Privacy Policy (Art. 13-14 EU Reg. 2016/679 – GDPR)

Website: martinocouscous.com
Last updated: 05/02/2026

This policy describes the ways in which S.I.P.A. International S.r.l. processes the personal data of users
who browse the site and/or send requests via contact forms or applications.

1. Data controller

The data controller is S.I.P.A. International S.r.l.
Registered office: Via Ferrari, 72 – 86100 Campobasso (CB), Italy
P. VAT: IT01410310708

Headquarters: Via Enrico Mattei 37/39 – 86039 Termoli (CB), Italy
Email: info@martinocouscous.com
Phone: +39 0875 752163

2. Data Protection Officer (DPO)

The Owner may have appointed a Data Protection Officer. For up-to-date information, you can contact
the Owner at the contact details above.

3. Types of data processed

Browsing data: IP, browser/device data, system logs.
Data provided voluntarily: first name, last name, email, phone, message.
Application data: biographical data, CV, uploaded attachments.

4. Purpose of processing and legal basis

Purpose	Data processed	Legal basis	Indicative retention
Responding to requests via contact forms	Master data, contacts, messages	Pre-contractual measures / consent	Generally up to 24 months
Application management	CV data and contacts	Pre-contractual measures	Generally up to 12 months
Security and operation of the site	Navigation data and logs	Legitimate interest	6-12 months unless required by law
Legal obligations	Data required for compliance	Legal obligation	According to current legislation

5. Methods of processing

Processing is carried out with electronic and organizational tools suitable for ensuring data security and confidentiality.

6. Recipients of the data

Data may be processed by:

IT providers and hosting
Email service providers and support
Technical, legal and tax consultants
Public authorities where applicable

7. Non-EU transfers

Any transfers will take place in compliance with the GDPR through standard contractual clauses or adequacy decisions.

8. Cookie

The site may use technical cookies and, with prior consent, analytical or marketing cookies. See the Cookie Policy for details.

9. Social and third-party content

The site may contain links or content from social platforms and external services.

10. Rights of the data subject

Users may exercise their rights under Articles 15-22 GDPR (access, rectification, cancellation, restriction, opposition,
data portability, withdrawal of consent).

You can file a complaint with the Privacy Guarantor: www.garanteprivacy.it