Privacy Policy

1. Data Controller

The data controller is Up to Ten, with registered office at Via Giuseppe Frua 21/6, 20146 Milan (MI), Italy. VAT: IT12071940964 Email: info@uptoten.it PEC: uptoten@pec.it

2. Data Collected

We collect the following personal data: • Contact details: first name, last name, email address, phone number, provided voluntarily through contact or booking forms. • Browsing data: IP address, browser type, pages visited, access times, collected automatically via technical and analytical cookies (with consent). • Voluntarily provided data: any additional information shared via email, phone, or WhatsApp.

3. Legal Basis

Data processing is based on: • Consent (Art. 6.1.a GDPR): for sending communications and using analytical cookies. • Contract performance or pre-contractual measures (Art. 6.1.b GDPR): to respond to information requests and manage bookings. • Legitimate interest (Art. 6.1.f GDPR): for service improvement and website security.

4. Purposes of Processing

Personal data is processed for the following purposes: • Responding to information requests sent via the contact form. • Managing lesson bookings. • Improving the browsing experience on the website. • Aggregate and anonymous statistical analysis of web traffic. • Complying with legal obligations.

5. Data Retention

Personal data is retained for the time strictly necessary for the purposes for which it was collected: • Contact data: up to 24 months from the last contact, unless otherwise requested. • Browsing data: according to the timeframes indicated in the Cookie Policy. • Accounting and tax data: for the periods required by applicable legislation.

6. Data Subject Rights

Under Articles 15-22 of the GDPR, data subjects have the right to: • Access their personal data. • Obtain rectification or erasure of data. • Restrict processing. • Object to processing. • Request data portability. • Withdraw consent at any time. To exercise your rights, write to: info@uptoten.it

7. Cookies

For detailed information on cookie usage, please refer to our Cookie Policy.

8. Contact Us

For any privacy-related questions, you can contact us: Email: info@uptoten.it PEC: uptoten@pec.it Phone: +39 02 0996 9655 Address: Via Giuseppe Frua 21/6, 20146 Milan (MI)