Privacy Policy

1. Data Controllers

This Privacy Policy applies to XTAL Strategies Srl (VAT nr. 08766171006, REA MI-1905810, Milan, Italy) and XTAL Markets Limited (registered in England and Wales, nr. 11742387), collectively referred to as "XTAL", "we", or "us". For questions regarding this policy, contact us at info@xtalstrategies.com.

2. Data We Collect

When you interact with this website or contact us, we may collect:

• Contact information you provide (name, email address, organisation, phone number)
• Enquiry content submitted through our contact form or by email
• Technical data collected automatically (IP address, browser type, pages visited, time of visit)
• Cookie data as described in Section 6 below

3. How We Use Your Data

We use your personal data only for the following purposes:

• Responding to enquiries and providing information about our services
• Managing our business relationship with you or your organisation
• Complying with applicable legal and regulatory obligations
• Improving the performance and content of this website

We do not sell, rent, or trade your personal data to third parties. We do not use your data for automated decision-making or profiling.

4. Legal Basis for Processing

Under the EU General Data Protection Regulation (GDPR) and UK GDPR, our legal bases for processing personal data are:

• Legitimate interests — responding to enquiries, managing business relationships, and improving our website
• Legal obligation — where processing is required to comply with applicable law or regulation
• Consent — where you have explicitly provided consent (e.g. subscribing to communications)

5. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. Contact and enquiry data is typically retained for up to 3 years from last interaction unless a longer period is required by law or regulation.

6. Cookies

This website uses cookies managed through Cookiebot, our consent management platform. Cookies are categorised as follows:

• Necessary cookies — essential for the website to function. These cannot be refused.
• Statistics cookies — we use Google Analytics 4 to understand how visitors use the site (pages visited, time on site, geography). These are only placed after you give consent.

On your first visit you will be shown a cookie consent banner. You may accept or decline non-essential cookies at any time. Your preference is stored and can be changed by clearing your browser cookies or clicking the cookie settings link in the footer.

For a full list of cookies in use on this site, see the Cookiebot cookie declaration below.

7. Your Rights

Under GDPR and UK GDPR, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request erasure of your data ("right to be forgotten")
• Object to or restrict processing of your data
• Request portability of your data in a structured format
• Withdraw consent where processing is based on consent

To exercise any of these rights, contact us at info@xtalstrategies.com. We will respond within 30 days. You also have the right to lodge a complaint with your local supervisory authority (in Italy: Garante per la Protezione dei Dati Personali; in the UK: Information Commissioner's Office).

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. Our website is served over HTTPS. Access to personal data within our organisation is restricted to those who need it to fulfil their responsibilities.

9. International Transfers

XTAL operates from Italy and the United Kingdom. If personal data is transferred outside the EEA or UK, we ensure appropriate safeguards are in place in accordance with GDPR requirements, including standard contractual clauses where applicable.

10. Third-Party Links

This website contains links to external platforms (POINTERS, SESTANTE, PRIFFE, LinkedIn, Substack). We are not responsible for the privacy practices of those platforms. We encourage you to review their respective privacy policies.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page indicates when it was last revised. Continued use of this website after changes constitutes acceptance of the updated policy.

12. Contact

For any privacy-related questions or to exercise your rights, contact us at info@xtalstrategies.com or by post at our registered offices in Milan or London.