Privacy Policy

1. Who we are and how to contact us

The controller of your personal data is Wise Strategies LLC, a limited liability company incorporated in the State of Florida, United States, trading under the brand SDM Consulting.

• Registered office: 18395 Gulf Blvd Ste 203 4, Indian Shores, FL 33785, United States
• EIN: 37-2117329
• Registered member: Davide Massimo Schipilliti, Sole Member
• Email: [email protected]
• Phone: +39 379 393 6512

We are not required to appoint a Data Protection Officer. For any question about this policy or about your data, write to the email address above and mark your message "Privacy".

[If an EU representative under Article 27 GDPR has been appointed, add name, address and contact details here.]

2. The personal data we collect

Data you give us

• Identity and contact data: first name, last name, email address, phone number, country, and, where relevant, company name, role, VAT or tax number.
• Booking data: the date and time of your call, your time zone, and the answers you give in our forms or in the intake questions before a call.
• Business data you share with us during the program: information about your business, such as products, suppliers, budgets, marketing results, sales figures, and documents or files you decide to send us.
• Payment data: billing details and the record of payments. Card details are collected and processed directly by our payment provider. We never receive or store complete card numbers.
• Communications: emails, messages, chats and notes taken during or after our calls.
• Session recordings, where a session is recorded. You are told before the recording starts and you can ask us not to record.

Data we collect automatically

• Technical data: IP address, browser type and version, device type, operating system and language.
• Usage data: pages visited, time spent on a page, links clicked and the page that referred you to us.
• Cookies and similar technologies, as described in section 5.

Data from third parties

• Advertising and analytics platforms, when you reach us through an advertisement or a campaign link.
• Publicly available business information, such as a company register or a public website, when we check the details of a business client.

We do not ask for and do not want special categories of data, such as health, political opinions or religious beliefs. Please do not share them with us.

3. Why we use your data, and our legal basis

We use personal data only where we have a legal basis to do so. In the list below, the letters refer to Article 6(1) of the GDPR.

• To reply to your request and arrange an introductory call. Basis: steps taken at your request before entering into a contract (b).
• To deliver the program you enrolled in, including sessions, support between sessions, materials and reviews. Basis: performance of a contract (b).
• To take payments, issue invoices and keep our accounts. Basis: performance of a contract (b) and legal obligation (c).
• To record a session, so that you and your mentor can go back to what was agreed. Basis: your consent (a), which you can withdraw at any time for future sessions.
• To send service messages, such as session reminders, changes of schedule or documents. Basis: performance of a contract (b).
• To send marketing emails or messages about our programs and content. Basis: your consent (a), or our legitimate interest in writing to existing clients about similar services (f).
• To improve our services and our website, and to keep them secure. Basis: our legitimate interest in running and protecting our business (f).
• To establish, exercise or defend legal claims, and to comply with the law. Basis: legal obligation (c) and legitimate interest (f).

Where we rely on a legitimate interest, we have checked that it does not override your rights. You can ask us for a copy of that assessment.

4. Marketing communications

We send marketing messages only to people who asked to receive them, or to our clients about services similar to the ones they already bought. Consent for marketing is always separate from consent for the contract, and it is never pre-ticked.

You can unsubscribe at any time using the link in any email, by replying to the message, or by writing to us. Withdrawing consent does not affect the lawfulness of what we did before, and it does not stop the service messages you need in order to follow your program.

5. Cookies and similar technologies

Our website uses cookies and similar technologies. Essential cookies make the site, the forms and the booking calendar work, and they cannot be switched off. Analytics and advertising cookies, where we use them, are set only after you accept them through the consent banner, and you can change your choice at any time.

You can also block or delete cookies in your browser settings. If you do, parts of the site may stop working.

[If analytics or advertising tools are active, list them here with their purpose and retention period, and keep the list aligned with the consent banner.]

6. Who we share your data with

We never sell personal data and we never share it for someone else's marketing. We share data only with:

• Service providers acting on our instructions under a written data processing agreement: our website, CRM, forms, calendar and email platform (HighLevel, Inc., United States); [messaging provider for WhatsApp]; [video-call provider]; [payment provider]; [course and community platform]; [any other tool you use].
• Our accountants, auditors and lawyers, bound by professional secrecy.
• The companies of our group, WiseFlow and WiseExit, only if you ask to be introduced to them or if you consent. They are separate companies and act as independent controllers of the data you give them.
• Public authorities, where the law requires it or to defend a legal claim.
• A buyer or successor, if our business is sold or reorganised. We would tell you before your data is transferred.

7. International transfers

We are established in the United States, and some of our providers are too. This means personal data of people in the European Economic Area or the United Kingdom is transferred outside those areas.

For these transfers we rely on the Standard Contractual Clauses adopted by the European Commission, and on the UK addendum where it applies. Where a provider is certified under the EU-U.S. Data Privacy Framework, or where the European Commission has adopted an adequacy decision for the country involved, we rely on that instead. We also apply additional measures, such as limiting access and encrypting data in transit.

You can ask us for a copy of the safeguards in place by writing to [email protected].

8. How long we keep your data

• Enquiries that do not become a contract: 24 months from the last contact.
• Client records, contracts and correspondence: for the duration of the contract and for as long as required afterwards by tax, accounting and limitation rules, generally up to 10 years.
• Invoices and accounting records: for the period required by the applicable tax law.
• Session recordings: [12 months], unless you ask us to delete them earlier.
• Marketing contacts: until you withdraw consent, and for 24 months after the last interaction.
• Website logs and cookie data: up to 12 months, or the shorter period set in the cookie banner.

When a retention period ends, we delete the data or make it anonymous.

9. Your rights

If you are in the European Economic Area or the United Kingdom, you have the right to:

• ask for a copy of the personal data we hold about you;
• have inaccurate data corrected;
• have your data deleted, where there is no other reason for us to keep it;
• ask us to restrict how we use your data, or object to a use based on legitimate interest;
• object at any time to direct marketing;
• receive the data you gave us in a portable format, or have it sent to another provider;
• withdraw a consent you gave, at any time;
• lodge a complaint with a supervisory authority. In Italy this is the Garante per la protezione dei dati personali; you can also contact the authority of the country where you live or work.

To exercise a right, write to [email protected]. We answer within one month. If the request is complex we may take up to two further months, and we will tell you why. We may ask you for proof of identity before we act, to make sure we are not sending your data to someone else.

10. United States privacy rights

If you live in California, or in another state with a similar law, you have the right to know what personal information we collect and why, to ask for a copy of it, to ask us to correct or delete it, and to opt out of the sale or sharing of personal information.

We do not sell personal information and we do not share it for cross-context behavioural advertising. We will never treat you differently because you exercised a privacy right. To make a request, write to [email protected].

11. How we protect your data

We keep access to personal data limited to the people who need it to do their work, we use two-factor authentication on the tools that offer it, and we work only with providers that offer appropriate security measures and encryption in transit.

No system is completely secure. If a breach happens that is likely to put your rights at risk, we will tell you and the competent authority within the time limits set by law. If you think your data has been exposed, write to us straight away.

12. Children

Our services are for adults. We do not offer them to people under 18 and we do not knowingly collect data of minors. If you believe a minor has sent us personal data, write to us and we will delete it.

13. Automated decisions and profiling

We do not take decisions that produce legal effects, or similarly significant effects, based solely on automated processing. The decision on whether a program fits you is taken by a person, after a call.

14. Changes to this policy

We update this policy when our services, our tools or the law change. The date at the top shows the last update. If a change is material, we tell the people concerned by email before it takes effect.

15. How to contact us

For any question about this policy, about how we use your data, or to exercise a right, write to [email protected] or call +39 379 393 6512.