Privacy Policy
Last updated: 31 May 2026
This Privacy Policy describes how StradiVault Ltd collects, uses and protects the personal data of users of the stradivault.com website.
1. Data Controller
StradiVault Ltd London, UK Registered in England and Wales Companies House No. 17037337 Email: privacy@stradivault.com The data controller can be contacted at the address above for any matter relating to the processing of personal data.
2. Data collected
The website collects personal data in two ways. a) Through the contact forms (/contatti and /investors pages): · Full name · Email address · Type of request · Instrument details (optional field, only for eligibility check requests) · Message content · Date and time of submission b) Through cookies and similar technologies: · Essential technical cookies required for the website to function (always active, no consent required) · Google Analytics 4 (third-party analytics cookies, activated only upon explicit consent via the cookie banner; IP anonymised). See the Cookie Policy for further details.
3. Purpose of processing
Data is processed exclusively to: · Reply to requests submitted through the contact forms · Assess the eligibility of instruments for the fractional tokenisation programme (where applicable) · Manage early access to the investor programme (where applicable) · Collect anonymous usage statistics to improve the site (only upon consent) Data is not used for marketing purposes nor shared with third parties for commercial purposes.
4. Legal basis
Processing is based on the explicit consent of the data subject, given by ticking the appropriate box in the contact form or via the cookie banner, pursuant to Art. 6(1)(a) of EU Regulation 2016/679 (GDPR) and the UK Data Protection Act 2018.
5. Data retention
Data collected through the contact forms is retained for the time strictly necessary to fulfil the request, and in any event for a maximum period of 24 months from the date of submission. Data collected via Google Analytics 4 is retained according to the service’s default periods (maximum 14 months), in aggregated and anonymised form. After such periods, data is deleted unless otherwise requested by the data subject or required by law.
6. Data recipients
Personal data is processed internally by the controller. It may be shared only with the following providers, acting as data processors: · Resend (transactional email service) — servers in the EU · Vercel Inc. (website hosting) — servers in EU/UK for European traffic · Google LLC (Google Workspace for the controller’s email and Google Analytics 4 for anonymous usage statistics) — global servers with standard contractual clauses No further transfers of data to third parties are envisaged.
7. Transfers outside the EU
Some of the providers listed in point 6 may process data outside the European Economic Area. In such cases, transfers take place exclusively to countries ensuring an adequate level of protection, or on the basis of standard contractual clauses approved by the European Commission and the United Kingdom.
8. Rights of the data subject
In accordance with the GDPR and the UK Data Protection Act 2018, the data subject has the right to: · Access their personal data · Request rectification or completion · Request erasure (“right to be forgotten”) · Restrict or object to processing · Receive data in a structured format (portability) · Withdraw consent at any time To exercise these rights, simply send a request to privacy@stradivault.com indicating the right to be exercised. A response will be provided within 30 days.
9. Right to lodge a complaint
Any data subject who believes that the processing of their personal data violates applicable law may lodge a complaint with the competent supervisory authority: · Information Commissioner’s Office (ICO) — United Kingdom — ico.org.uk · Italian Data Protection Authority (Garante) — Italy — garanteprivacy.it · or the authority of the data subject’s country of residence
10. Changes to the Privacy Policy
This Privacy Policy may be updated at any time to reflect regulatory or organisational changes. The date of the latest update is indicated at the top of the document. Users are invited to consult this page periodically.
StradiVault Ltd · Companies House No. 17037337