Last updated: 23 October 2026
The data controller of your personal data is 369DCH S.r.l. (single-member company), registered office: Viale dell'Industria 303, 62014 Corridonia (MC), Italy. VAT no. IT 02185950439, REA MC-317301. Certified email (PEC): 369dchsrl@legalmail.it. Contact for anything in this policy: david.clementoni@gmail.com · Tel. +39 327 778 7053.
This policy covers the website davidclementoni.com and the services offered through it. It is written under the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Italian law (D.Lgs. 196/2003 as amended).
| Activity | Data | Purpose | Legal basis (GDPR art. 6) |
|---|---|---|---|
| Visiting the site | IP address, browser/device data, requested pages (server logs) | Serving the site, security, abuse prevention | Legitimate interest (6(1)(f)) |
| Forms on this site | Name, email, information you provide | Answering you, sending the resource you requested, evaluating fit for the program | Contract / pre-contractual steps (6(1)(b)) |
| Gift Reading | Date, time and place of birth, name, email | Producing and sending the personalized gift reading you requested (see section 3) | Contract: delivery of the reading you asked for (art. 6(1)(b)). Follow-up marketing emails only with your separate, optional consent (art. 6(1)(a)), given by an unticked checkbox on the form. |
| Newsletter & email sequences | Email, name, which resources you took, opens/clicks | Sending the newsletter and relevant follow-up emails | Consent (6(1)(a)); for existing customers, soft opt-in with an unsubscribe link in every email |
| Booking a call | Name, email, chosen time, anything you write in the booking | Scheduling and holding the meeting (Google Calendar / Meet) | Contract / pre-contractual steps (6(1)(b)) |
| Purchases | Name, email, billing data; card data is handled by the payment provider, never by us | Processing payment, invoicing, accounting | Contract (6(1)(b)); legal obligation (6(1)(c)) |
| WhatsApp communication with clients | Phone number, messages | Client communication during a program; always optional, email is available | Contract (6(1)(b)) |
| Video testimonials | Your image, voice, name, story | Publishing your testimonial on the site and in marketing | Consent (6(1)(a)), withdrawable at any time with effect for the future |
We do not buy data about you, and we never sell your data.
To create your gift reading we ask for your date, time and place of birth. From these we derive a personality-style profile using the Human Design framework, together with numerology, astrology and Kabbalah-derived frameworks (reflective, educational tools, not sciences, see our Terms). Your readings and maps may draw on any combination of these.
The gift reading never asks for, and never infers, special-category data. But coaching is personal: if you join the Activation Kit (which includes a live session and the Experience Blueprint) or the Talent Accelerator™, you may choose to share information about your health or psychological wellbeing, your beliefs or spiritual life, or other deeply personal matters, in the Blueprint questionnaire, in sessions, or on WhatsApp. This is special-category data under art. 9 GDPR, and we process it only with your explicit consent (art. 9(2)(a)), which we ask for when you start the program, and only to deliver your coaching. You can withdraw this consent at any time with effect for the future (section 8); session work then continues without that data. We never use it for marketing, never share it beyond the processors in section 4, and delete it at the end of the retention periods in section 5.
| Provider | Role | Location / transfer safeguard |
|---|---|---|
| Cloudflare, Inc. | Hosting, DNS, CDN, security | US; EU–US Data Privacy Framework and/or Standard Contractual Clauses |
| Google LLC (Forms, Sheets, Calendar, Meet, Gmail) | Form intake, lead storage, scheduling, meetings | US; EU–US DPF and/or SCCs |
| Systeme.io (Systeme SAS) | Email marketing & automation | France (EU) |
| Stripe | Payments | Ireland entity; US transfers under DPF and/or SCCs |
| WhatsApp Ireland Ltd (Meta) | Client messaging, only where you choose it | Ireland; Meta transfer mechanisms (SCCs/DPF) |
| Accountant / tax advisor | Legal compliance | Italy |
Where a provider transfers data outside the EEA (mainly to the USA), the transfer rests on the EU–US Data Privacy Framework and/or the EU Standard Contractual Clauses (art. 46 GDPR), plus the provider's supplementary measures.
This site is substantially static. We set no analytics or advertising cookies. Cloudflare may set strictly necessary technical cookies (such as bot protection) to keep the site secure; these are exempt from consent. Videos on this site are self-hosted files, not third-party embeds. If this ever changes, this section and the site's consent handling will be updated first.
Access is limited to David Clementoni; accounts with our providers are protected with strong authentication; data stays in the providers' secured infrastructure; no copies of birth data are kept beyond what producing the reading requires.
Under GDPR arts. 15–22 you may at any time: access your data; correct it; have it deleted; restrict or object to processing (including direct marketing: one click in any email); receive your data in a portable format; and withdraw any consent with effect for the future (for example gift-reading consent or a testimonial release).
Write to david.clementoni@gmail.com. We answer within one month. You may also complain to the Italian supervisory authority, the Garante per la Protezione dei Dati Personali (garanteprivacy.it), or the authority of your country of residence.
We do not knowingly collect data from children under 14; the services are addressed to adults.
We may update this policy; material changes are flagged on the site and, for active subscribers, by email. The date at the top tells you the current version.