Privacy Policy

Last updated: January 2026

Introduction

Protocol ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal data in connection with our diagnostic platform for post-construction cleaning services, available at novalians.com and related services.

This policy applies to all visitors and users of our website, consultation forms, and diagnostic tools. Please read this policy carefully. By accessing or using Protocol, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy.

Data We Collect

We collect personal data in several ways:

Information You Provide Directly

When you use our consultation form or contact us, you may provide:

• Your name and professional title
• Your email address and phone number
• Your company or property management organization name
• Property type and location information
• Construction phase completion dates
• Specific debris concerns and cleaning challenges you face
• Any other information you choose to share in messages or inquiries

Information Collected Automatically

When you visit our website, we may automatically collect certain technical information:

• Your IP address and device identifier
• Browser type, version, and operating system
• Pages you visit and time spent on each page
• Referral source and navigation patterns
• General geographic location (city/region level)

We may use analytics tools to understand how visitors interact with our platform. These tools may place cookies or similar tracking technologies on your device to collect this information.

Cookies and Similar Technologies

We use cookies and similar technologies (such as pixels and local storage) to:

• Remember your preferences and settings
• Understand how you use our website
• Improve our services and user experience
• Measure the effectiveness of our content

Most web browsers allow you to control cookies through their settings. You can choose to decline cookies, though this may limit your ability to use certain features of our website. For more information about managing cookies, visit your browser's help section or allaboutcookies.org.

How We Use Your Data

We process your personal data for the following purposes:

• Providing Services: To respond to your inquiries, deliver diagnostic assessments, and provide post-construction cleaning guidance tailored to your property and debris concerns.
• Communication: To send you updates, newsletters, and information about our services, protocols, and industry insights relevant to property managers and developers.
• Improvement: To analyze how our platform is used, identify common failure points in construction cleaning, and refine our diagnostic tools and content.
• Legal Compliance: To comply with applicable laws, regulations, and legal obligations in Italy and the European Union.
• Business Operations: To manage our website, prevent fraud, ensure security, and protect the rights and safety of our users and company.

Legal Basis for Processing

Under European Union data protection law (GDPR), we process your personal data on the following legal bases:

• Consent: When you submit a consultation form or contact us, you consent to our processing of your data to respond to your request.
• Legitimate Interests: We process data to improve our services, understand user needs in the post-construction cleaning industry, and operate our business effectively.
• Contractual Necessity: If you engage our services, we process data necessary to fulfill our obligations to you.
• Legal Obligation: We process data as required by Italian and EU law.

Data Sharing and Processors

We do not sell your personal data. However, we may share your information with:

• Service Providers: Third-party vendors who help us operate our website, send communications, analyze data, and provide customer support. These processors are contractually bound to protect your data and use it only as necessary to provide services to us.
• Legal Requirements: If required by law, court order, or government request, we may disclose your data to comply with legal obligations.
• Business Transfers: If Protocol is acquired, merged, or assets are transferred, your data may be transferred as part of that transaction.

We ensure all processors maintain appropriate data protection standards and execute data processing agreements as required by GDPR.

Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy:

• Consultation inquiries and contact information are retained for up to 3 years to support ongoing communication and service delivery.
• Analytics and usage data are typically retained for 12 months.
• If you request deletion, we will remove your data within 30 days, except where we are legally required to retain it.

If you no longer wish to receive communications from us, you may request deletion at any time by contacting us using the information below.

Your Rights Under GDPR

As a data subject in the European Union, you have the following rights:

• Right of Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request that we correct inaccurate or incomplete data.
• Right to Erasure: You can request deletion of your data, subject to certain legal exceptions.
• Right to Restrict Processing: You can request that we limit how we use your data.
• Right to Data Portability: You can request your data in a structured, machine-readable format.
• Right to Object: You can object to certain types of processing, including marketing communications.
• Right to Withdraw Consent: If we process your data based on consent, you can withdraw that consent at any time.

To exercise any of these rights, contact us at hello@novalians.com with your request. We will respond within 30 days.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, secure server infrastructure, and restricted access controls. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security of your data.

Children's Privacy

Our services are intended for property managers, developers, and other professionals involved in construction and property management. We do not knowingly collect personal data from children under the age of 16. If we become aware that we have collected data from a child under 16, we will delete it promptly. If you believe we have collected data from a child, please contact us immediately.

Third-Party Links

Our website may contain links to third-party websites and services. This Privacy Policy applies only to Protocol and does not cover external websites or services. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any external sites before providing your personal data.

International Data Transfers

Protocol is based in Milan, Italy, and your data is processed within the European Union. If we transfer data outside the EU, we will do so only with appropriate safeguards as required by GDPR, such as Standard Contractual Clauses or adequacy decisions.

Contact Us

If you have questions about this Privacy Policy, wish to exercise your rights, or have concerns about how we process your data, please contact us:

• Email: hello@novalians.com
• Phone: +39 357 388 0802
• Address: Protocol, Milan, Lombardy, Italy

You also have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.

Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by updating the "Last updated" date at the top of this page and, where appropriate, by sending you an email notification. Your continued use of Protocol following any changes constitutes your acceptance of the updated Privacy Policy.