Privacy and Cookie Policy
Data Controller Nicoletta De Vincenzi, trading as EMKTG LAB Via Ricasoli 19, 00185 Rome (RM), Italy VAT No. IT17077981003 Email: info@emktglab.com
Last updated: 20 July 2026
1. Introduction
This Privacy and Cookie Policy describes how Nicoletta De Vincenzi, trading as EMKTG LAB (hereinafter the "Controller"), collects, uses and protects the personal data of users who visit the website emktglab.com (hereinafter the "Site") or use the services offered.
Data processing is carried out in compliance with Regulation (EU) 2016/679 (GDPR) and applicable Italian data protection legislation.
The Controller maintains a record of processing activities where required by applicable law.
2. Data collected and purposes of processing
2.1 Navigation data
When you visit the Site, our systems automatically collect certain technical data: IP addresses, browser type, operating system, pages visited, access times. These data are processed to ensure the security, integrity and proper functioning of the Site and to obtain aggregate technical statistics. They are deleted within 90 days.
Legal basis: Legitimate interest of the Controller (Art. 6(1)(f) GDPR).
2.2 Contact form
When you fill in the contact form, we collect the data you provide (name, email address, company name and message). The data are used to respond to your enquiry or consultation request.
Legal basis: Pre-contractual measures taken at the request of the data subject (Art. 6(1)(b) GDPR).
Provision of data: Fields marked as mandatory are necessary to process the request. Failure to provide them may prevent us from responding to the enquiry.
2.3 Newsletter subscription
When you subscribe to the newsletter, we collect your name and email address. The data are used to send commercial communications relating to EMKTG LAB services.
We may use technologies that allow us to measure engagement and improve the relevance and effectiveness of our communications (such as open rates and link clicks).
Legal basis: Consent of the data subject (Art. 6(1)(a) GDPR). Consent may be withdrawn at any time by writing to info@emktglab.com or clicking the unsubscribe link in any email.
Retention: Until consent is withdrawn and, in any event, subject to periodic verification of continued interest and data accuracy.
Provision of data: Newsletter subscription is always optional.
2.4 AI Decision Readiness Assessment™
When you use the AI Decision Readiness Assessment™, we collect the information entered in the form and the answers provided during the Assessment, which may include your name, business email address, company name, business sector and organisation size.
The data are processed to calculate the Assessment score, generate and provide the personalised report and, where requested by you, follow up on the results or arrange an Executive Discovery Session.
Assessment responses may also be used in aggregated or anonymised form to improve the diagnostic methodology and develop non-identifying benchmarks. No benchmark will identify any individual or organisation.
The Assessment applies predefined scoring rules to the answers provided. It does not make decisions producing legal or similarly significant effects on the data subject within the meaning of Art. 22 GDPR. Its results are indicative and do not replace an in-depth strategic, legal or technical assessment. The Assessment is intended to support organisational self-assessment and should not be interpreted as legal, financial or technical advice.
Legal basis: Performance of a service requested by the data subject and steps taken at the data subject's request prior to entering into a contract (Art. 6(1)(b) GDPR). Any optional newsletter subscription or separate promotional communication is based on consent (Art. 6(1)(a) GDPR).
Provision of data: Mandatory fields are necessary to generate and deliver the report. Failure to provide them will prevent completion of the Assessment. Marketing consent is optional and does not affect access to the report.
2.5 Session bookings
When you book an Executive Discovery Session via Google Appointment Scheduling, data processing is governed by Google LLC's Privacy Policy. The Controller only accesses the information necessary for appointment management.
Source of personal data: Unless otherwise stated, personal data are collected directly from the data subject.
3. Recipients of data
Personal data may be shared with:
- Brevo SAS (Sendinblue) — email marketing service provider, headquartered in France. Processing governed by a GDPR-compliant DPA.
- Google LLC — provider of Google Analytics 4, Google Tag Manager and Google Appointment Scheduling. Processing governed by a GDPR-compliant DPA.
- Microsoft Corporation — provider of Microsoft Clarity for user behaviour analysis.
Personal data may also be processed by authorised personnel and by hosting, website management, IT, professional or technical service providers acting as processors under Art. 28 GDPR.
An updated list of processors may be requested from the Controller at info@emktglab.com.
Data are not sold to third parties or shared for third-party marketing purposes.
4. International data transfers
Some providers (Google LLC, Microsoft Corporation) are based in the United States. Transfers are carried out in compliance with the safeguards required by the GDPR, in particular through Standard Contractual Clauses (SCCs) approved by the European Commission and, where applicable, the EU-US Data Privacy Framework.
5. Retention periods
| Data type | Retention period |
|---|---|
| Navigation data | 90 days |
| Newsletter subscribers | Until consent is withdrawn, subject to periodic review |
| Contact requests | 24 months from receipt |
| Assessment data | 24 months from completion |
6. Your rights
Under Arts. 15–22 of the GDPR, you have the right to:
- Access — obtain confirmation of processing and a copy of your data
- Rectification — correct inaccurate or incomplete data
- Erasure — request deletion of your data ("right to be forgotten")
- Restriction — request restriction of processing
- Data portability — receive your data in a structured, machine-readable format
- Objection — object to processing based on legitimate interest
- Direct marketing objection — where personal data are processed for direct marketing purposes, you have the right to object at any time, without giving reasons
- Withdrawal of consent — withdraw consent at any time
To exercise your rights, please write to: info@emktglab.com
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) or with the supervisory authority of your country of residence.
7. Cookie Policy
7.1 What are cookies
Cookies are small text files that websites save on a user's device during browsing. They are used to make the site work, improve the user experience and collect statistical information.
7.2 Cookies used by this Site
Technical cookies (necessary) Required for the correct functioning of the site. Do not require consent.
| Name | Purpose | Duration |
|---|---|---|
cookie_consent | Stores the user's cookie preferences | 12 months |
Analytics cookies (require consent)
| Provider | Cookies | Purpose | Duration |
|---|---|---|---|
| Google Analytics 4 | _ga, _ga_* | Statistical analysis of visits (when activated following consent) | 2 years (default) |
| Microsoft Clarity | _clck, _clsk, CLID and related identifiers | Heatmaps, session recordings and website usage analysis | According to the provider's current settings and the configuration applied on the Site |
Note: Google Tag Manager is a tag management tool and does not set its own cookies directly. Analytics cookies are activated through GTM only upon user consent.
7.3 Consent management
On your first visit to the Site, a banner is displayed allowing you to accept or reject non-essential cookies. Preferences can be changed at any time by clicking "Manage cookie preferences" in the Site footer.
By default, analytics and advertising storage are set to denied. Non-essential cookies are not stored unless the user provides consent. Depending on the Consent Mode configuration, limited cookieless signals may be transmitted to Google for basic measurement and modelling purposes.
7.4 How to disable cookies
You can also disable cookies through your browser settings:
- Google Chrome: support.google.com/chrome/answer/95647
- Mozilla Firefox: support.mozilla.org
- Safari: support.apple.com
- Microsoft Edge: support.microsoft.com
8. Security
The Controller implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction or disclosure. The Site uses the HTTPS protocol for secure data transmission.
9. Changes to this Policy
The Controller reserves the right to modify this Privacy and Cookie Policy at any time. Changes will be published on this page with the date of the update. In the event of material changes, subscribed users will be notified by email.
10. Contact
For any questions regarding the processing of personal data:
Nicoletta De Vincenzi, trading as EMKTG LAB Via Ricasoli 19, 00185 Rome (RM), Italy VAT No. IT17077981003 Email: info@emktglab.com
Responsible AI Statement
EMKTG LAB believes that artificial intelligence should support, not replace, human judgement. Our AI-powered tools are designed to assist decision-making while preserving meaningful human oversight, transparency and accountability.