Privacy Policy

Last updated: 30 October 2026

1. Data Controller

The Data Controller is:

Hoculus S.r.l.
Registered office: Via B. Telesio 12, 20145 Milan (MI), Italy
VAT No.: 10781740963
Email: info@hoculus.com
Website: https://www.hoculus.com

For any questions regarding the processing of personal data, you may contact the Data Controller using the email address above.

2. Personal Data We Process

Depending on how you interact with our website and services, we may process the following categories of personal data:

• Identification and contact data: name, surname, business email address, telephone number, company name, job title and other professional details.

• Communication data: information contained in messages, contact requests, emails and other communications exchanged with Hoculus.

• Browsing and technical data: IP address, device and browser information, operating system, access logs, pages visited, browsing activity and other technical information collected through the website.

• Marketing and communication data: preferences, subscription status, interactions with marketing communications, including email delivery, opening and click events, where applicable.

• Customer and contractual data: information required to manage commercial relationships, service provision, contractual obligations, invoicing and related administrative activities.

Personal data may be collected directly from you, through forms on our website, through communications with Hoculus, or from publicly available professional sources and other business-related sources, where permitted by applicable law.

3. Purposes of Processing

Personal data may be processed for the following purposes:

A. Responding to requests and managing business communications

To respond to contact requests, provide information about our services, arrange meetings and manage communications with prospective clients, partners and other business contacts.

Legal basis: performance of pre-contractual measures requested by the data subject and/or the legitimate interest of the Data Controller in managing business relationships.

B. Providing services and managing contractual relationships

To establish, perform and manage contractual relationships, provide consultancy and technical services, manage projects, handle administrative activities and fulfil legal obligations.

Legal basis: performance of a contract, compliance with legal obligations and, where applicable, the legitimate interests of the Data Controller.

C. Sending marketing communications

To send commercial communications, updates, invitations to events, newsletters and information about Hoculus services, initiatives and activities, including through email.

Legal basis: the data subject's consent, where required by applicable law, or another applicable legal basis where expressly permitted.

D. Managing and measuring email communications

Where the recipient has provided the required consent, Hoculus may use tracking technologies in marketing emails, including tracking pixels, to collect information about whether an email has been opened and to measure interactions with the communication.

These technologies may be used to understand the effectiveness of marketing campaigns and improve the relevance of future communications.

Legal basis: the data subject's consent, where required under applicable data protection and electronic communications legislation.

E. Website analytics and improvement

To analyse website usage, improve website performance, understand visitor behaviour and optimise the user experience.

Legal basis: consent, where required for the use of cookies or similar technologies, or the legitimate interest of the Data Controller where applicable.

F. Security and fraud prevention

To protect the website, systems, services and information, prevent unauthorised access, detect security incidents and ensure the proper functioning of our infrastructure.

Legal basis: the legitimate interest of the Data Controller and, where applicable, compliance with legal obligations.

4. Third-Party Tools and Services

Hoculus may use third-party platforms and services to manage its website, communications, marketing activities and business operations.

Depending on the services actually used, these may include:

• Shopify: website and e-commerce infrastructure.

• Klaviyo: management of contact databases, marketing communications, newsletters and related email interactions.

• Google Analytics 4: website traffic analysis and statistical reporting.

• Microsoft Clarity: analysis of website interactions and user experience.

• Shopify Email: email marketing and communication services, where used.

• OpenAI: tools supporting certain business and operational activities, where personal data is processed.

• Google Maps: display of maps and location-related content, where integrated into the website.

These providers may process personal data on behalf of Hoculus as data processors or, depending on the specific service and processing activity, act as independent data controllers.

Further information about the processing carried out by these providers is available in their respective privacy policies.

5. Cookies and Similar Technologies

The website may use cookies and similar technologies to ensure its proper functioning, analyse traffic, improve the browsing experience and provide integrated third-party services.

Cookies and similar technologies may include:

• Strictly necessary cookies: required for the operation, security and accessibility of the website.

• Analytics cookies: used to collect statistical information about website usage.

• Marketing and profiling cookies: used to measure marketing activities or provide content and advertising that may be relevant to visitors.

• Third-party cookies: installed by external services integrated into the website.

Where required by applicable law, non-essential cookies and similar technologies are used only after the user's consent.

Further details about the cookies used, their purposes and how to manage preferences are provided through the website's cookie management interface.

6. Cookie Consent Management

When visiting the website for the first time, users may be presented with a cookie banner allowing them to accept, reject or customise the use of non-essential cookies.

Users may change or withdraw their consent at any time through the cookie management interface available on the website.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

7. Marketing, Email Tracking and Profiling

Hoculus may use Klaviyo to manage business contacts and send marketing communications to prospective and existing business contacts.

Contact data may originate from different sources, including:

• Forms submitted through the Hoculus website and other connected platforms.

• Direct communications with Hoculus.

• Contacts manually entered or imported from other business systems.

• Publicly available professional sources, where permitted by applicable law.

Marketing communications are sent in accordance with applicable data protection and electronic communications legislation.

Where required, Hoculus collects consent before sending promotional communications. The fact that an email address is publicly available or belongs to a business professional does not, by itself, constitute consent to receive marketing communications.

Email tracking technologies

Marketing emails may include tracking pixels and similar technologies that allow Hoculus to determine whether a message has been opened and to collect information about interactions with the communication.

These technologies are used only where the required legal conditions have been met, including obtaining consent where required by applicable law.

Recipients may withdraw their consent to email tracking separately from their consent to receive marketing communications. Where technically available, Hoculus will provide a preference management mechanism allowing recipients to continue receiving emails without being subject to individual email-opening tracking.

Recipients may also unsubscribe from marketing communications at any time by using the unsubscribe link included in the emails or by contacting Hoculus.

Withdrawing consent to email tracking does not necessarily require unsubscribing from all marketing communications.

8. Recipients of Personal Data

Personal data may be disclosed to or accessed by the following categories of recipients, where necessary for the purposes described in this Privacy Policy:

• Employees and authorised personnel of Hoculus.

• External consultants and professional advisers.

• IT, hosting, website and infrastructure providers.

• Marketing automation and email communication providers, including Klaviyo.

• Analytics and website optimisation providers.

• Payment, accounting and administrative service providers, where applicable.

• Public authorities and other entities where disclosure is required by law.

Such recipients may act as data processors, independent data controllers or authorised persons, depending on the nature of their role and the applicable legal framework.

Personal data is not made available to third parties for their own independent marketing purposes without an appropriate legal basis.

9. Transfers of Personal Data Outside the European Economic Area

Some third-party providers used by Hoculus may process personal data outside the European Economic Area (EEA).

Where personal data is transferred to countries that do not benefit from an adequacy decision adopted by the European Commission, Hoculus will ensure that appropriate safeguards are implemented, such as Standard Contractual Clauses approved by the European Commission, together with any additional measures required by applicable law.

Further information about international data transfers and the safeguards adopted may be requested by contacting Hoculus.

10. Data Retention

Personal data is retained only for the period necessary to fulfil the purposes for which it was collected, subject to applicable legal obligations and limitation periods.

In particular:

• Data relating to contact requests and business communications is retained for the time necessary to manage the request and any subsequent business relationship.

• Customer and contractual data is retained for the duration of the contractual relationship and for the additional period required by applicable legal and tax obligations.

• Marketing contact data is retained until consent is withdrawn or the data is no longer necessary for the relevant purpose, subject to applicable legal requirements.

• Email tracking data is retained only for the period necessary to measure and manage the relevant marketing activities.

• Technical and browsing data is retained for the period necessary to ensure website security, functionality and performance.

Once the applicable retention period has expired, personal data will be deleted or anonymised, unless further retention is required by law or necessary to establish, exercise or defend legal claims.

11. Data Subject Rights

Under the GDPR and applicable data protection legislation, data subjects have the right to:

• Obtain confirmation as to whether their personal data is being processed.

• Access their personal data and obtain a copy.

• Request the rectification of inaccurate or incomplete data.

• Request the erasure of personal data, where the relevant legal conditions are met.

• Request the restriction of processing.

• Object to processing based on legitimate interests.

• Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

• Request data portability, where applicable.

• Lodge a complaint with the competent supervisory authority.

In Italy, the competent supervisory authority is the Italian Data Protection Authority (Garante per la protezione dei dati personali).

To exercise these rights, data subjects may contact Hoculus at info@hoculus.com.

12. Data Security

Hoculus adopts appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Such measures are designed to ensure a level of security appropriate to the risks associated with the processing activities.

13. Minors

The website and services offered by Hoculus are intended for businesses, professionals and adults.

Hoculus does not knowingly collect personal data relating to minors through its website for marketing purposes.

If Hoculus becomes aware that personal data relating to a minor has been collected unlawfully, appropriate measures will be taken to delete such data.

14. Changes to This Privacy Policy

Hoculus reserves the right to amend or update this Privacy Policy at any time, including to reflect changes in applicable legislation, the services offered or the processing activities carried out.

The updated version will be published on this page, together with the relevant revision date.

Users are encouraged to review this page periodically.

15. Contact

For any questions, requests or information concerning this Privacy Policy or the processing of personal data, please contact:

Hoculus S.r.l.
Via B. Telesio 12
20145 Milan (MI), Italy
VAT No.: 10781740963
Email: info@hoculus.com
Website: https://www.hoculus.com