Privacy Policy
Last updated: November 3, 2026
1. Data controller and contact details
The data controller for the website pompeirealty.com is Pompei Immobiliare S.r.l.s., registered at Via di Parione 21, 00186 Rome, Italy, VAT and tax no. 14986811009, REA RM-1560185 (the “Controller”).
The Vacation Homes and Interior Design services are provided by Pompei Realty S.r.l.s., a separate company registered at Via di Sant’Elena 8, 00186 Rome, Italy, VAT and tax no. 13772791003, REA RM-1471671, PEC pompeirealty@pec.it (“Pompei Realty”). See section 4.
YUKI di Luca Danilo Follega and TEC di Filippo Mancinelli (jointly “YukiTec”) are the data processors for the site, under the data processing agreement of 24/07/2026.
For questions about personal data or to exercise the rights described in this notice:
- email: info@pompeirealty.com
- post: Via di Parione 21, 00186 Rome, Italy
- for technical questions: privacy@yukitec.com (requests about your rights are passed on to the Controller)
2. Personal data we process
- Data you enter in the forms (contact form, enquiry about a home, the Giulia assistant): name, email address, phone if given, enquiry type and message.
- For rental enquiries only, if filled in: budget, length of stay, desired start date and your answer about proof of income. The site does not ask for or receive any documents.
- Data linked to the enquiry: the property and page you write from, the form used, your confirmation that you have read this notice, and the date and time sent.
- Free text: open fields can contain whatever you choose to write. Please do not include unnecessary information or special categories of personal data.
- Technical data: IP address and browser data, processed by the hosting systems and the providers in section 4 to deliver pages and protect the site. To limit abuse of the forms, the website’s database keeps only a salted hash of the IP address, never the address itself; the server holds the address in memory only briefly, for the same purpose.
- Browsing data, only with your consent: statistics collected by Google Analytics (section 8).
- Staff authorised to use the administration area: name, email, role, sign-ins and a change log (who changed what, and when). Passwords are never recorded in readable form. Failed sign-in attempts record the email address entered.
Giulia is an assistant with preset answers, not an artificial intelligence system. The choices made in the conversation are not saved; only the data you enter in her form (name, email) reaches the Controller, with the topic and property concerned, through the same route as the other forms.
3. Purposes, legal bases and whether data must be provided
- Purpose
- Responding to enquiries about homes, rentals, sales, buyers agent, interior design and landlord services
- Data
- Form and enquiry data
- Legal basis
- Pre-contractual steps at your request (Art. 6(1)(b) GDPR); for general enquiries, legitimate interest in replying (Art. 6(1)(f))
- Purpose
- Recording and routing enquiries to the team, so none is lost
- Data
- Form and enquiry data
- Legal basis
- The same as the enquiry
- Purpose
- Passing to Pompei Realty enquiries expressly concerning Vacation Homes, Interior Design or vacation-home management
- Data
- Form and enquiry data
- Legal basis
- The legitimate interests of the Controller and Pompei Realty in routing and responding to enquiries concerning services provided by Pompei Realty (Article 6(1)(f) GDPR). The disclosure is limited to enquiries expressly concerning those services.
- Purpose
- Operating the site and administration area, showing photos, videos and maps, security, preventing abuse, resolving technical problems
- Data
- Technical data, IP hash, sign-ins and change log
- Legal basis
- Legitimate interest in the security and operation of the site (Art. 6(1)(f))
- Purpose
- Measuring use of the site with Google Analytics
- Data
- Browsing data and online identifiers
- Legal basis
- Consent (Art. 6(1)(a)), which can be withdrawn at any time
- Purpose
- Complying with legal obligations or protecting the Controller’s rights
- Data
- Data strictly necessary
- Legal basis
- Legal obligation (Art. 6(1)(c)) or legitimate interest (Art. 6(1)(f))
Fields marked as required are needed to receive and handle your enquiry: without them we cannot reply. The others are optional. The checkbox on the forms only confirms that you have read and understood this notice; it is not consent to any further processing. We do not use enquiry data for marketing.
Consent to analytics cookies is optional: if you reject them, the site works the same.
4. How we process data and who may receive it
When you send a form, the enquiry is saved in the website’s database and emailed to the Controller’s mailbox by an automation system. Data is not sold. It may be accessed, within their respective functions, by: the Controller’s authorised staff; Pompei Realty, for the enquiries described below; the processors and sub-processors below; advisers bound by confidentiality, where necessary; and authorities, where required by law.
- Provider
- YukiTec (section 1)
- Function
- Development and technical management of the site and server (data processing agreement of 24/07/2026)
- Role
- Processors
- Location
- Italy
- Provider
- Vercel Inc.
- Function
- Page hosting; processing in Frankfurt, delivery through a global network
- Role
- Sub-processor
- Location
- EU / USA (section 5)
- Provider
- Hetzner Online GmbH
- Function
- Server: database, file storage, automation system and backups
- Role
- Sub-processor
- Location
- Germany
- Provider
- BunnyWay d.o.o. (Bunny)
- Function
- Delivery of photos and videos. When a page shows them, your browser connects to Bunny’s servers, which receive your IP address and browser data
- Role
- Sub-processor
- Location
- Slovenia, EU; global network
- Provider
- Google (Google Workspace)
- Function
- Email: sending and receiving enquiry notifications
- Role
- Processor
- Location
- EU / USA (section 5)
- Provider
- Google (Google Analytics, Tag Manager)
- Function
- Usage statistics, only with your consent
- Role
- Processor
- Location
- EU / USA (section 5)
- Provider
- Hyperknot Software Kft. (OpenFreeMap)
- Function
- Maps. When a page shows a map, your browser connects to this service, which receives your IP address and browser data. No cookies; according to its privacy policy it does not store IP addresses in its access logs, and it may use the Cloudflare network
- Role
- Independent controller
- Location
- Hungary, EU
Pompei Realty. The Controller receives every enquiry sent through the site. If it expressly concerns Vacation Homes, Interior Design or the management of a vacation home, the Controller forwards it to the right person at Pompei Realty. Pompei Realty processes the enquiry independently as a separate controller in order to take pre-contractual steps at the data subject’s request (Article 6(1)(b) GDPR). For these enquiries you can also contact Pompei Realty directly. Vacation home bookings take place on VRBO and do not pass through the site (section 9).
Vercel, Hetzner and Bunny act as sub-processors of YukiTec. Google is directly the Controller’s processor, as the Controller holds the accounts. Hyperknot (OpenFreeMap) is an independent controller.
OpenStreetMap (Nominatim) is used by our server to look up a home’s approximate coordinates from its address, when it is saved in the administration area: it receives no visitor data. BetterStack checks that the site and systems are up: it receives no enquiry or visitor data. Fonts are hosted on our own domain: your browser does not contact Google for fonts. Supabase, Payload CMS and n8n are software installed on our server, not outside providers receiving data.
5. Transfers of personal data outside the EEA
Vercel Inc. and Google are based in the United States and may process data outside the EEA, including for support or maintenance. These transfers are made on the basis of the data processing agreements (DPAs) with these providers: for Vercel, the standard contractual clauses (SCCs) approved by the European Commission; for Google, the SCCs or another approved transfer mechanism, where Google has adopted one. For information or a copy of the safeguards, write to info@pompeirealty.com.
6. Data retention
- Category
- Enquiries in the website’s database
- Period
- Deleted automatically 3 days after being emailed to the team. If delivery is delayed they stay until it has happened, so that no enquiry is lost
- Category
- Daily database backups
- Period
- 14 days: an enquiry may therefore remain in a backup for up to 14 days after deletion
- Category
- Server-level backups
- Period
- Up to 7 days
- Category
- Failed runs of the automation system, which may contain enquiry data
- Period
- Up to 14 days. Successful runs are not saved
- Category
- Enquiry emails in the Controller’s mailbox and at Pompei Realty
- Period
- 6 months from the last contact. If the contact stays active or becomes a contract, for as long as needed to handle it and as the law requires
- Category
- IP hash for limiting abuse
- Period
- 1 day
- Category
- Hosting technical logs
- Period
- Up to 30 days
- Category
- Your cookie choice
- Period
- 6 months in your browser, then we ask again. You can change it sooner at any time
- Category
- Google Analytics data
- Period
- 14 months
- Category
- Change and sign-in log of the administration area
- Period
- 12 months
- Category
- Administration accounts
- Period
- For as long as access is enabled; deleted within 30 days after it ends
At the end of these periods data is deleted or anonymised, unless further retention is necessary to comply with a legal obligation or to establish, exercise or defend a legal claim.
7. Your rights
Subject to the conditions set by law, you may ask for access to your data, rectification, erasure or restriction of processing; object to processing based on legitimate interests; and, where applicable, request data portability. Where processing is based on consent you may withdraw it at any time, without affecting the lawfulness of earlier processing. Write to info@pompeirealty.com. You may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali); its contact details and procedures are on its institutional website.
9. Links to external websites and services
The site contains links to external platforms: the booking button on vacation homes opens VRBO, and there are links to Facebook and Instagram. If you follow them, further processing is carried out by those providers under their own notices. The site does not handle bookings or payments.
10. Automated decision-making
The site makes no decisions based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect users. Giulia follows a scheme of preset answers and does not use artificial intelligence.
11. Changes to this notice
We may update this notice to reflect changes to the site, processing activities or applicable requirements. The updated version is published on this page with its latest update date.
