TRON Private — Privacy and cookie information

Updated: 11 September 2026. This information covers new consultation requests collected through the TRON Private website under this notice.

Who is responsible. Smart Technologies Srl, Via Valsugana 5, Genova, Italy, VAT IT02473990998, is responsible for the personal data described in this notice. For questions or to exercise your rights, contact Fabrizio Vassallo at f.vassallo@solariumsmart.it.

Your consultation request. We use the details you provide to receive your request, assess your proposed TRON installation and respond through your chosen contact method. These details may include your name, email address, telephone or WhatsApp number, country and city, project type, message and preferred language. We also process submission details needed to deliver and manage your request, such as its date and a submission reference. Please do not include health information or other sensitive personal details in your message.

The information marked as required, including a suitable contact method, is necessary for us to handle and answer your request. You choose whether to send the request and whether to provide optional details. Without usable contact details, we cannot respond.

Why we use your information. We process information necessary to respond to your consultation request and take steps at your request before a possible contract under Article 6(1)(b) GDPR. Where applicable, legal obligations are based on Article 6(1)(c). Protecting the service against abuse and retaining strictly necessary evidence to establish or defend legal claims are based on our legitimate interests under Article 6(1)(f), subject to your rights and interests.

Submitting a consultation request does not subscribe you to a newsletter or authorise unrelated promotional emails, calls or messages. We use the request to discuss the project you have asked us about. Optional website measurement is a separate choice.

Who receives the information. The team responsible for your project uses your details. The website is hosted through IONOS. Requests are managed in the customer relationship service supplied by Good Company LTD through Squadd, using the HighLevel platform. These technical providers process information needed to host, operate and support the services. Necessary information may also be disclosed to professional advisers or competent authorities where a legal obligation or a specific legal claim requires it.

International processing. Service provision may involve processing outside the European Economic Area, including in the United States. The Squadd Data Processing Agreement provides for the applicable safeguards, including adequacy decisions, the EU–US Data Privacy Framework where applicable, or standard contractual clauses. You can read that agreement and contact Fabrizio Vassallo at f.vassallo@solariumsmart.it for information about the safeguards relevant to the processing of your data and how to obtain a copy.

How long we keep new consultation details. We keep a prospective customer’s request only while it is needed for the project, and for no more than 24 months from your latest request or active exchange with us about the project. Internal changes to a record or an unanswered message from us do not restart that period. Fabrizio Vassallo oversees retention reviews. At the end of the applicable period, information that is no longer needed is deleted or irreversibly anonymised.

If a contract is in progress, or specific information must be retained to meet a legal obligation or establish or defend a legal claim, we retain only what is necessary for that purpose for the applicable period. Access is limited accordingly. This longer retention does not authorise unrelated promotional contact.

Cookies and measurement. Google Analytics 4 is used only with your Analytics consent; Meta Pixel is used only with your separate Marketing consent, as explained below. You can accept either category, both, or neither. The website stores the choices you make in Cookie settings in your browser so it can respect them on later visits. These choices do not subscribe you to promotional communications.

Your browser preference is stored for up to 180 days and can be changed at any time. If you choose Marketing, campaign and advertising-click identifiers in the link may be associated with the request in our CRM to understand its source; this processing is based on your consent. The website also processes technical connection information, such as IP address and browser information, as needed to operate and protect the service.

Your rights. Subject to the conditions in applicable law, you may request access to your personal data, correction, erasure, restriction of processing and portability. You may object to processing based on legitimate interests and withdraw consent for processing based on consent, without affecting the lawfulness of earlier processing. Contact f.vassallo@solariumsmart.it and describe your request; we may ask for proportionate information to verify your identity. You may lodge a complaint with the Italian data protection authority, Garante per la protezione dei dati personali, or another competent supervisory authority.

We do not make decisions about your consultation request solely by automated means that produce legal or similarly significant effects.

Google Analytics 4: optional website statistics

With your consent to Analytics, TRON Private uses Google Analytics 4 to understand how visitors use the website and where consultation requests originate. You can refuse Analytics and still browse the site or request a consultation. The legal basis for this optional measurement is your consent under Article 6(1)(a) GDPR.

Information involved. We measure page visits, consultation-button clicks, the start of a form and accepted consultation requests. Starting or attempting to submit a form is not recorded as an accepted request. The parameters added by TRON describe the page language, the form and the relevant button or page. We do not add your name, email address, telephone number, free-text message or CRM record identifier to Analytics events. Approved campaign parameters may be included when you also consent to Marketing.

Google also processes pseudonymous browser identifiers, session and engagement information, page addresses and referring origins, and browser/device information. Connecting to Google’s service discloses your IP address to Google. This measurement is not anonymous. TRON does not use Google Signals, advertising personalisation, User-ID, user-provided data collection or Google Ads integration for this measurement.

Cookies. Analytics uses first-party cookies scoped to the TRON Private hostname:

Browser restrictions, withdrawal or deletion can shorten these durations. The session cookie can remain beyond 180 days from its first creation because its expiry is renewed when it is written again. These are TRON’s settings rather than Google’s default two-year duration. See Google’s cookie information.

Retention. TRON sets user-level and event-level Analytics retention to 2 months, without restarting the user-retention period on new activity. Google’s deletion runs periodically. Standard aggregated reports are not governed by that setting and may remain available longer. This period is separate from cookie lifetimes and the consultation-record policy above. Google explains retention here.

Provider and international processing. Google Analytics is supplied by Google Ireland Limited, Ireland. Smart Technologies Srl determines the purposes of this website measurement; Google processes Analytics customer data under the Google Ads Data Processing Terms. Processing may involve Google affiliates or service providers outside the European Economic Area, including the United States. Google describes the applicable safeguards, including the EU–US Data Privacy Framework for covered transfers and standard contractual clauses where applicable, in its international-transfer information. Further information is available in Google’s Privacy Policy.

Your choice. Use Cookie settings to withdraw Analytics consent at any time. The site blocks further Analytics measurement by this integration and attempts to remove its Analytics cookies. Withdrawal does not affect earlier lawful processing or automatically erase data already received by Google. You can also remove cookies through your browser and exercise the rights described above by contacting Fabrizio Vassallo.

Meta Pixel: optional advertising measurement

With your consent to Marketing, TRON Private uses Meta Pixel to measure visits and consultation requests associated with its advertising. You can refuse this choice and still browse the site or request a consultation. This consent covers website measurement; it does not subscribe you to promotional emails, calls or WhatsApp messages. Analytics consent is a separate choice.

What is sent. The site sends a PageView event for a page visit and a Lead event only after the website accepts a consultation submission. The parameters added by TRON are the page language and, for Lead, the form name. Your name, email address, telephone number and free-text message are not sent to Meta as event parameters. Automatic advanced matching and the Conversions API are not used for this TRON integration.

The Pixel also involves technical information such as the page address, event time, browser/device information, IP address and cookie or advertising-click identifiers where available. Meta may associate received information with information it already holds, including an account you use with Meta, in accordance with its privacy policy and your settings. The measurement is therefore not described as anonymous.

Cookies. After your Marketing consent, Meta may set the following cookies on the website’s domain:

These are browser-cookie lifetimes. Browser restrictions or deletion can shorten them. Under section 4 of the Meta Business Tools Terms, Meta retains Event Data for a maximum of two years. The 90-day cookie duration and the Event Data retention period are separate; neither replaces the retention policy for your consultation details. Meta describes its cookie use in its Cookies Policy and other processing in its Privacy Policy.

Provider and responsibilities. The European provider is Meta Platforms Ireland Limited, Ireland. Under the Meta Business Tools Terms, Smart Technologies Srl is the controller for matching, measurement and analytics performed for us, and Meta Ireland acts as processor under the Data Processing Terms. For the collection and transmission of event data for which we and Meta jointly determine purposes and means, we act as joint controllers under the Controller Addendum. Meta Ireland acts as an independent controller for subsequent processing after transmission. Meta may use received information for its own advertising and other purposes described in its Privacy Policy, taking your choices into account.

The Controller Addendum, incorporated into the Business Tools Terms agreed between Smart Technologies Srl and Meta Ireland, assigns responsibilities for this joint collection and transmission. Smart Technologies Srl provides the information about the site’s purposes, processing and your rights. Meta Ireland is responsible for responding to requests under Articles 15–20 GDPR concerning personal data stored by Meta after the joint processing. You can exercise your rights under Articles 15–21 directly with Meta through the contact routes in its Privacy Policy. You can also contact Smart Technologies Srl through Fabrizio Vassallo at f.vassallo@solariumsmart.it about your rights or this arrangement.

International processing. Meta’s Privacy Policy explains that information may be processed in the United States and other countries. It describes reliance on adequacy decisions, including the EU–US Data Privacy Framework for covered transfers to Meta Platforms, Inc., and standard contractual clauses in other circumstances. The policy explains how to obtain further information about these safeguards.

Your choice. The legal basis for TRON’s optional Pixel measurement is your consent under Article 6(1)(a) GDPR. Use Cookie settings to withdraw Marketing consent at any time. This stops new Pixel measurement from this website in that category. Withdrawal does not affect the lawfulness of prior consent-based processing or automatically erase information already received by Meta. You can also remove cookies using your browser controls and exercise the rights described in the main TRON privacy information or Meta’s Privacy Policy.