Last updated: 1 October 2026
1. Introduction
Azzurro Technology Inc. (“Azzurro”, “we”, “our”, “us”) respects your privacy and is committed to protecting the personal information we collect in the course of providing our services. This Privacy Policy explains what data we collect, how we use it, on what legal bases, with whom we share it, how long we retain it, and the rights you have under:
- Canada: the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial statutes (including Quebec’s Law 25 where applicable);
- European Union and Italy: Regulation (EU) 2016/679 (GDPR) and the Italian Privacy Code (Legislative Decree 196/2003, as amended);
- United Kingdom: the UK GDPR and the Data Protection Act 2018;
- Switzerland: the Federal Act on Data Protection (FADP, revised) and its ordinances.
By visiting https://azzurro.tech, using our web-based portals, or engaging us for any of our services, you consent to the practices described herein to the extent consent is used as a legal basis. If you do not agree, please do not use our website or services.
Controller: Azzurro Technology Inc., info@azzurro.tech. Questions, requests, and complaints can be addressed to us at that address.
2. Personal Information We Collect
| Category | Examples | Purpose |
|---|---|---|
| Identity & Contact | Name, email address, phone number, mailing address, company name | Create and manage accounts, communicate about orders, quotes, invoices, support tickets, and warranty matters. |
| Authentication & Security | Username, password (hashed), login timestamps, IP address, device identifiers, browser user-agent | Secure access to our portals, detect fraud, enforce warranty limits (warranty period is tied to the date of the last valid payment). |
| Payment & Billing | Credit-card details (processed by a PCI-DSS-compliant processor), billing address, transaction IDs | Process payments and deposits, issue invoices, administer the money-back guarantee. |
| Store Orders & Support Entitlements | Order details, selected product, Qualifying Operations performed (including data-extraction events) | Fulfil support entitlements, administer the money-back guarantee, honour deletion obligations. |
| Comments & Community Interaction | Comment text, optional website URL, IP address, user-agent, Gravatar hash (if you use Gravatar) | Publish public comments, moderate spam, display avatars. |
| Media Uploads | Images, documents, firmware binaries, hardware design files | Provide deliverables, support custom hardware, host documentation. |
| Cookies & Tracking | Session cookies, “remember-me” tokens, preference cookies, analytics identifiers | Preserve session state, remember preferences, improve site usability, measure traffic. |
| Support & Service Requests | Ticket description, attached logs/files, IP address (for password-reset emails) | Diagnose issues, fulfil warranty support, provide technical assistance. |
| Third-Party Embedded Content | Data transmitted to embedded video/audio providers, social-media widgets | To enable embedded media functionality; these providers may collect their own data. |
Note: We never collect more data than is necessary to fulfil the purpose for which it is collected.
3. How We Use Your Information & Legal Bases
We process personal information on the following legal bases:
- Performance of a contract or steps at your request (GDPR/UK GDPR Art. 6(1)(b); PIPEDA) – designing, delivering, and supporting contracted solutions; creating accounts; processing orders, deposits, and refunds.
- Consent (GDPR/UK GDPR Art. 6(1)(a); FADP; CASL; PECR) – marketing communications, optional cookies and embedded content. Consent can be withdrawn at any time.
- Legal obligation (GDPR/UK GDPR Art. 6(1)(c)) – tax and accounting records, lawful requests from Canadian and Italian authorities and other competent authorities.
- Legitimate interests (GDPR/UK GDPR Art. 6(1)(f); PIPEDA) – fraud prevention, site security, aggregated analytics, and administering the Terms (including Payment Checkpoints, Qualifying Operations tracking, and deletion obligations), balanced against your rights.
In particular we use your information for: provisioning of services; account management and warranty enforcement; order confirmations, invoices, quotes, and status updates; support and warranty diagnostics; administration of store deposits, the money-back guarantee, and instance-deletion obligations; legal and regulatory compliance; aggregated service improvement; and third-party service facilitation (payments, email delivery, spam detection, embedded media).
4. Cookies & Similar Technologies
| Cookie Type | Duration | Purpose |
|---|---|---|
| Commenter Cookies | 1 year | Remember name, email, website for future comments (optional). |
| Session Test Cookie | Browser session | Verify that the browser accepts cookies (no personal data). |
| Login Cookies | 2 days (or 2 weeks if “Remember Me” selected) | Keep you authenticated. |
| Screen-Preference Cookies | 1 year | Store UI/display choices. |
| Post-Edit Cookie | 1 day | Indicate the ID of a recently edited article (no personal data). |
| Analytics / Third-Party Cookies | Varies | Set by embedded content providers (e.g., YouTube, Vimeo). |
Strictly necessary cookies are set on the basis of operating our service; optional cookies require your consent where EU, UK, or Swiss law applies, and consent requests include a reject-all option of equal prominence. You may disable or delete cookies via your browser settings; however, doing so may affect functionality (e.g., staying logged in).
5. Sharing & Disclosure of Personal Information
| Recipient | Reason for Sharing | Safeguards |
|---|---|---|
| Payment Processors (PCI-DSS compliant) | Process credit-card transactions and deposits | No card data stored on our servers; only tokenized data is retained. |
| Spam-Detection Service (e.g., Akismet) | Filter comment spam | Only comment text, IP, and user-agent are transmitted. |
| Domain Registrar (for domains we register on your behalf) | Register and manage domain names (ownership remains with Azzurro) | Registrars are bound by contractual confidentiality. |
| Cloud Hosting Providers (OVHCloud, DigitalOcean — Canada-region primaries) | Host applications, instances, and backups | Data encrypted at rest and in transit; provider agreements require compliance with Canadian privacy standards. |
| Competent Authorities in Canada and Italy | Response to lawful requests and compliance obligations | Only data strictly required by law is disclosed. |
| Law Enforcement / Legal Authorities (other jurisdictions) | Respond to lawful requests, protect rights | Only disclose data strictly required by law. |
| Embedded Content Providers (YouTube, Vimeo, etc.) | Serve embedded media | They may collect data per their own privacy policies (links provided). |
We do not sell, rent, or otherwise commercially trade your personal information.
6. International Data Transfers
All primary processing occurs on servers located in Canada, with hosting providers selected to avoid exposure to foreign jurisdictional data-access regimes where practicable. Where personal data of individuals in the EU, UK, or Switzerland is transferred to Canada or any other jurisdiction, we ensure that the transfer is protected by adequacy decisions where available, the EU/UK Standard Contractual Clauses, the UK International Data Transfer Agreement, or the Swiss-EU/UK transfer instruments as applicable, and that the provider adheres to privacy standards comparable to the applicable law.
7. Data Retention
| Data Type | Retention Period |
|---|---|
| Comments & Metadata | Indefinitely (to allow thread continuity and moderation), subject to legal withdrawal objections (GDPR/UK GDPR Art. 21). |
| User Account Information | As long as the account remains active; you may request deletion at any time (except the username, which is immutable). |
| Support Tickets & Logs | 24 months after ticket closure, unless required longer for legal/compliance reasons. |
| Hosted Instance Data | Deleted upon refund, termination, or Checkpoint enforcement — no retention period applies. Where the payment-checkpoint process applies, deletion occurs after a minimum 24-hour warning window (extended where mandatory consumer law so requires). |
| Operational & HTTP Logs | Minimum 24-hour retention for billing purposes, then purged as part of instance deletion. |
| Payment Records | Minimum 7 years (tax and accounting requirements, including per Italian and Swiss fiscal-records rules). |
| Warranty-Related Data | 12 months from the date of the last valid payment (aligned with the warranty period). |
| Cookies | As described in Section 4; persistent cookies expire automatically. |
Notes: (i) Where the Terms and Conditions provide for deletion “without retention,” deletion of Customer instance data overrides any longer retention period in this table, except for invoicing and payment records (retained the statutory minimum of 7 years) and records we must retain under lawful exception. (ii) Nothing in this section limits erasure rights under GDPR, the UK GDPR, or the Swiss FADP; where storage is no longer necessary or processing is unlawful, data is erased despite shorter or longer periods stated here.
When retention periods expire, we securely delete or anonymize the data.
8. Your Rights
Depending on your jurisdiction, you have the following rights (subject to lawful exceptions):
- Access – Request a copy of the personal information we hold about you.
- Correction / Rectification – Request correction of inaccurate or incomplete data.
- Deletion / Erasure – Request erasure of your personal data (except where we must retain it for legal, tax, or security purposes).
- Restriction of Processing – Request that we limit processing while a dispute is resolved (EU, UK, Switzerland).
- Portability / Data Transfer – Receive your data in a structured, commonly used, machine-readable electronic format (EU, UK, Switzerland; comparable rights in Quebec under Law 25).
- Objection – Object to direct marketing (you can unsubscribe at any time) and to processing based on legitimate interests (EU, UK).
- Withdraw Consent – Withdraw consent at any time where processing is based on consent.
- Complaint – Lodge a complaint with your supervisory authority: the Office of the Privacy Commissioner of Canada; the Garante per la Protezione dei Dati Personali (Italy); the Information Commissioner’s Office (UK); or the Federal Data Protection and Information Commissioner (FDPIC, Switzerland).
To exercise any of these rights, contact us using the details in Section 11. We will respond within one month (extendable by two further months for complex requests where permitted), and within 30 days under PIPEDA.
9. Security Measures
We employ industry-standard safeguards, including:
- Encryption – TLS for data in transit; encryption for data at rest on hosted instances.
- Access Controls – Role-based permissions and multi-factor authentication for staff.
- Monitoring – Log-based monitoring and periodic security reviews of hosted systems.
- Physical Security – Data centres operated by our hosting providers with restricted access and environmental controls.
While we strive to protect your information, no transmission over the Internet is 100 % secure; you acknowledge the inherent risks of online communication. Where a personal data breach affecting individuals in the EU, UK, or Switzerland is likely to result in a high risk to your rights, we will notify you and the competent supervisory authority within 72 hours of becoming aware, as required by the GDPR, UK GDPR, and the revised Swiss FADP.
10. Changes to This Privacy Policy
We may update this Privacy Policy to reflect regulatory changes, new services, or operational adjustments. When we make material changes, we will:
- Post the revised policy on https://azzurro.tech with a new “Last updated” date.
- Notify existing customers via email (if you have provided an email address).
Your continued use of our website or services after such notice constitutes acceptance of the updated policy to the extent permitted by law.
11. Contact Information
If you have questions, concerns, or wish to exercise any of your privacy rights, please contact:
Azzurro Technology Inc. Email: info@azzurro.tech
We will make every effort to address your inquiry promptly and transparently.
Thank you for trusting Azzurro Technology Inc. with your data.