Privacy Policy

Last updated: October 2026

This notice describes how the personal data of users who visit the en.toitrack.com website and submit a request through the contact form is processed, pursuant to Regulation (EU) 2016/679 (the “GDPR”).

Data controller

The data controller is 3C di Cruoglio Pasqualina, registered office at Via Donato Vestuti, 15 – 84025 Eboli (SA) – Italia, VAT no. 06429210658. For any privacy-related request, you can write to info@toitrack.com.

What data we collect

Data provided voluntarily through the contact form: company name, the contact person’s first and last name, email address, phone number (optional) and any message.
Technical data from browsing, required for the operation and security of the site (e.g. IP address), processed for strictly the time necessary.
Anonymous aggregate statistics collected without cookies or identifiers: visited page, language, referring domain and campaign parameters (UTM). They cannot identify you.

Purposes and legal basis

Responding to contact, demo and quote requests (legal basis: pre-contractual measures at the data subject’s request, art. 6.1.b GDPR).
Ensuring the security of the site and preventing abuse of the form, including through Google reCAPTCHA (legal basis: legitimate interest, art. 6.1.f GDPR).
Measuring visits to the site with Google Analytics 4, only if you accept analytics cookies (legal basis: consent, art. 6.1.a GDPR).

Retention

Contact data is retained for as long as necessary to handle the request and any resulting relationships, and in any case no longer than the fifth anniversary of the last use of the platform or the last active interaction with the data controller, except for the different periods required by tax and accounting legal obligations.

Sharing of data

Data may be processed by service providers (hosting on European infrastructure, email) appointed as data processors, and by Google to protect the contact form (reCAPTCHA) and, only with your consent, for visit statistics (Google Analytics 4): Google may process data outside the European Economic Area; transfers rely on the EU-US Data Privacy Framework and/or the Standard Contractual Clauses, as declared by Google. Data is neither disclosed publicly nor transferred to third parties for marketing purposes.

Providers' official information on data transfers: Google: data transfer frameworks

Platform emails and open statistics

The service emails Toitrack sends during the free trial (welcome, onboarding, reminders) may contain an invisible 1×1 pixel image and links that go through one of our redirect addresses. They tell us whether the email was delivered and read and whether links were clicked, so we can improve onboarding and notice when a trial needs help. We only record a signed identifier of the send, the date and time of the first open and the number of opens and, for links, the date and time of the click (clicked_at) and the number of clicks: we do not record IP address, browser or location. The signal is an indication, not a certainty (some mail clients load images automatically or block them). Legal basis: legitimate interest (art. 6.1.f GDPR) in verifying delivery and effectiveness of service communications tied to an ongoing pre-contractual relationship. Open data is kept for the same period as the email send log. How to opt out: block image loading in your mail client, or write to info@toitrack.com to object (art. 21 GDPR); objections are handled on request by email (art. 21 GDPR) and processed manually. We do not use this data for profiling or promotional mailings.

Platform emails and open statistics

Data subject rights

Users may exercise at any time the rights provided for by arts. 15-22 GDPR (access, rectification, erasure, restriction, objection and portability) by writing to info@toitrack.com. You may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).