Privacy and cookie notice

Last updated: 23/10/2026

1. Who handles your data

The data controller is Domenico Palomba, trading as Firmitas (Italian VAT no. 14247940969). For any question about your data, write to dom@firmitascoaching.com.

2. What data, why, and for how long

Contact form and email

Your name, email, area (if you give it) and your message. I use them to reply to your enquiry and, if you wish, to set up a training programme. Legal basis: steps taken at your request before a contract (Art. 6(1)(b) GDPR). I don't use them for newsletters or advertising.

Booking a call

If you book a call, Calendly collects on my behalf your name, email, the date and time you choose and any answers you give. I use them to arrange and hold the call. Legal basis: Art. 6(1)(b) GDPR.

If you become a client

I process the data needed for invoicing to meet my tax obligations (Art. 6(1)(c) GDPR) and keep it for the period required by Italian law (usually 10 years).

Ad measurement (only with your consent)

If you accept measurement cookies, the site loads the Google Ads tag to find out whether a visit that came from an ad ends with the form being sent or a call being booked. Legal basis: your consent (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code), which you can withdraw at any time from "Cookie preferences". Google acts as an independent controller for this data: Google's privacy policy.

Technical browsing data

Like any website, the host (Netlify) records technical data such as your IP address and the pages requested, to run the site and protect it from abuse. Legal basis: legitimate interest in keeping the site secure (Art. 6(1)(f) GDPR).

How long

Messages and bookings: for as long as needed to handle your enquiry. If no working relationship follows, I delete them at the latest 24 months after our last contact. If you become a client, I keep them for the length of our working relationship and then for the periods required by law.

3. Who receives the data

I don't sell or pass on your data. These providers process it on my behalf, only for the services listed:

• Netlify, Inc. (USA): website hosting and form collection.
• Calendly LLC (USA): call bookings.
• Zoho: the dom@firmitascoaching.com mailbox.
• Google Ireland Ltd: ad measurement, only with your consent.
• My accountant, only if you become a client and for tax purposes.

Some of these providers are based in the United States or may process data there. In those cases the transfer relies on the EU–US adequacy decision (Data Privacy Framework), for companies that have joined it, or on the standard contractual clauses approved by the European Commission.

4. Your rights

You can ask at any time for access to your data, or for it to be corrected, deleted, restricted or transferred, and you can object to processing based on legitimate interest. You can withdraw your cookie consent at any time; this does not affect processing already carried out. Write to dom@firmitascoaching.com. You also have the right to complain to the Italian Data Protection Authority, the Garante per la protezione dei dati personali.

Giving your data is optional, but without a name and email I can't reply to you. I make no automated decisions about your data.

5. Cookies

On your first visit a banner asks whether you accept measurement cookies. You can accept, reject, or close the banner with the X: in the last two cases only technical cookies stay active. The site does not use Google Analytics, does not use cookies for personalised advertising and does not load fonts from external servers.

With your consent Google may also set its own cookies on its domains: list of Google cookies. If you open the booking window, the calendar is loaded by Calendly, which shows you its own cookie notice and manages those cookies directly: Calendly cookie notice.