Information notice pursuant to Art. 13 GDPR (EU Regulation 2016/679)

Privacy Policy

Last updated: July 2026
Data Controller: Telos di Massimiliano Ortelli

1. Data Controller

The data controller for personal data collected through this website is Telos di Massimiliano Ortelli, registered at Via della Scaletta 56 - 22077 Olgiate Comasco (Como), VAT / Tax ID: 04225220138.

Contact: info@telosboats.com — Tel. +39 347 845 4957

2. Purposes and legal basis for processing

Personal data collected through this website is processed for the following purposes:

a) Website browsing

The computer systems operating this website automatically collect certain data whose transmission is implicit in the use of Internet communication protocols (IP addresses, browser type, operating system, pages visited, date and time of access). This data is used for security purposes and to obtain anonymous statistical information about website usage. Legal basis: legitimate interest of the data controller (Art. 6(1)(f) GDPR).

b) Direct contact by email

Users may contact us by sending an email to the address published on this website. The data provided (name, email address, message content) will be used solely to respond to the enquiry. Legal basis: pre-contractual measures or performance of a contract (Art. 6(1)(b) GDPR).

c) Contact via WhatsApp

Users may start a conversation with us via the WhatsApp link on this website. Through this channel, we process the personal data the user chooses to share (profile name, phone number, chat content). WhatsApp's own terms and privacy policy (Meta Platforms Inc.) also apply to this channel. Legal basis: consent of the data subject (Art. 6(1)(a) GDPR).

d) Booking via the Holidoit platform

Boat reservations are handled through the third-party platform Holidoit (Holidoit S.r.l.), which acts as an independent data controller. Data entered during the booking process (name, surname, email, payment details) is collected and processed by Holidoit in accordance with their Privacy Policy and Terms and Conditions. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

e) Analytics and marketing (Google Analytics & Meta Pixel)

Subject to the user's explicit consent via the cookie banner, we use:

Google Analytics 4 (Google LLC / Google Ireland Ltd): to analyse website traffic in aggregated and anonymised form. Data may be transferred to servers in the United States under the EU–US Data Privacy Framework. Google Privacy Policy.
Meta Pixel (Meta Platforms Ireland Ltd): to measure the effectiveness of advertising campaigns on Facebook and Instagram and, where applicable, for retargeting. Data may be transferred to servers in the United States. Meta Privacy Policy.

Legal basis: consent of the data subject (Art. 6(1)(a) GDPR).

f) External fonts (Google Fonts)

This website uses typefaces provided by Google Fonts, loaded from the external server fonts.gstatic.com (Google Ireland Ltd / Google LLC). Loading these fonts automatically sends certain technical information to Google's servers (IP address, browser type), regardless of the choice made in the cookie banner, as this is a static resource and not a cookie in the strict sense. This service does not install any cookies or perform behavioural tracking. For more information: Google Privacy Policy. Legal basis: legitimate interest of the data controller, related to the technical necessity of correctly displaying the page (Art. 6(1)(f) GDPR).

3. Categories of data processed

Depending on how you interact with this website, the following data may be processed:

Browsing data (partial IP address, browser type, pages visited)
Contact data (name, email, phone number)
Booking data (managed by Holidoit as an independent data controller)
Usage and behavioural data (collected by Google Analytics and Meta Pixel, only upon consent)
Technical data sent to Google for font loading (IP address, browser type) — independent of cookie consent

4. Disclosure and transfer of data

Personal data is not sold or transferred to third parties for their own commercial purposes. It may be shared with the following parties to the extent strictly necessary:

Website hosting and technical service providers (data processors under Art. 28 GDPR)
Google LLC / Google Ireland Ltd – for Google Analytics 4 and for loading Google Fonts
Meta Platforms Ireland Ltd – for Meta Pixel
Holidoit S.r.l. – for booking management
Competent authorities, where required by law

Transfers to non-EU countries (in particular the United States) take place in accordance with the EU–US Data Privacy Framework adopted on 10 July 2023, or on the basis of Standard Contractual Clauses approved by the European Commission.

5. Retention periods

Contact emails: retained for as long as necessary to handle the request, and in any case no longer than 24 months.
Browsing data (server logs): no longer than 30 days, unless retention is required for the investigation of offences.
Google Analytics: user data is retained for 14 month.
Meta Pixel: in accordance with Meta Platforms' retention policies.
Booking data: managed by Holidoit according to their own policies.

6. Your rights

As a data subject, you have the right to:

Access (Art. 15)Obtain confirmation and a copy of data being processed

Rectification (Art. 16)Correct inaccurate or incomplete data

Erasure (Art. 17)Request deletion of your personal data

Restriction (Art. 18)Restrict processing in certain circumstances

Objection (Art. 21)Object to processing based on legitimate interest

Portability (Art. 20)Receive your data in a structured, machine-readable format

Withdrawal of consentWithdraw consent at any time without affecting prior processing

Lodge a complaintFile a complaint with the relevant supervisory authority

To exercise your rights, please write to: info@telosboats.com
We will respond within 30 days of receiving your request.

You may lodge a complaint with the Italian Data Protection Authority (Garante Privacy): www.garanteprivacy.it. If you are resident in another EU/EEA country, you may also contact your local supervisory authority.

7. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration or destruction, in accordance with Art. 32 GDPR. This website uses HTTPS (SSL/TLS encryption) for all communications.

8. Changes to this policy

We reserve the right to update this Privacy Policy to reflect changes in applicable law or the services we offer. The updated version will be published on this page with a revised date.