1. Data Controller

Natural Numbers is operated by Antonio Davoli, an individual operating under Italian fiscal identification (partita IVA: 14559390969), with registered address at Spaces Piazza Vetra 17, Milano, Italy ("Natural Numbers", "we", "us" or "our"). Antonio Davoli acts as the data controller for all personal data collected through this website.

For any questions regarding how we handle your personal data, please contact us at privacy@naturalnumbers.studio.

2. Scope

This Privacy Policy applies to visitors of naturalnumbers.studio and any individuals who contact us through this website or by email. It explains how we collect, use, share, and protect your personal data, and what rights you have in relation to it.

We process personal data in accordance with Regulation (EU) 2016/679 (GDPR) and, where applicable, Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018 (the "Italian Privacy Code").

This Policy does not cover personal data processed in the context of professional consulting engagements. Such processing is governed by the applicable engagement agreement and any data processing agreement entered into between Natural Numbers and the client.

3. Personal data we collect

Browsing data

When you visit our website, we automatically collect certain technical information including your IP address, browser type and version, device identifiers, pages visited, referral URLs, and timestamps. This website does not use cookies or tracking technologies.

Contact and enquiry data

When you submit your email address through our website or contact us directly by email, we collect:

• Your email address
• Your name (if provided)
• Your organisation name (if provided)
• The content of your message or enquiry
• Any additional information you voluntarily share

Communication data

If we enter into a professional relationship, we may retain records of communications including emails, notes from calls, and meeting summaries, as necessary to manage that relationship and comply with our legal and professional obligations.

4. How we use your data

• Responding to enquiries: to contact you regarding your discovery call request or any other message you send us.
• Service delivery: to manage any consulting or advisory engagement you enter into with us.
• Website improvement: to understand how our website is used and improve its content and functionality.
• Security: to detect and prevent fraudulent or abusive activity.
• Legal compliance: to comply with applicable laws, regulations, and legal obligations.
• Marketing communications: with your explicit consent, to send newsletters or updates about our work. You may withdraw consent at any time without affecting the lawfulness of prior processing.

We do not use your data for automated decision-making or profiling in ways that produce significant legal or similarly significant effects.

5. Legal basis for processing

• Consent (Art. 6(1)(a) GDPR): for marketing communications and optional data collection activities where we have obtained your prior explicit consent.
• Contract performance (Art. 6(1)(b) GDPR): where processing is necessary to respond to your enquiry or to take pre-contractual steps at your request.
• Legitimate interests (Art. 6(1)(f) GDPR): for website analytics, security monitoring, and service improvement. You have the right to object to processing on this basis at any time.
• Legal obligation (Art. 6(1)(c) GDPR): where we are required by law to process your data.

6. Data sharing

We do not sell your personal data. We may share your data only in the following limited circumstances:

Service providers

We work with a limited number of trusted third-party service providers who assist us in operating our website and managing communications. These providers act as data processors on our behalf and are bound by data processing agreements compliant with Article 28 GDPR. Current providers include:

• GitHub Pages (GitHub Inc., USA) — website hosting. Data transfers outside the EEA are governed by Standard Contractual Clauses.
• Namecheap Inc., USA — domain name registration. Data transfers outside the EEA are governed by Standard Contractual Clauses.
• Gmail and Google Calendar (Google LLC, USA) — email communications and discovery call scheduling. Data transfers outside the EEA are governed by Standard Contractual Clauses.

Legal requirements

We may disclose your data where required by law, court order, or instruction from a competent supervisory or regulatory authority, or where necessary to protect the rights, property, or safety of Natural Numbers or third parties.

Business transfers

In the event of a merger, acquisition, or transfer of all or part of our business, your personal data may be transferred as part of that transaction. We will provide you with prior notice and information about your rights in such circumstances.

7. International transfers

Some of our service providers may process personal data outside the European Economic Area (EEA). Where such transfers occur, we ensure that an appropriate safeguard is in place, which may include an adequacy decision by the European Commission, Standard Contractual Clauses (SCCs) approved under Article 46(2)(c) GDPR, or another lawful transfer mechanism under Chapter V GDPR.

8. Data retention

• Enquiry data: up to 24 months from initial contact, unless a professional engagement commences.
• Engagement records: for the duration of the engagement and for 10 years thereafter, in accordance with Article 2946 of the Italian Civil Code.
• Website analytics: up to 13 months from collection, in line with the Garante's Cookie Guidelines of 10 June 2021.
• Marketing consent data: until you withdraw consent, or up to 24 months after your last interaction with us, whichever is earlier.

When personal data is no longer required, we securely delete or irreversibly anonymise it.

9. Your rights

• Access (Article 15 GDPR): to obtain confirmation of whether we hold personal data about you and to receive a copy.
• Rectification (Article 16 GDPR): to request correction of inaccurate or incomplete data.
• Erasure (Article 17 GDPR): to request deletion of your data where there is no legitimate ground for us to continue processing it.
• Restriction (Article 18 GDPR): to request that we limit processing in certain circumstances.
• Portability (Article 20 GDPR): to receive your data in a structured, machine-readable format where processing is based on consent or contract.
• Objection (Article 21 GDPR): to object to processing based on our legitimate interests, including for direct marketing.
• Withdrawal of consent (Article 7(3) GDPR): to withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@naturalnumbers.studio. We will respond within one month of receiving your request. Where requests are complex or numerous, we may extend this period by a further two months and will notify you accordingly.

If you are not satisfied with our response, you may lodge a complaint with the Garante per la protezione dei dati personali (www.garanteprivacy.it).

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction, consistent with Article 32 GDPR. These include access controls, encryption in transit, and careful selection of service providers.

If you believe your personal data has been compromised, please contact us immediately at privacy@naturalnumbers.studio.

11. Special categories of data

We do not intentionally collect special categories of personal data within the meaning of Article 9 GDPR, such as data revealing racial or ethnic origin, political opinions, religious beliefs, health information, biometric data, or data concerning sexual orientation. Please do not submit such information through our website or in any communication with us.

12. Updates to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top of this page. Where required by law, we will provide more prominent notice of material changes.

13. Contact us

Natural Numbers
Email: privacy@naturalnumbers.studio
Website: naturalnumbers.studio

We aim to respond to all privacy-related enquiries within one month.

1. Acceptance of terms

By accessing and using naturalnumbers.studio (the "Website"), you agree to be bound by these Terms of Use. If you do not agree to these terms, please do not use the Website.

These Terms of Use apply to all visitors and users of the Website. They govern your access to and use of the Website, including any contact forms or discovery call requests submitted through it. Any professional services engaged through this Website are governed exclusively by a separate written engagement agreement.

We reserve the right to modify these terms at any time. Material changes will be notified by updating the "Last updated" date and, where practicable, by a notice on the Website. Your continued use of the Website after the effective date of any changes constitutes acceptance of the revised Terms.

2. Description of services

Natural Numbers is operated by Antonio Davoli, an individual operating under Italian fiscal identification (partita IVA: 14559390969), based in Italy ("Natural Numbers", "we", "us" or "our").

Natural Numbers provides AI consulting, implementation, and advisory services to organisations. The Website serves as an informational and lead generation platform. The Website does not itself provide AI services, software, or tools. Any consulting, implementation, or other professional services are subject to separate engagement agreements. No obligation to provide services arises from use of this Website alone.

3. Permitted use

You may use the Website for lawful purposes only. Permitted uses include:

• Browsing and reading the content presented on the Website
• Submitting your contact information to request a discovery call or enquire about our services
• Sharing links to pages on the Website

You represent that you are at least 18 years of age and, where acting on behalf of an organisation, that you have the authority to bind that organisation to these Terms.

4. Prohibited conduct

You agree not to:

• Use the Website for any unlawful purpose or in violation of applicable laws or regulations
• Submit false, misleading, or fraudulent information through any contact form
• Attempt to gain unauthorised access to any part of the Website or its underlying systems
• Introduce any virus, malware, or other harmful or disruptive code to the Website
• Scrape, crawl, or systematically extract data from the Website without prior written permission
• Reproduce, republish, or redistribute any content from the Website without prior written permission
• Impersonate any person or entity, or misrepresent your affiliation with any person or entity
• Engage in any conduct that could damage, disable, or impair the Website or interfere with others' use of it

5. Intellectual property

All content on the Website, including text, graphics, code examples, visual design, logos, and any other materials, is the property of Natural Numbers or its licensors and is protected by applicable intellectual property laws, including Italian Law 633/1941 on copyright and Regulation (EU) 2017/1001 on EU trade marks.

The code snippets and technical examples presented in our case studies are provided for illustrative purposes only. They are simplified representations of actual systems and do not constitute complete, deployable code. No license, express or implied, is granted to reproduce, adapt, or exploit any content on this Website, except as strictly necessary for the permitted use set out in Section 3 above.

The Natural Numbers name, wordmark, and visual identity are proprietary. You may not use them without prior written permission. Nothing in these Terms grants you any right to use our intellectual property except as expressly set out herein.

6. Confidentiality

Any information you share with us through the Website, including details about your organisation, projects, or technical challenges, will be treated with reasonable discretion. We will not disclose such information to third parties except as necessary to operate our services or as required by law.

This clause does not constitute a non-disclosure agreement. Formal confidentiality obligations are set out in the applicable engagement agreement or non-disclosure agreement, if and when entered into.

7. Disclaimer of warranties

The Website and its content are provided on an "as is" and "as available" basis. To the fullest extent permitted by applicable law, Natural Numbers makes no representations or warranties of any kind, express or implied, as to the accuracy, completeness, reliability, currency, or fitness for a particular purpose of any information on the Website.

The results and metrics described in our case studies reflect specific client engagements under particular conditions. They are not guarantees of future results. We do not warrant that the Website will be uninterrupted, error-free, or free of harmful components.

8. Limitation of liability

To the fullest extent permitted by applicable law, and except in cases of wilful misconduct or gross negligence, Natural Numbers shall not be liable for any indirect, incidental, consequential, or special damages arising out of or in connection with your use of, or inability to access, the Website, including loss of profits, loss of data, business interruption, or reputational harm.

Given that the Website is provided without charge and no contractual services are performed through it, Natural Numbers' aggregate liability for any claim arising solely from your use of the Website shall not exceed EUR 500, except in cases of wilful misconduct or gross negligence.

9. Indemnification

You agree to indemnify Natural Numbers against any third-party claims, losses, and reasonable legal costs arising directly from: (a) your use of the Website in material breach of these Terms; or (b) information you submit through the Website that is demonstrably false, fraudulent, or infringes a third party's rights.

10. Third-party links

The Website may contain links to third-party websites or resources. These links are provided for convenience only. Natural Numbers has no control over the content, privacy practices, or availability of third-party sites and accepts no responsibility for them. Linking to a third-party site does not constitute an endorsement.

11. Data protection

The collection and use of personal data through this Website is governed by our Privacy Policy, available at naturalnumbers.studio. By using the Website and submitting any contact form, you acknowledge that you have read and understood our Privacy Policy.

12. Governing law and disputes

These Terms are governed by Italian law. Any dispute arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of Milan.

If you are an individual consumer resident in the EU, nothing in these Terms affects your right to bring proceedings in the courts of your country of habitual residence.

13. Changes to these terms

We may update these Terms of Use at any time. Material changes will be communicated by updating the "Last updated" date on this page and, where practicable, by a notice on the Website. Your continued use of the Website after the effective date of any changes constitutes acceptance of the revised Terms.

14. General

14.1 Severability

If any provision of these Terms is found to be invalid, unlawful, or unenforceable, that provision shall be modified to the minimum extent necessary to make it enforceable, or severed if modification is not possible, and the remaining provisions shall continue in full force and effect.

14.2 Entire Agreement

These Terms constitute the entire agreement between you and Natural Numbers in relation to your use of the Website. They do not govern any professional services engagement, which is subject to a separate written agreement.

14.3 Waiver

No failure or delay by Natural Numbers in exercising any right under these Terms shall operate as a waiver of that right.

14.4 No Assignment

You may not assign or transfer any rights or obligations under these Terms without our prior written consent.

15. Contact

Natural Numbers
Email: hello@naturalnumbers.studio
Website: naturalnumbers.studio