Privacy Policy

ProntoItaliano LTD — UK GDPR · Last updated: [Insert date]

1. Introduction

ProntoItaliano LTD is committed to protecting your personal data in accordance with UK GDPR and the Data Protection Act 2018.

2. Data Controller

ProntoItaliano LTD

Company No: [Insert]

Address: [Insert]

Email: [Insert]

3. Payment Processing

We use Paddle.com Market Ltd as Merchant of Record. This means: Paddle is the seller of record for transactions. Paddle processes payments, VAT, invoicing, and refunds. Paddle may collect and process your billing data independently as a separate data controller. See their Privacy Statement at paddle.com/legal/privacy.

4. Data we collect

Name and email address
Account login details
Usage data (platform activity)
Communications (support messages)
Limited billing metadata (order reference, subscription status)

We do not store full payment card details.

5. How we use data

We use personal data to:

Provide access to services
Manage accounts
Deliver learning content
Provide customer support
Maintain platform security
Comply with legal obligations

6. Legal bases

Contract (service provision), Consent (marketing), Legitimate interests (service improvement), Legal obligation.

7. We may share data with:

Paddle (payments & billing)
Hosting providers
Analytics providers
Email service providers

We do not sell personal data.

8. International transfers

Where data is transferred outside the UK, appropriate safeguards (e.g. SCCs) are applied.

9. Data retention

Account data: active use + reasonable retention
Transaction records: managed by Paddle + legal retention
Support data: up to 24 months

10. Your rights

You have rights under UK GDPR including access, rectification, erasure, restriction, objection, and portability.

Contact: [Insert email]