Privacy Policy

This Privacy Policy explains how History Mind Winter processes personal data through historymindwinter.garden in connection with insurance selection services for retirees. It describes what we collect, how we use it, when we share it, and the choices and rights available to individuals under applicable law.

Effective Date As stated in policy
Scope All users of our services
Questions Contact
GDPR

GDPR Overview

We act as a controller for the personal data processed through this website unless we state otherwise for a specific activity. Processing is based on one or more lawful grounds, such as consent, performance of a contract or pre-contractual steps, legal obligation, or our legitimate interests where those interests are not overridden by the rights and freedoms of the individual.

Where GDPR applies, it governs our processing of personal data of individuals located in the European Economic Area and, in some cases, related processing carried out in connection with our services.

This section is intended for individuals protected by the GDPR.
GDPR Rights

GDPR Rights

Where GDPR applies, individuals may have the right to access, rectify, erase, restrict, or object to processing, and to receive data portability in certain cases. Where processing is based on consent, consent may be withdrawn at any time without affecting prior processing. Individuals may also lodge a complaint with the competent supervisory authority.

The rights described here apply subject to the conditions and limits set by law.
Data category

Data We Collect

We may collect identification details, contact details, age or retirement-related information, insurance preferences, communication content, technical identifiers, and usage data. Where needed for insurance selection services, we may also process information that helps assess suitability or prepare a response to a request.

The categories collected depend on the form, inquiry, or service step used.
Collection source

Sources of Data

We receive data directly from users when they submit forms, request information, or communicate with us. We also collect certain data automatically through the website, such as device and browsing information. In some cases, we may receive limited information from service providers that support hosting, analytics, security, or communication functions.

Information may come from the user, device activity, or service providers involved in site operation.
Cookie type

Types of Cookies

Essential cookies support core site functions, security, and form handling. Functional cookies remember basic choices and improve usability. Analytics cookies help us understand how the site is used and whether pages perform as expected. Cookies may be session-based or persistent, depending on their purpose.

The site uses essential, functional, and analytics cookies, with limited tracking where permitted.
User control

Cookie Controls

Users may block or delete cookies through their browser settings. Some cookies are necessary for the website to function and may not be fully disabled without affecting performance. Where the site provides a cookie banner or preference tool, users can use it to adjust non-essential cookies.

Cookie preferences can be managed through browser settings and, where available, site controls.
User Rights

Your Rights

Depending on applicable law, individuals may have rights relating to access, correction, deletion, restriction, objection, and portability of personal data. Some rights apply only in specific circumstances, and we may need to verify identity before responding. If a request cannot be fully granted, we will explain the reason where required.

Available rights depend on the legal basis and the context of processing.
Requests

Submitting Requests

To exercise a privacy right, individuals should provide enough information for us to identify the relevant data and the nature of the request. We may ask for additional details to confirm identity or to understand the scope of the request. If a request is complex or numerous, the response period may be extended as allowed by law.

Requests are handled after identity checks and any legally required review.
Data Retention

Retention of Data

We retain personal data for the period necessary to provide the requested service, manage our records, resolve disputes, meet legal obligations, and support security and audit needs. When data is no longer needed, we delete it or anonymise it, unless a longer retention period is required or permitted by law.

Data is kept only for as long as needed for the relevant purpose or legal requirement.
Policy Updates

Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our processing practices, legal requirements, or the services we provide. The updated version will apply from the date it is posted unless a different effective date is stated. Where changes are material, we will take reasonable steps to draw attention to them.

We review this policy when our practices or legal obligations change.
Privacy Office

Contact Information

Privacy email
Telephone
+39 312 688 3262
Mailing address
Corso Secondigliano 171, 80144 Naples
Privacy contact
Processing category

Purposes of Processing

We use personal data to respond to inquiries, provide insurance selection support, manage communications, operate and secure the website, analyse usage, maintain records, comply with legal duties, and handle disputes or claims. Where required, we also use data to assess whether a request can be processed and to carry out related administrative tasks.

Processing is limited to the operational and legal purposes described below.
Third-party sharing

Service Providers

We may share personal data with hosting providers, technical support providers, analytics services, communication tools, and other vendors that assist with operating the website and delivering our services. These parties act under contractual or similar obligations and may process data only for the purposes we specify.

Service providers receive only the information needed to perform their functions.