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PRIVACY POLICY

Your presence is sacred.
We protect your data as we guard the rhythm of the night — safe, unseen, untouchable.

1: INTRODUCTION

This notice aims to explain who processes the data of the data subject (also referred to as the User), how it is processed, what data is involved, and what rights the User has and how they can exercise them. For specific clarifications, where the User does not understand or does not consider the information provided in this policy sufficient, they are invited to write to the following address: info@nikita.land

2: SOME IMPORTANT CONCEPTS ABOUT PERSONAL DATA

What is meant by personal data?

Personal data includes all information that refers to an identifiable natural person. An email address is personal data. The text of a message, if it reveals information about a person, is personal data. A nickname is personal data, and so on.

What does it mean to process data?

The legal definition of processing includes any operation or set of operations concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, deletion, and destruction of data. Practically speaking, everything that can be done with the user's data constitutes processing. Even collecting or reading data, that is, consulting it, is already considered processing.

Why is it important for the data subject?

Data reveals who the data subject is and what they do. It belongs to them, and precisely because it is “theirs,” it is important. It is also clear that since it is “theirs,” the data subject has the right to decide whether to allow third parties — including this website — to process it, and to know how such processing is carried out.

Why is it important for the Data Controller?

It is important because it allows NIKITA CLUB S.R.L. to have information about the users.

3: WHO PROCESSES THE DATA

The Data Controllers are the entities that make decisions on how to process the data, such as what precautions to take to protect it, where to store it (servers or cloud, etc.), what data to request from the user, what data to process and for what purpose, which data to share and with whom, how to manage user relations and rights, who to appoint as collaborators, processors, or persons in charge of processing, and what instructions to give them, among other responsibilities.

Therefore, the Data Controllers are:

NIKITA CLUB S.R.L.
Registered office: VIA DEI MORENGHI 2, Telgate 24060 - BG
VAT No.: 04417070168 | Tax Code: 04417070168
Email: info@nikita.land
Tel: +39 335537734
Website: nikita.land

TRIANGLE CORPORATION S.R.L.
Registered office: Piazza Cavour 21, Rovato 25038 - BS
VAT No.: 04037090984 | Tax Code: 04037090984
Email: info@trngl.it
PEC: trianglecorp@pec.it
Tel: +39 3484440680
Website: trngl.it

The Controllers may rely on internal staff authorized to process the data (also called “persons in charge”) or on external entities, mostly as processors, independent controllers, or joint controllers, depending on the case.

3/a: WHO THE DATA IS DISCLOSED TO (OR WHO IS ALLOWED ACCESS)

The data is disclosed to internal personnel of the Controllers (employees or collaborators) involved in the operational and administrative management of the services. It may also be disclosed in compliance with legal obligations or at the request of competent authorities (e.g., Court, Tax Police, etc.). Furthermore, the data is shared with providers of hosting, software, and digital tools (including third-party cookies).

It is important to note that the Controllers — NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. — can only govern the data stored and processed within their systems. Data transferred or disclosed to third parties will be independently processed by them according to their own privacy policies. Should one of the Controllers cease processing, they will notify the third parties to whom the data has been disclosed, but cannot guarantee that such third parties will also cease processing.

4: WHERE THE DATA IS PROCESSED

Users' personal data is processed at the registered offices of NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L., as well as through cloud services located in member countries of the European Union.

5: WHAT DATA IS PROCESSED

Depending on their nature, the following categories of data can be identified: - Contact data: email, phone number; - Identification data: first name, last name, date of birth; - Content data: the content of communications sent by the User through the dedicated forms; - Browsing data.

6: PURPOSES OF DATA PROCESSING, LEGAL BASIS, AND RETENTION PERIOD

NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. process users' data for the following purposes:

Responding to user requests (information, exercising rights, etc.):

This includes responding to contacts made by the customer/user (via email or other forms of contact).
Legal basis: execution of the service requested by the user in the communication (such as exercising a right);
Retention period: ten years (obligation to retain commercial correspondence).
Data processed: contact, identification, and other data depending on the content of the request.

Creating subscriber databases:

NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. create a database (internal/external) of contacts received via forms on the website. The database is used for the following purposes:
A) as a backup copy of the addresses from which communications were received;
B) to send offers or other content via newsletters and/or SMS.
Legal basis:
A) legitimate interest of the controller in retaining contact data (considered prevalent over opposing interests as it ensures the availability of data to NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. while, given the low risk and significance of the data, it does not harm the user);
B) consent of the data subject expressed by ticking the box at the bottom of the subscription form (or by entering the email address in the designated field);
Retention period: A) until a deletion request is made (see section on exercising rights) by sending an email to info@nikita.land;
B) until consent is withdrawn;
Data processed: A) email, identification, content data; B) email, identification, content data.
Note: consent can always be revoked. The withdrawal of consent terminates the processing of data for the purpose for which it was granted.

Disclosure of data for third-party marketing purposes:

NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. may share user data with companies for their own marketing purposes. These companies — with a new privacy notice sent to the user within one month — will specify the methods and timing of contact and communication (see section on data disclosure).
Data processed: user profile (meaning identification, preference, professional, and contact data), contact data, preference or personal/professional data.
Legal basis: user consent.
Retention period: until consent is withdrawn.

Sending newsletters and/or SMS for own marketing purposes:

The user's email address is used to send periodic emails with operational and promotional content regarding services offered by NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L.
Data processed: contact data, and possibly preference or personal data where emails are targeted at a selected audience.
Legal basis: consent expressed during the subscription phase by entering the email address in the form.
Retention period: until unsubscribing from the newsletter and/or SMS service via the dedicated feature. Data will be retained afterward only to prove that consent was withdrawn.
Email frequency: variable;
Service provider for newsletters and/or SMS: Skebby

Informing about third-party products or services not managed by NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. (third-party marketing):

The content will still be included in emails that primarily provide information from NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. (products, events, etc.).
Legal basis: user consent during newsletter and/or SMS subscription, contract execution;
Retention period: until consent is withdrawn by the user. Data will be retained afterward only to prove that consent was withdrawn.
Data processed: email, first name, last name.
Email frequency: variable

Providing information about regulatory updates, new opportunities (e.g., grants), and new events:

Legal basis: user consent expressed unequivocally by subscribing to the service, contract execution;
Retention period: until consent is withdrawn by the user. Data will be retained afterward only to prove that consent was withdrawn.
Data processed: email, first name, last name.
Email frequency: variable

Sending creative content (articles written by NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. or its collaborators):

Legal basis: user consent, contract execution;
Retention period: until consent is withdrawn by the user. Data will be retained afterward only to prove that consent was withdrawn.
Data processed: email, first name, last name.
Email frequency: variable

User account activation and management:

Legal basis: execution of the user's request for account activation and management (contract execution);
Data processed: user profile (identification, preference, professional, and contact data), contact data, preference or personal/professional data.
Retention period: until account deletion, with data retained for up to three months after deletion to allow reactivation without data loss if requested by the user (and — in case of criminal acts — to allow the filing of a complaint).

Statistics:

Development of statistics based on user categories to optimize the Controller's business (e.g., evaluating areas of interest).
Legal basis: legitimate interest of the Controller in assessing market sectors of interest and the effectiveness of the sales system.
Retention period: statistics are generated in real time, but only aggregated and therefore anonymized data is retained.

Content download:

The service allows users to download content (files) and, for this purpose, collects user profile data (identification, preference, professional, and contact data).
Legal basis: execution of the content delivery service requested by the user.
Data processed: user profile (identification, preference, professional, and contact data), contact data, preference or personal/professional data.
Retention period: instantaneous with respect to the download.

7: HOW DATA IS PROVIDED

Data is provided directly by the User by filling out the registration form available on the website.

8: WHICH DATA IS MANDATORY AND WHICH IS OPTIONAL (AND THE CONSEQUENCES OF REFUSAL TO PROVIDE DATA)

User contact and identification data are mandatory. Failure to provide them makes it impossible to perform the requested service (newsletter/SMS delivery, responding to contact, account creation). Optional, but naturally inherent, are the data formed in the drafting of the communication (for example, what is written in the message body). For these, it is not possible to distinguish between mandatory and optional, as they arise naturally as part of the communication.

9: HOW THE SERVICE WILL “BOTHER” THE USER

NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. will “bother” the User in the following ways:
• The User may receive messages or other communications from NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L.; these will be operational or responses to the User’s communication. Such communications are essential for managing the relationship with the User.
• Newsletters and/or SMS: frequency: weekly; content: operational, promotional, regarding products or services of NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L. or third-party companies; service provider: register;
• Sending DEM (direct email marketing) — communications with product or service offers — via email, SMS, or messaging apps (WhatsApp, Telegram, etc.). Frequency: no more than once per month per channel. The User may unsubscribe simply by replying “Unsubscribe” (or similar wording) to any received communication.

10: USERS' RIGHTS

Users are entitled to a series of rights. Rights to information include:

  • Categories of data being processed (see sections 2 and 5);
  • Source of the data, i.e., where the service obtained it (see section 7);
  • Purposes of data processing (see section 6);
  • Details of the controller and any processors (see section 3);
  • Entities to whom the data is disclosed (see section 3/a);
  • Retention period and processing terms (see section 6);
  • Right to lodge a complaint with the data protection authority via the following link: http://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-nostri-dati-personali
  • Existence or absence of profiling;
  • Legal basis for processing (see section 6);

There are also rights that are not merely informational but operational, of various types. In summary:

  • The data subject has the right to obtain a copy of the data they have provided. If the data was processed using automated means and based on their consent or a contract, the user may request — if technically possible — that the data be transmitted to themselves or even to another controller (portability), provided this does not infringe on the rights (and data) of others.
  • If personal data is inaccurate or incomplete, the data subject may request correction or completion.
  • If personal data is no longer necessary for the purposes for which it was collected or otherwise processed, the data subject may request its deletion.
  • If processing is unlawful, the data subject may request deletion or restriction of processing.

For a more detailed overview of rights:

Right of access: The user has the right to obtain from the controller confirmation of whether personal data concerning them is being processed…

Right to rectification: The data subject has the right to obtain correction if their personal data is inaccurate…

Right to erasure (“right to be forgotten”): The data subject has the right to obtain deletion… (follows the full list of cases where deletion may be requested or denied)

Right to restriction: This is the right to mark data and limit its use to storage only…

11: HOW USERS CAN EXERCISE THEIR RIGHTS

Requests to exercise rights can be sent to either Controller, using the following addresses: NIKITA CLUB S.R.L. – info@nikita.land TRIANGLE CORPORATION S.R.L. – info@trngl.it (or, for certified communications: bc@pec.trngl.it)

12: USERS' DUTIES AND OBLIGATIONS

Users are required to provide truthful data. It is the User's responsibility to notify the Controller of any changes to the personal data previously provided…

13: DATA BREACH SCENARIOS

Should one or more of the following events occur regarding Users’ data: unauthorized access, theft, loss, destruction, disclosure, or modification (so-called Data Breach), NIKITA CLUB S.R.L. and TRIANGLE CORPORATION S.R.L., while implementing urgent technical measures to block the event (as far as possible) and reduce harmful effects, commit to:

  • restoring the service as quickly as possible, recovering available data from the most recent valid backup;
  • informing Users, directly where circumstances allow, or more generally (via a notice on the homepage of the website or communication sent to all users, including those unaffected by the breach), about the type of event, the time it occurred, the measures adopted (without disclosing details that could aid further attacks) to mitigate damage and to prevent recurrence, as well as the measures and precautions that Users should take themselves to reduce the likelihood of new incidents and limit the consequences of those already occurred.

Policy effective as of 30/09/2025

Via dei Morenghi, 2 — Telgate (BG)