Privacy & Cookie Policy

1. Data controller

The controller of personal data collected through this website is:

• Controller: Davide Osto
• Contact: info@eircosmetics.com

For any request regarding your data you can write to the email address above; we will reply as soon as possible.

2. What data we collect

We collect two categories of data:

• Data you provide voluntarily: through the "Notify me at launch" form, we collect your email address and the consent you give by ticking the checkbox.
• Data collected automatically: during normal browsing of the site, our hosting and security provider (Cloudflare) collects technical data (IP address, user-agent, request timestamps, pages visited) necessary for the network's operation and security.

We do not collect special categories of data (e.g. health data).

3. Why we process data and on what legal basis

Providing data for the waitlist signup is optional, but without it we cannot notify you at launch. Technical browsing data, on the other hand, is collected automatically and is necessary for the service to run, regardless of whether you sign up via the form.

4. How data is processed

Data entered in the site's form (email) is stored in a Cloudflare D1 database with jurisdiction set to the European Union (data is therefore stored and processed exclusively on European infrastructure), accessible by the controller to manage the launch notification.

Technical browsing data (IP, access logs) is processed by Cloudflare as a data processor, as part of its hosting, CDN and abuse-protection services, according to its standard log retention policy.

5. How long we keep it

• Waitlist signup: until EIR launches or consent is withdrawn, and in any case no longer than 24 months, unless otherwise required by law.
• Technical security logs: according to Cloudflare's standard retention periods for security purposes.

6. Who we share data with

Your data is not disclosed or sold. It may be processed by technical service providers acting as data processors, solely for the purposes stated above:

• Cloudflare, Inc. — website hosting (Cloudflare Pages), subscriber database (Cloudflare D1), DNS management and security services (protection from malicious traffic).

The domain is registered through Porkbun LLC, which acts as registrar: it processes the domain holder's data but not the browsing data of site visitors.

7. Data transfer outside the European Union

Cloudflare, Inc. is based in the United States. For transfers of data to the US, Cloudflare primarily relies on its own active certification under the EU-U.S. Data Privacy Framework (DPF), recognized by the European Commission's adequacy decision. Should that certification lapse or be invalidated, Cloudflare falls back on the Standard Contractual Clauses (SCCs) approved by the European Commission, together with the necessary supplementary measures. These mechanisms guarantee an adequate level of protection under Chapter V of the GDPR.

8. Automated decisions

Your data is not subject to any automated decision-making process or profiling activity.

9. Your rights

You can exercise the rights set out in Articles 15-22 of the GDPR at any time:

• access your data and request a copy of it;
• request its rectification or erasure;
• restrict or object to its processing;
• withdraw consent at any time (without affecting processing already carried out);
• request data portability;
• lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

To exercise your rights, write to info@eircosmetics.com.

10. Cookies

This site does not use profiling cookies and, at present, does not set any technical cookie either: no Cloudflare features requiring cookies are active (Bot Management/Bot Fight Mode, Turnstile, Load Balancer, Waiting Room). Should any of these features be enabled in the future, this notice will be updated accordingly.

Fonts are hosted directly on the site: displaying them does not involve any connection to external servers nor the transmission of your IP address to third parties.