Privacy Policy
The details you send us (name, phone and email) are used only to prepare your growth audit and to communicate with you as a prospect or client. They are never sold, rented or traded to third parties.
1. Who we are
Data Controller: Rayen Frost (Codice Fiscale: [INSERT_YOUR_CF_LATER]), Turin, Italy. Email: [email protected]
This Privacy Policy explains how Rayen Frost, working under the name Rayen Frost Agency as an individual on an occasional, self-employed basis (prestazione occasionale) ("we", "us", "our"), collects and uses personal data through the website rayenfrost.com. Rayen Frost is the data controller of the personal data described here, under Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).
For any question about this policy or your data, contact us at [email protected].
2. What data we collect
Data you give us through the Growth Audit form
- Identity and contact details: your full name, phone or WhatsApp number and email address.
- Business details: your business name, automotive sub-niche and monthly revenue range.
- Your consent record: confirmation that you ticked the consent box, with the date, time and language of your submission.
Data you give us when we talk
If we speak by phone, WhatsApp, email or video call, we keep the messages you send us and our own notes about your business needs, so we can prepare your audit and any proposal.
Technical data
When you visit the site, our hosting and security provider automatically processes technical data such as your IP address, browser type and the pages requested. This is needed to deliver the website, keep it secure and prevent abuse. We do not use this data to identify you or to build a profile of you.
We do not ask for, and ask you not to send, special categories of data (such as health, religion or political opinions).
3. Why we use your data and our legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Preparing and delivering the free growth audit you requested, and contacting you about it by phone, WhatsApp or email. | Steps taken at your request before entering into a contract (Art. 6(1)(b)) and your consent given through the form (Art. 6(1)(a)). |
| Communicating with you as a client: proposals, onboarding, service delivery, reporting and support. | Performance of a contract (Art. 6(1)(b)). |
| Keeping receipts and tax records of payments once you become a client. | Compliance with legal obligations (Art. 6(1)(c)). |
| Keeping the website secure, preventing spam and fraudulent form submissions. | Our legitimate interest in protecting our website and services (Art. 6(1)(f)). |
| Defending or exercising legal claims, if ever needed. | Our legitimate interest (Art. 6(1)(f)). |
Your data is used strictly for lead generation audits and client communication. We do not use it for unrelated marketing, and we never sell it. We will only send you promotional newsletters if you separately ask to receive them, and you can opt out at any time.
5. Transfers outside the European Economic Area
Some of the providers listed above are based in, or use servers located in, countries outside the European Economic Area (EEA), including the United States. When your data is transferred outside the EEA, we make sure it is protected by an appropriate safeguard under Chapter V of the GDPR: a European Commission adequacy decision (such as the EU–US Data Privacy Framework, for certified providers) or the European Commission's Standard Contractual Clauses. You can contact us for more information about these safeguards.
6. How long we keep your data
- Audit requests that do not become clients: up to 12 months from our last contact with you, then deleted, unless you ask us to delete them sooner.
- Clients: for the duration of our working relationship, then for as long as Italian tax law requires us to keep records of the payments we receive.
- Technical and security logs: for the short periods set by our hosting provider, unless needed to investigate an incident.
If you withdraw your consent, we stop contacting you about the audit straight away. We may keep a minimal record that you withdrew it, so we respect your choice in the future.
7. Your rights
Under the GDPR (Articles 15 to 22) you have the right to:
- Access the personal data we hold about you and receive a copy.
- Rectify data that is inaccurate or incomplete.
- Erase your data ("right to be forgotten"), where there is no legal reason for us to keep it.
- Restrict our processing of your data in certain circumstances.
- Data portability: receive the data you gave us in a structured, machine-readable format, or have it sent to another organisation.
- Object to processing based on our legitimate interests.
- Withdraw your consent at any time. This does not affect processing carried out before you withdrew it.
To exercise any of these rights, email [email protected]. We will reply within one month, as required by the GDPR. We may ask you to confirm your identity before acting on a request.
You also have the right to lodge a complaint with the Italian data protection authority: Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, Italy (www.garanteprivacy.it), or with the supervisory authority in the EU country where you live or work.
8. Cookies and local storage
This website does not use advertising, analytics or tracking cookies, and we do not use your data for profiling.
The site uses your browser's local storage, on your own device only, for a few functional purposes:
- Remembering the language you choose (English, Italian or French).
- Keeping a copy of the details you submit through the Growth Audit form on your own device, so the confirmation works smoothly. This copy is not sent anywhere by your browser.
These items are strictly necessary for features you use, so they do not require separate consent. You can delete them at any time by clearing your browser's site data for rayenfrost.com.
9. How we protect your data
We use appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access. These include encrypted connections (HTTPS) across the website, access to personal data limited to people who need it to work with you, and providers that maintain recognised security standards. No method of transmission over the internet is completely secure, but we work to protect your data and will notify you and the Garante of any data breach where the law requires it.
10. Client data and AI systems
This policy covers data about visitors, prospects and clients of Rayen Frost Agency. When we run lead generation and booking systems for a client, we may process personal data of that client's own customers and prospects on the client's behalf. In that case the client is the data controller and we act as a data processor under a separate data processing agreement (Article 28 GDPR).
We do not make decisions about you based solely on automated processing, including AI tools, that produce legal or similarly significant effects for you.
11. Children
Our services are aimed at businesses and are not directed at anyone under 18. We do not knowingly collect personal data from minors. If you believe a minor has sent us personal data, contact us and we will delete it.
12. Changes to this policy
We may update this Privacy Policy when our services or the law change. The "Last updated" date at the top shows when it was last revised. If we make significant changes that affect how we use data you have already given us, we will tell you directly.
13. Contact us
Data Controller: Rayen Frost (Codice Fiscale: [INSERT_YOUR_CF_LATER]), Turin, Italy. Email: [email protected]
Website: rayenfrost.com