Last updated: June 2026
1. Data controller
The data controller of the personal data processed through this website is Steg Procurement trading as Stefano Gottardis.
Steg Procurement trading as Stefano Gottardis
VAT n. IT04155350129
Busto Arsizio | Varese | Italy
email: hello@stegprocurement.com
PEC: stefano.gottardis@pecprofessionale.com
For requests relating to the protection of personal data, Steg Procurement may be contacted using the details above or through the forms available on the website.
No sensitive data should be sent via website form unless strictly necessary.
2. Personal data collected
Depending on the user’s interaction with the website, the following categories of personal data may be collected:
- • Name and surname
- • Email address
- • Company name
- • Job title or role, where provided
- • Phone number, where provided
- • Content of messages submitted through contact or enquiry forms
- • Technical data strictly required for site operation and form security
The website is not intended to collect special categories of personal data unless strictly necessary and expressly provided by the user.
3. Purposes of processing
Personal data may be processed for the following purposes:
- • Responding to contact requests and business enquiries
- • Evaluating potential service requests, collaborations or project discussions
- • Managing follow-up communications connected to an enquiry submitted by the user
- • Ensuring technical operation, integrity and security of the website and its forms
- • Complying with applicable legal or regulatory obligations, where required
4. Legal basis
Personal data is processed on one or more of the following legal bases, depending on the context:
- • The user’s request for information or pre-contractual steps
- • The data controller’s legitimate interest in managing business enquiries, website security and operational continuity
- • Compliance with legal obligations, where applicable
- • The user’s consent, where this is specifically required
5. How data is collected
Data is collected primarily when the user:
- • Fills in and submits a contact or enquiry form
- • Communicates directly through the website’s forms or related channels
- • Interacts with the website in ways that generate strictly necessary technical data for security and functionality
6. Data retention
Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including:
- • Data submitted through contact or enquiry forms is retained for the time necessary to handle the request and any related follow-up, normally up to 24 months, unless a contractual relationship, legal obligation or need to protect rights requires longer retention
- • Data relating to contractual, administrative or project relationships is retained for the periods required by applicable law and by tax, accounting or legal obligations
- • Technical and security data, including any server logs, is retained for a limited period proportionate to security, diagnostic and abuse-prevention purposes, according to the technical settings of the hosting provider
Data that is no longer necessary is deleted or appropriately secured in accordance with internal retention principles and applicable law.
7. Recipients and service providers
Personal data may be processed only by parties involved in operating the website, managing communications and supporting any professional activities requested by the user.
- • Technical providers, hosting providers, email services and parties supporting website security, maintenance and operation
- • External advisors or professionals, where necessary for administrative, tax, legal or contractual purposes
- • Public authorities or entitled parties, only where required by law or necessary to protect rights
Where such parties process personal data on behalf of Steg Procurement, they do so under appropriate agreements, instructions or confidentiality obligations. Personal data is not sold or disclosed to third parties for commercial or marketing purposes.
8. International data transfers
Steg Procurement does not intend to transfer personal data outside the European Economic Area as part of the normal operation of the website and contact form.
- • The website, hosting and ordinary communication management are configured to operate through providers and infrastructure compatible with the EU/EEA context, where applicable
- • If services involving transfers to countries outside the EEA are used in the future, such transfers will take place only where an appropriate legal basis and the safeguards required by applicable law are in place
- • Such safeguards may include adequacy decisions, standard contractual clauses, supplementary technical and organisational measures or other mechanisms provided under applicable privacy law
Any relevant updates regarding international transfers will be reflected in this notice.
9. Data security
Reasonable technical and organizational measures are adopted to protect personal data against unauthorized access, disclosure, alteration, loss or misuse.
These measures may include secure transmission practices, form protection mechanisms, access controls and security-related monitoring appropriate to the website’s scale and purpose.
10. Data subjects’ rights
Subject to applicable law, users may have the right to:
- • Access their personal data
- • Request rectification of inaccurate data
- • Request erasure of data where applicable
- • Request restriction of processing in certain cases
- • Object to processing based on legitimate interest, where applicable
- • Request data portability where legally available
- • Lodge a complaint with the competent supervisory authority
To exercise these rights, users may contact Steg Procurement using the contact details provided in section “1. Data Controller” of this document or through the “Contact” page of the website. Users also have the right to lodge a complaint with the Italian Data Protection Authority or another competent supervisory authority.
11. AI-related processing considerations
Steg Procurement’s services may involve analytical, operational or decision-support activities.
Where client-related data is processed within the scope of procurement, sourcing, analytics or diagnostic work, such processing is expected to follow principles of necessity, proportionality, confidentiality, data minimization and appropriate contractual safeguards.
If AI-enabled tools are used in future service delivery, they should be used in a controlled and proportionate manner, consistent with applicable data protection obligations and the specific context of the client engagement.
12. Future client area / restricted area
In the future, the website may include a restricted client area or private user area.
In that scenario, additional personal data may be processed to support account access, authentication, session continuity, security and operational functionality strictly related to the reserved area.
If and when such functionality is introduced, this Privacy Policy will be updated accordingly.
13. Cookie Policy
This website currently uses only technical and strictly necessary cookies. For more information, please refer to the Cookie Policy.
14. Contact
For privacy-related requests or questions regarding this Privacy Policy, users may contact Steg Procurement through the contact details or forms made available on the website.