Privacy policy

This privacy policy explains how Devis Nishku processes the personal data of people who visit devisnishku.com or contact him through the site's form, under Regulation (EU) 2016/679 (GDPR). If you have any questions, write to the email address below.

Data controller

Devis Nishku, VAT no. (P.IVA) IT04834590400, based in Forlì (FC), Italy. Email: devisnishku1@gmail.com.

What data I process

Data you enter in the contact form. Your name, email address and message, together with the language of the page you write from. Please do not include health data or other special categories of data in your message, nor data about other people that your request does not need.

Technical data. When you submit the form, your IP address is used for the anti-bot check and to limit repeated submissions in a short time. As with almost every website, the hosting provider also records technical data about requests (IP address, date and time, requested page, browser type) for security and to keep the service running.

Visit statistics. The site uses Cloudflare Web Analytics, which provides aggregated statistics (for example page views, referring site, country and device type) without cookies and without building visitor profiles.

Direct contact. If you write to me by email, on LinkedIn or on Telegram, I process the data you send (name, address or profile, message content) to reply to you. In that case the privacy policies of those services also apply.

Why I process it and on which legal basis

• Replying to your request and, if you ask for it, preparing a proposal or a quote. Legal basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR).
• Protecting the site and the form from spam, bots and abuse, through the anti-bot check, the submission limit and technical logs. Legal basis: legitimate interest in keeping the site secure (Art. 6(1)(f) GDPR).
• Measuring site usage in aggregate, to understand which pages are useful. Legal basis: legitimate interest (Art. 6(1)(f) GDPR); the statistics use no cookies and do not identify visitors.

Filling in the form is optional, but without your name, email and message I cannot reply. I do not use your data for newsletters or marketing and I do not share it with anyone else.

How your message reaches me: Telegram

The site does not store messages in a database of its own. When you submit the form, your message (name, email, text and language) is forwarded by a bot to the data controller's Telegram account, where he reads it and replies to you by email.

Telegram is a messaging service run by companies based outside the European Union, so the message data may be processed outside the European Economic Area (EEA). For this transfer I do not rely on an adequacy decision or on standard contractual clauses, but on the derogation in Art. 49(1)(b) GDPR: the transfer is necessary to act on the request you send me, that is, for steps taken at your request before entering into a contract. It covers only the data you enter in the form and happens only when you submit it.

If you prefer your data not to go through Telegram, do not use the form and email me directly instead.

Providers and recipients

• Cloudflare, Inc. hosts the site, runs the code that receives the form (Cloudflare Workers), provides the anti-bot check (Cloudflare Turnstile) and the cookieless aggregated statistics (Cloudflare Web Analytics). Cloudflare processes this data as a provider to the data controller, under its data processing agreement, which includes the safeguards the GDPR requires for transfers outside the EEA. Cloudflare privacy policy
• Telegram delivers the form message to the data controller's account, as described above. Telegram privacy policy
• Google (Gmail) runs the data controller's mailbox, which I use to reply to you and for any further correspondence. Google privacy policy

Your data is not published or disclosed to anyone else, unless the law requires it.

How long I keep the data

• Form messages and email correspondence: up to 24 months after our last exchange, then I delete them. If your request leads to an engagement, I keep the data needed for the duration of the engagement and for as long as legal obligations require, for example tax and accounting obligations.
• Technical and security data (logs, anti-bot check, submission limit): for the periods set by Cloudflare's services.
• Visit statistics: in aggregate form only, with no data that identifies you.

Cookies

The site uses no profiling or marketing cookies. Cloudflare Web Analytics works without cookies. The Cloudflare Turnstile anti-bot widget is loaded only on the Contact page, the only page with the contact form, when the form is in view or about to come into view, and processes only the technical browser data strictly needed for the check.

Security

The site is served only over an encrypted connection (HTTPS). The form is protected by the anti-bot check and by a limit on repeated submissions, and the site's logs do not record the content of messages.

Your rights

Under Articles 15–22 of the GDPR you can ask at any time to access your data, to have it rectified or erased, to restrict its processing and to receive it in a portable format, and you can object to processing based on legitimate interest. To exercise your rights, write to devisnishku1@gmail.com: I will reply without undue delay and in any case within one month.

You also have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or with the supervisory authority of the EU country where you live or work.

I do not make decisions based solely on automated processing and I do not carry out profiling.

Changes to this policy

I may update this policy, for example if the services used by the site change. The date of the last update is shown at the top of the page.