UltraSkills

Privacy Policy

Last updated: April 21, 2026 — Version 1.1

1. Data Controller

Ultra Skills ("we", "us", "our") is operated in Italy.

We are the data controller responsible for your personal data processed through this website, as defined under Article 4(7) of the General Data Protection Regulation (GDPR).

2. What Data We Collect

Information you provide directly

  • Contact form: name, email address, company name, project type, message content
  • Newsletter signup: email address
  • Resource downloads: email address, which resource was downloaded

Information collected automatically

  • Analytics data: page views, referral source, device type, browser type, general geographic region, clicks, scrolls, and session interaction recordings (collected via Google Analytics 4, Vercel Web Analytics, and Microsoft Clarity, only after you grant analytics consent)
  • Cookie consent choices: your consent preferences, timestamp, anonymized IP address, consent receipt ID

We do not collect sensitive personal data (health, biometric, political, or religious data).

3. Legal Basis for Processing

Under GDPR Article 6, we process your data based on the following legal grounds:

  • Consent (Art. 6(1)(a)): newsletter subscription, resource downloads, analytics cookies, marketing cookies. You can withdraw consent at any time.
  • Legitimate interest (Art. 6(1)(f)): responding to contact form inquiries you initiate, improving our website based on aggregated analytics.
  • Contract performance (Art. 6(1)(b)): delivering digital products you purchase (when available).

4. How We Use Your Data

  • To respond to your contact form inquiries
  • To send newsletters and updates you explicitly opted into
  • To deliver resources you requested via email gate
  • To analyze website usage and improve our content (only with your consent)
  • To comply with legal obligations

We never use your data for automated decision-making or profiling.

Providing your personal data is entirely voluntary. You are not required by law or contract to provide it. However, without your email address, we cannot deliver requested resources or newsletters.

5. Cookies and Tracking

This website uses a cookie consent system compliant with the EU ePrivacy Directive and Italian Garante guidelines. Cookies are grouped into four categories:

  • Necessary: always active. Required for the website to function (consent storage, security).
  • Functional: remember your preferences (e.g., theme). Enabled only with your consent.
  • Analytics: Google Analytics 4 and Vercel Web Analytics for traffic measurement, plus Microsoft Clarity for consent-gated heatmaps and session interaction recordings. Enabled only with your consent. IP anonymization is active where supported.
  • Marketing: currently unused. If enabled in the future, will require your explicit consent.

No analytics or marketing scripts load until you grant consent. You can change your preferences at any time using the "Cookie Preferences" link in the footer. Closing the cookie banner (X button) is treated as rejecting non-essential cookies, not as consent.

6. Third-Party Services (Data Processors)

We share your data with the following processors, each under their own privacy policy and data processing terms:

  • Supabase (EU West region) — database hosting for leads, contact form submissions, and consent logs
  • Brevo (EU) — email marketing, newsletter delivery, and transactional emails
  • Google Analytics 4 — website analytics (only with your consent, IP anonymization enabled)
  • Microsoft Clarity — heatmaps and session interaction recordings (only with your analytics consent)
  • Vercel (US, with EU data processing) — website hosting, deployment, and consent-gated Web Analytics
  • Cal.com — appointment scheduling for discovery calls

We do not sell, rent, or trade your personal data to any third party.

7. Data Retention

  • Contact form submissions: retained for 2 years, then deleted
  • Newsletter subscribers: retained until you unsubscribe
  • Resource download records: retained for 2 years
  • Cookie consent logs: retained for 3 years (legal compliance)
  • Google Analytics data: retained for 14 months
  • Microsoft Clarity data: click data retained for 9 months; recording playback data retained for 30 days; labeled or favorited sessions retained for 9 months

8. International Data Transfers

Your data is primarily stored in the EU (Supabase EU West, Brevo EU). Some processors (Vercel, Google, Microsoft) may transfer data to the United States under EU-approved mechanisms including the EU-US Data Privacy Framework and Standard Contractual Clauses.

9. Your Rights Under GDPR

If you are in the EU/EEA, you have the following rights under GDPR Articles 15-22:

  • Right of access (Art. 15): request a copy of your personal data
  • Right to rectification (Art. 16): correct inaccurate data
  • Right to erasure (Art. 17): request deletion of your data
  • Right to restrict processing (Art. 18): limit how we use your data
  • Right to data portability (Art. 20): receive your data in a machine-readable format
  • Right to object (Art. 21): object to processing based on legitimate interest
  • Right to withdraw consent: at any time, without affecting the lawfulness of prior processing

To exercise any of these rights, email us at info@ultra-skills.com. We will respond within 30 days. You can also use our self-service data access and deletion tool at /api/dsar.

You also have the right to lodge a complaint with your local data protection authority. For Italian residents, the supervisory authority is the Garante per la protezione dei dati personali.

10. California Residents (CCPA)

If you are a California resident, you have the right to know what personal information we collect, request its deletion, and opt out of any sale of personal information. We do not sell personal information. To exercise your rights, contact us at info@ultra-skills.com.

11. Children's Privacy

This website is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

12. Changes to This Policy

We may update this policy from time to time. Changes will be posted on this page with an updated revision date and version number. If changes are material, we will notify newsletter subscribers via email.

13. Contact

For any questions about this privacy policy or your personal data, contact us at: