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Privacy & Cookie Policy

Last updated: 8 October 2026

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This Privacy & Cookie Policy explains how Elli Real Estate collects, uses, stores and protects personal data from visitors to www.ellirealestate.com, in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Italian data protection legislation.

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1. Data Controller

The data controller responsible for processing personal information is:

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LOTO S.r.l.

Elli Real Estate is the brand through which real estate opportunities, investment services and property development activities are presented.

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2. Categories of Personal Data Collected

Personal information is primarily collected through the contact forms available in different sections of the website, managed using Wix Forms.

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Depending on the nature of the enquiry, the following categories of information may be collected:

 

Identification and Contact Information

  • First and last name

  • Email address

  • Telephone number, where requested or voluntarily provided

 

Real Estate and Investment Preferences

  • Geographical markets of interest

  • Investment type and objectives

  • Indicative investment budget

  • Expected investment or purchase timeline

  • Preferences regarding properties and investment opportunities

 

Professional and Business Information

  • Company or professional firm

  • Professional activity or operator category

  • Geographical area of operation

  • Types of real estate products handled

  • Client profile

  • Indicative volume of real estate transactions

  • Assets under management (AUM) range, where applicable

  • Frequency of real estate transactions

  • How the visitor discovered Elli Real Estate

 

Other Information

  • Messages and enquiries voluntarily submitted

  • Information concerning partnership or professional collaboration requests

  • Records of privacy notice acknowledgement and acceptance of confidentiality conditions, where applicable

 

Technical information, such as IP addresses, device information and browser details, may also be processed when visitors access the website for operational and security purposes.

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3. Purposes and Legal Bases for Processing

Personal information is processed for the following purposes:

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Managing Real Estate Enquiries

 

Responding to requests for information concerning properties, projects, investments and real estate

opportunities presented on the website.

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Managing Professional Contacts

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Reviewing and managing enquiries from real estate operators, financial advisers, brokers, institutional investors and potential business partners.

 

Communications Related to Enquiries

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Providing relevant information, documentation and clarification, and maintaining communications necessary to address submitted enquiries.

 

Website Operation and Security

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Ensuring proper operation of online services and protecting the website's technical infrastructure.

Depending on the nature of the enquiry, processing of personal data submitted through contact forms is based on taking steps at the request of the data subject prior to entering into a contract, pursuant to Article 6(1)(b) GDPR, or on the controller's legitimate interests in managing professional enquiries and relationships, pursuant to Article 6(1)(f) GDPR.

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Technical information necessary for website security may be processed on the basis of the controller's legitimate interests.

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Personal data is not used for newsletters, advertising profiling, email marketing campaigns or unsolicited promotional communications.

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4. Provision of Personal Information

Providing personal information through the website's contact forms is voluntary.

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Fields marked as mandatory are necessary to process the relevant enquiry. Failure to provide this information may prevent the controller from responding to or evaluating the request.

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Optional information may be provided at the visitor's discretion.

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This Privacy & Cookie Policy is accessible through the relevant links available on the website and its contact forms.

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5. Data Processing and Security

Personal information is processed using electronic systems in accordance with the principles of lawfulness, fairness, transparency, data minimisation and confidentiality.

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The data controller implements appropriate technical and organisational measures designed to prevent unauthorised access, loss, disclosure or misuse of personal information.

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Access to personal data is limited to authorised individuals and service providers who require it for relevant business activities.

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6. Data Retention

Personal information collected through contact forms is retained for a maximum of 24 months from the last relevant interaction with the visitor, unless a longer retention period is necessary to comply with legal obligations, manage contractual relationships or establish, exercise or defend legal claims.

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At the end of the applicable retention period, personal information is deleted or anonymised unless a further lawful basis justifies continued retention.

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7. Data Recipients and Sharing

Personal information may be processed by authorised LOTO S.r.l. personnel and collaborators, as well as technology providers necessary for website operation and communication management.

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The website uses Wix for hosting, contact form management and related technical services.

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Personal information may also be disclosed to parties involved in handling real estate or professional enquiries, to the extent necessary to respond to the visitor's request and in accordance with applicable data protection requirements.

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Personal data is not sold to third parties or disclosed for advertising purposes.

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8. International Data Transfers

The use of international technology providers may involve processing personal data outside the European Economic Area.

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Any international transfers are carried out in accordance with Articles 44 and following of the GDPR, relying on adequacy decisions or appropriate safeguards where required.

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Further information about applicable safeguards may be requested from the data controller.

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9. Data Subject Rights

Visitors may exercise their rights under Articles 15–22 GDPR, where applicable, including:

  • Right of access to personal data

  • Right to rectification of inaccurate information

  • Right to erasure

  • Right to restriction of processing

  • Right to object to processing

  • Right to data portability, where applicable

  • Right to withdraw consent where processing is based on consent

Requests may be submitted to:

elli.m@ellirealestate.com

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Visitors also have the right to lodge a complaint with the Italian Data Protection Authority, available at www.garanteprivacy.it.

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10. Cookie Policy

The Elli Real Estate website is built using the Wix platform and uses technical cookies necessary for website functionality, security and performance.


Technical Cookies Identified
bSession: Technical session management and monitoring

hs: Platform security

server-session-bind: Server-side session management

ssr-caching: Cache and performance optimisation

svSession: Session management and website functionality

XSRF-TOKEN: Protection against fraudulent requests

 

These cookies support essential website functions and are not intended for advertising profiling.

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Analytics and Marketing Cookies

Elli Real Estate has not enabled additional statistical analytics, visitor profiling or advertising tracking tools.

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Based on the current configuration and checks performed, no marketing or profiling cookies have been identified.

 

Cookie Consent

Cookies strictly necessary for website operation do not require visitors' prior consent.

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If non-essential cookies or additional tracking technologies are introduced, this policy will be updated and appropriate consent mechanisms will be implemented where required by law.

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Managing Cookies

Visitors can manage, restrict or delete cookies through their browser settings.

Disabling certain essential cookies may affect website functionality.

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Further information about cookies used by Wix is available at:

https://support.wix.com/en/article/cookies-and-your-wix-site

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11. Updates to This Policy

LOTO S.r.l. reserves the right to update this Privacy & Cookie Policy to reflect changes in personal data processing practices, website functionality or applicable legislation.

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Updated versions will be published on this page, indicating the date of the latest revision.

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