Privacy notice

The controller for the personal data described here is Adriano Foschi, in Italy, acting as an individual: Palumb is not incorporated as a company yet, and we would rather say so than leave the question open. You can reach the controller at privacy@palumb.com.

This notice covers palumb.com, the website. It does not describe the notification platform itself: that gets its own documentation and data processing agreement when the service becomes generally available.

If you join the waitlist, we collect one thing: the email address you type in. The form asks for nothing else: no name, no company, no job title. If you write to us through the contact form, we collect what you type there: your name, your email address and your message, and nothing besides.

That is the entire set. For visitor numbers we use Simple Analytics, a Dutch company that keeps the data in the Netherlands: it is cookieless, stores no identifier for you and cannot follow you to another site, so there is no consent banner to click and no advertising pixel anywhere here. If you never submit the form, nothing about you is collected beyond those aggregate page counts and the ordinary server logs kept to serve the page.

We use your email for exactly one purpose: to contact you about access to the Palumb beta. The legal basis is your consent (Art. 6(1)(a) GDPR), given by ticking the box on the form. A message sent through the contact form is used to answer you and for nothing else; the basis there is our legitimate interest in replying to someone who wrote to us (Art. 6(1)(f) GDPR), and writing to us does not put you on the waitlist.

We will not add you to a newsletter, we will not send you unrelated marketing, and we will not sell, rent or share your details with anyone for their own purposes.

The waitlist is held by Brevo (Sendinblue SAS), a French company in Paris, which stores your submission on our behalf under a data processing agreement and sends the beta invitation when your turn comes. Contact-form messages are received by Formward (EGF Fastighetsservice AB), a Swedish company in Stockholm, which stores them in Sweden and forwards them to our mailbox, also under a data processing agreement. The site itself is served as static files by BunnyWay d.o.o. (bunny.net), a Slovenian company, and our mailboxes are hosted by IONOS SE in Germany.

We name every one of them, along with the company that ultimately owns it, on our sub-processors page, rather than hide them behind a generic phrase about 'trusted partners'.

Until the beta programme ends, or until you ask us to delete it, whichever comes first. If we contact you and you tell us you are not interested, we delete your record then and there rather than keeping it for a future campaign. A message you send through the contact form is kept while we are dealing with it and for as long as the exchange is useful to either of us, then deleted.

You can ask us for a copy of what we hold about you, correct it, delete it, restrict or object to our processing, or receive it in a portable format. You can withdraw your consent at any time, which does not affect processing carried out before you withdrew it.

Write to privacy@palumb.com and we will act on it. You also have the right to lodge a complaint with the data protection authority of the country you live in.

We do not transfer waitlist data outside the European Union. If that ever has to change, we will say so here before it happens, not after.