to third-party websites or services. We are not responsible for their content, privacy policies, or practices.

12. Changes to This Policy

We may update this Policy periodically. The most current version will always be available on the Site with the effective date indicated above.

13. Contact Us

For questions or requests regarding this Policy or your personal data:

Email: info@avatar-investments.com
Address: Milan, Italy

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