Privacy and Cookie Policy

This policy explains how TerzoTesto processes personal data received through the website, email, WhatsApp and subsequent communications relating to the assessment or performance of an engagement.

Data Controller

Irene Stocco – TerzoTesto
Email: info@terzotesto.com

Purposes of processing

Categories of personal data processed

• Identification and contact details.
• Information provided in the initial request and subsequent communications.
• Content of documents submitted for assessment or performance of the engagement.
• Any health data or other special-category data.
• Technical data relating to browsing and cookie preferences.

Provision of data

Providing the data necessary to assess the request and carry out the engagement is optional, but failure to provide it may make it impossible to respond or proceed. Before sending documents containing health data or other special categories of personal data, explicit consent is required. Without such consent, those data must not be sent.

Initial contact and confirmation of the engagement

By continuing via email or WhatsApp, the user confirms that they have read this policy. The engagement is confirmed separately, in accordance with the terms stated in the quotation or confirmation message. Where special-category data is involved, an explicit consent statement is requested before those data are used.

Recipients and service providers

Data may be processed by technical providers necessary for the operation of the service, including hosting, email, cloud services, messaging tools and providers connected with administrative obligations. Depending on the service provided, these parties act as processors or independent controllers. Personal data is not publicly disclosed.

WhatsApp and email

When the user chooses to contact TerzoTesto via WhatsApp or email, personal data is also processed through the relevant service providers. Users are asked to send initially only the information necessary to describe the case and not to send documents containing special-category data before receiving instructions on how to proceed.

Personal data relating to third parties

Anyone who submits personal data relating to third parties confirms that they are entitled to disclose it and undertakes to provide only information that is relevant and necessary for assessment or performance of the engagement.

Data retention

• Data relating to requests and drafts: up to 12 months after closure of the matter or failure to proceed with the engagement.
• Final documents and correspondence relating to the engagement: up to 5 years, for organisational and protective purposes.
• Tax data and documents: for the period required by applicable law, normally 10 years.
• Consent relating to Google Analytics: until withdrawn or until the stored browser preference is deleted.

Rights of the data subject

The data subject may request access, rectification, erasure, restriction of processing, objection and, where applicable, data portability. Consent may also be withdrawn at any time; withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Requests may be sent to info@terzotesto.com. The right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) remains unaffected.

Cookies, technical tools and preference management

The website uses technical tools necessary for operation and for storing the choice made in the banner. Cloudflare Web Analytics operates without cookies or local storage for aggregated and technical statistics. The preference relating to Google Analytics 4 is instead stored in the browser through local storage so that the banner is not shown again on every page.

Cloudflare Web Analytics

The website uses Cloudflare Web Analytics, a service provided by Cloudflare, to obtain aggregated statistics on website usage and page performance. In the configuration used, the service does not use cookies, localStorage or other persistent identifiers for Web Analytics and is not used to profile or individually track visitors.

The Cloudflare beacon is loaded when pages are opened regardless of the choice made in the banner relating to Google Analytics 4. The IP address is technically received as part of the normal network request; according to the provider's documentation, it is processed at the Cloudflare data centre and is not retained in the main Web Analytics databases or logs. The data is used to produce aggregated statistics such as visits, page views, pages consulted, general traffic source, country, browser, operating system, device and performance metrics.

Google Analytics 4

With the user's consent, the website activates Google Analytics 4, a service provided by Google, to collect statistics on page usage. Tracking is not loaded before statistical-cookie consent is accepted. The user can refuse consent through the banner and can later change their choice using the Cookie settings link in the footer.

Google Analytics 4 does not log or store users' IP addresses. For traffic originating in the European Union, Google states that IP addresses are used only to determine approximate geographic information and are discarded before data is logged. Use of services provided by Google may involve additional processing and transfers of data in accordance with the provider's terms and safeguards.

Nature of the service and engagement terms

TerzoTesto provides a professional writing and document-mediation service: it analyses the information provided by the Client, organises the content and drafts tailored texts consistent with the communicative, administrative, civic or personal context indicated.

The documents produced serve a communicative, organisational and documentary purpose. They are intended to make a request, response, agreement, reconstruction or written communication clearer, more orderly and more relevant.

The service does not replace legal, medical, tax, psychological or other activities reserved to regulated professionals. TerzoTesto does not provide civil or commercial mediation within the meaning of Italian Legislative Decree 28/2010, does not represent the Client before third parties and does not guarantee specific outcomes arising from use of the texts produced.

Responsibility towards third parties

Any references to individuals, professionals or organisations included in the texts are based on information provided by the Client, who remains responsible for that information. TerzoTesto does not carry out independent verification and does not express personal judgments; it organises and converts the information received into written form according to the engagement.

Ownership of texts

Documents produced are the exclusive property of the Client, who assumes full ownership and responsibility from the moment they are sent. TerzoTesto retains no copyright or subsequent right of use over texts drafted on the Client's behalf.

Confirmation of the engagement implies acknowledgement of this Policy and acceptance of the engagement terms communicated to the Client.

Last updated: 18 August 2026.