Privacy notice

1. Data controller

The controller for data collected through this site and the Client journey form is Seconda Torre S.r.l., Strada degli Angariari 25, 47891 Falciano, Republic of San Marino, COE 26018. Contact: iam@centerlife.coach.

The CENTERLIFE Association is a separate, non-profit legal entity. Initiatives managed by it will identify their controller and applicable notice separately.

2. Data processed

We may process browsing data and information voluntarily provided in forms: name, email, telephone number, city and province, optional age range, stated goals, contact preferences, referral source and any referring Coach.

When you request the Centerlife Map PDF, we also process your email address, the twelve Map scores, calculated summaries, email-verification date and evidence of consent.

The initial form does not request information about illnesses, medication, diagnoses or other health data. Please do not enter such information in free-text fields.

3. Purposes and legal bases

• manage requests and arrange the first conversation: pre-contractual steps requested by the data subject;
• answer questions and provide support: fulfilment of the request and legitimate interest in contact management;
• verify email, create, download and send the personal Map PDF: performance of the requested service;
• comply with legal duties or authority requests: legal obligation;
• send informational or promotional messages: optional, separate consent, withdrawable at any time.

Required data is necessary to manage the request. Marketing consent is not required for contact about the submitted request.

4. Processing, recipients and providers

Authorised personnel and collaborators process data digitally according to necessity, fairness and minimisation. Technical providers may process data to operate the site, email and online forms, including Jotform, site hosting and database infrastructure, and transactional email providers.

Data is not sold. No solely automated decisions producing legal or similarly significant effects are envisaged.

5. International transfers

Some technical providers may process data outside San Marino or the European Economic Area. Processing must then rely on safeguards required by applicable law, including adequacy decisions or appropriate contractual clauses.

6. Retention

Contact requests are kept as long as needed and generally no longer than 24 months from the last useful contact, unless law, protection of rights or a contractual relationship requires otherwise. Promotional data is kept until consent is withdrawn or the purpose ends.

Unused verification codes expire after 10 minutes. Maps linked to verified emails are generally retained no longer than 24 months from the last useful contact, unless deletion is requested or other duties apply.

7. Your rights

Where applicable, you may request access, correction, deletion, restriction, portability and objection, and withdraw consent without affecting earlier lawful processing. Contact iam@centerlife.coach.

You may also complain to the Data Protection Authority of the Republic of San Marino.

8. Law and updates

This notice takes account of San Marino Law no. 171 of 21 December 2018 and, where applicable, EU Regulation 2016/679. It may be updated following service or legal changes; the current version will be published here.