Privacy policy

1. Who the data controller is

The data controller is Vittorio Halfon, owner of the sole proprietorship trading under the name Vilmor, with registered office at Via Bartolomeo D'Alviano 24, 20146 Milan (MI), Italy, VAT no. 14871950961.

For information about the processing or to exercise your rights, you can write to privacy@vilmor.it.

2. What data we process

• Contact requests: name, WhatsApp number, email and description of the business entered in the form on the Italian Contact page; name, email, company and role, message and, if you give it, phone number entered in the form on the English Contact page.
• WhatsApp messages: if you write to our WhatsApp Business number, from the site or directly, your number, profile name and the messages you send.
• Email: if you write to one of our addresses, the sender's address and the content of the message.
• Conversation and appointments: messages, answers to questions, information about the business and its needs, the outcome of the qualification, and any availability and bookings.
• Technical data: IP address, browser information, server requests and any errors, processed to deliver and protect the site and prevent abuse.
• Anonymous statistics, without consent: pages visited, referrer, browser and device type and form submission events, collected by PostHog without cookies and without persistent identifiers; technical page errors. Browser and IP address are used only to calculate an anonymous identifier that changes every day, and are not stored.
• Measurement data, according to the consent given: pages visited, referrer, interactions, cookie identifiers, campaign parameters and form submission events.
• Outcomes of requests, in pseudonymous form: how a request progresses (qualification, appointment, proposal, contract or closure), with the arrival channel, the campaign parameters recorded on the contact and, for a contract, its value.

Please send only information relevant to your request, avoiding health data, other particularly sensitive information and unnecessary data about third parties.

3. Why we process it and on what legal basis

Responding to your request and showing you the service. We use the data from the forms, messages and conversation to reply to you, understand whether Vilmor is right for your business and arrange any appointment. For pre-contractual requests made by the data subject, the basis is Art. 6(1)(b) GDPR. If you contact us on behalf of a company, the basis is our legitimate interest in managing professional relationships and requests, Art. 6(1)(f).

Running and protecting the site. We process the technical data needed for transmission, security and the prevention of spam and repeated submissions, on the basis of our legitimate interest in the security of the service, Art. 6(1)(f), and of the rules applicable to strictly necessary technical tools.

Understanding how the site is used. PostHog, on infrastructure in the European Union, records page views and events anonymously, without writing cookies or persistent identifiers on the device. To distinguish visits on the same day, it calculates on its own servers an anonymous identifier from the date, browser, IP address and site, which changes every day: browser and IP address are used only for that calculation and are not stored. It also records technical page errors (message and point in the code) so that we can fix them. This is aggregated statistics in our legitimate interest in knowing how the site is used, Art. 6(1)(f), under the conditions set by the Italian Data Protection Authority (Garante) for analytics tools. With consent to statistics, Art. 6(1)(a), PostHog uses a cookie to recognize the same browser on later visits and across vilmor.it and websites.vilmor.it, records click and scroll positions for heatmaps and clicks on elements that don't respond, and Google Analytics 4 and Microsoft Clarity are switched on. Clarity analyzes interactions, heatmaps and session replays, with forms marked for masking. PostHog also measures page performance (Web Vitals) and, after a choice made on the updated banner, records browsing sessions. Form fields and the number shown after submission are masked, hidden fields are excluded and console recording is disabled. Without consent to statistics, no Web Vitals, heatmaps or session recordings are collected. Ad click identifiers are sent to PostHog only with consent to marketing. The calculator processes the numbers in the browser: the values you enter don't reach us; we record only which fields are changed and a band of the result.

Measuring advertising campaigns. Meta Pixel and the Conversions API link visits and requests to Facebook and Instagram campaigns, after consent to marketing, Art. 6(1)(a). With the consent given on the updated banner, we also tell Meta whether the request progresses: whether you write to us on WhatsApp from the site's button and whether you book a call (details in section 5). With the same consent, the OpenAI pixel links visits and requests to advertising campaigns on ChatGPT.

Understanding which campaigns bring customers. When a request progresses, HighLevel tells our site, which sends PostHog only the outcome, the stage reached, the arrival channel (form or WhatsApp), the campaign parameters recorded on the contact and, for a contract, its value. Name, number, email, company and the text of conversations are not sent: the contact is identified by a pseudonymous code, calculated by the site with a secret key. If you have accepted statistics on the updated banner, the contact form also sends HighLevel the identifier with which PostHog recognizes your browser, and outcomes are linked to your visits to the site. The basis is our legitimate interest in assessing the effectiveness of campaigns, Art. 6(1)(f); the link with visits is based on consent to statistics, Art. 6(1)(a), and withdrawing it stops the link for later requests.

Meeting legal obligations and protecting rights. Where applicable, we keep the information needed for legal obligations, Art. 6(1)(c), or to establish, exercise and defend rights, Art. 6(1)(f).

4. What happens on WhatsApp

When you write to us on WhatsApp, or after you submit the form on the Italian Contact page, you get a reply from Vilmor's AI employee: an assistant based on artificial intelligence, which presents itself as such and uses your answers to ask follow-up questions and assess whether the service is a fit. Messages sent from the form on the English Contact page are not passed to the AI employee: we reply by email.

The assessment covers, for example, how you receive and handle requests, response times and the needs of your business. It may steer the conversation towards proposing an appointment, a different path or an indication that the service isn't a fit. The system is not used to take, on its own, decisions with legal or similarly significant effects. You can ask to speak with a person and to have the outcome reviewed, including by writing to the address above.

The request does not sign you up to a newsletter. Any automatic messages that follow concern the request, the qualification or the related appointment. You can reply STOP to stop them. Stopping the messages is not the same as asking for all data to be deleted: for that request you can contact us directly.

This policy covers the site and the conversation with Vilmor. Any systems installed at client companies have processing roles and instructions defined in the respective agreements.

5. Cookies and sending events to Meta and OpenAI

With marketing consent on the updated banner, we keep the campaign parameters and supported click identifiers in the browser tab and attach them to the request forwarded to HighLevel, to attribute its source. Without that consent, the server does not forward them. Statistics events for clicks on actions, starting to fill in a form, submission attempts and form errors report path, position, error categories and campaign parameters; with marketing consent they also include supported click identifiers. They do not report the values entered in the form fields.

You can use the forms even if you decline statistics and marketing. Google Tag Manager manages the loading of tags; its technical request to the provider takes place when the site opens. Statistics and advertising tags are switched on according to the preferences expressed in the banner.

If you accept marketing, the server sends Meta a request event in two cases: when the form on the Italian Contact page is forwarded successfully, and when you click a button that opens the WhatsApp chat with us, once per visit. The form event may include the available first name, last name, phone and email, transformed with a SHA-256 hash; both include IP address, browser information, page URL and any Meta identifiers present, such as _fbp and _fbc. The click sends only the fact that you opened the chat. The events also include the country estimated from the IP address and, with consent to statistics, a pseudonymous identifier derived by hashing the one with which PostHog recognizes your browser. The form on the English Contact page does not send events to Meta.

If you have accepted marketing on the updated banner, we also tell Meta about two later steps: that you started the conversation, when you write to us on WhatsApp from the site's button, and that you booked a call with us. These events contain the phone number transformed with a SHA-256 hash, the country derived from the dialling code and, if you had also accepted statistics, the same pseudonymous identifier, so that Meta can link them to the click on the ad. The content of messages is never sent to Meta. To recognize that the message comes from your visit, with marketing consent the button adds to the pre-filled text, right after «Ciao,», a few invisible characters containing a random code for the browser, kept until marketing consent is withdrawn. The site reads the first message only to extract that code, and links the message to the visit only if the code matches that of a click on the button. If the code is missing or has been deleted, we send nothing. To do this we record in PostHog, when the WhatsApp button is clicked, the browser's code and which consents you had given; at the first message, or when the form is submitted with consent to statistics, we record proof of marketing consent associated with the contact's pseudonymous code or with the PostHog identifier, valid for 28 days, together with the browser's PostHog identifier when you had accepted statistics. If you withdraw marketing, or statistics, from the banner, we record it with the code and the browser's identifier: the later conversation and call are not sent. The call is sent only if you had also accepted statistics, because without it we cannot check a later withdrawal. To check that this mechanism works, we record in PostHog, against the contact's pseudonymous code, whether each of the two steps was reported to Meta or the reason why it wasn't, for example consent missing or withdrawn, or a missing code.

Hashing is a pseudonymization measure: the data remain personal and can be matched by Meta to its own users. Without marketing consent, this server-side sending does not take place. Withdrawal prevents new sending based on that consent, without retroactively canceling what has already been sent.

From 12 November 2026, Meta is introducing on-device conversion measurement in the pixel. According to Meta, the pixel may use on your device data you have already entered, such as the email in a form, and temporary device data to recognize a conversion linked to a campaign; this data stays on the device, and Meta receives only the information that the conversion took place and which campaign to attribute it to. This happens only if you have accepted marketing: without that consent the pixel is not loaded.

Consent to marketing also switches on the OpenAI pixel. It records page views, form submissions and, if you arrive from an ad on ChatGPT, the campaign identifier in the page address. The pixel uses OpenAI's automatic advanced matching: it may detect data entered in forms, such as email and phone number, normalize them and transform them with a hash in the browser before sending. After the form on the Italian Contact page is forwarded successfully, the site also passes the pixel the available email and phone, normalized and transformed with a SHA-256 hash in the browser, to link the request to the campaign even when the form is no longer visible. These identifiers are not added to the statistics events sent to Google Analytics or PostHog. Here too the data remain personal and can be matched by OpenAI to its own users. Without marketing consent the pixel is not loaded; withdrawal stops further sending.

You can change your choice from Cookie preferences. Details of the tools, cookie durations and withdrawal are in the cookie policy.

6. Providers and recipients

The data are accessible to the controller and to authorized people who need them for the purposes described. The services used include:

• Vercel: hosting, site delivery and technical infrastructure.
• Cloudflare: delivery of the demo video files from the media.vilmor.it domain, without cookies; it receives the technical data of the request, such as IP address and browser information.
• HighLevel / LeadConnector: management of contacts, conversations, automations, the AI employee and appointments. AI features may involve the sub-processors listed in the HighLevel documentation.
• WhatsApp / Meta: delivery and management of WhatsApp messages; Meta also provides the advertising tools described above.
• PostHog: usage statistics, pseudonymous outcomes of requests, technical errors, page performance, heatmaps and session replays (PostHog Inc., European cloud instance with data stored in Frankfurt, Germany).
• Google: Tag Manager and, with consent to statistics, Analytics 4.
• Microsoft: Clarity, switched on with consent to statistics.
• OpenAI: measurement of advertising campaigns on ChatGPT, with consent to marketing.

Providers may act as processors for the services provided to Vilmor and, for activities they determine independently, under their own policies. Advisers and authorities may also receive data when necessary for legal obligations or the protection of rights. Vilmor does not sell contacts' data.

7. Processing outside the European Economic Area

Using these providers may involve processing in the United States or other countries outside the European Economic Area. The applicable safeguards depend on the recipient and the service: they may include adequacy decisions, including the Data Privacy Framework for participating organizations and covered processing, or standard contractual clauses and the additional measures required.

You can ask for information about the applicable safeguards and a copy of the relevant ones by writing to privacy@vilmor.it. The data processing agreements of HighLevel, Vercel, Cloudflare and PostHog are also available; PostHog data remain in the European Union.

8. How long we keep the data

For requests that do not lead to a relationship, the planned period is at most 24 months from the last contact, unless a deletion request that can be granted is made earlier or there are documented needs to protect rights. If a contractual relationship arises, the necessary data are kept for managing it and for the applicable legal obligations.

The minimum elements needed to respect a request not to be contacted again may be kept to avoid new unwanted messages. Technical data are kept for the time needed for management and security, taking any incidents into account. Cookie durations are listed in the cookie policy; their expiry does not necessarily coincide with the deletion of data already received by the providers.

9. Which data are required

Providing data is voluntary. The required fields of the forms serve to handle the path you choose: without a valid WhatsApp number we cannot start the conversation, and without an email address we cannot reply to the English form. Consent to statistics and marketing is optional and does not affect your ability to contact us.

10. Your rights and how to exercise them

In the cases and within the limits provided by the GDPR, you can request access, rectification, erasure and restriction of processing; obtain portability where applicable; object to processing based on legitimate interest; and withdraw consent at any time. Withdrawal does not affect the lawfulness of earlier processing.

Write to privacy@vilmor.it. We normally reply within one month; any extensions in the cases provided by the GDPR are communicated with the reasons. If necessary, we may ask for proportionate information to verify your identity.

You can lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or the competent supervisory authority, and use the other remedies provided by law.

This policy describes the processing configured at the date shown. We will update it if tools, purposes or flows change; it does not replace a professional assessment of the specific case.