ESPI Engineering S.r.l · Twin Disc

Privacy Policy

Last updated: 21 September 2026

This notice explains how ESPI Engineering S.r.l — Twin Disc Division processes data collected through assistenza-twindisc.it, twindisc-ricambi.it and twindisc.espisrl.com under Regulation (EU) 2016/679 (GDPR).

This notice is written in Italian and translated for ease of reading. Contact the controller for clarification about any translation.

1. Controller and privacy contact

The data controller is ESPI Engineering S.r.l, Via Emilia Ovest 71/73, 41013 Castelfranco Emilia (MO), Italy. Privacy responsible person: Francesco Pezzoni. For personal data questions and rights requests, email [email protected]. This website covers Twin Disc assistance and spare parts for land-based applications.

2. Data collected and purposes

The form requires your name, email, service type, message and acknowledgement of the privacy notice. Phone, company, model, serial number and location are optional. We use this information to respond, identify components and handle service or parts requests. Requests are emailed to the company mailbox; they are not stored in a website database and no automatic copy is sent to the visitor. There are no accounts, job applications or file uploads. Do not submit sensitive or unnecessary information.

3. Legal bases and nature of data provision

Handling requests and requested pre-contractual steps is based on Article 6(1)(b) GDPR; legal obligations on Article 6(1)(c). Security, abuse prevention and website operation rely on the controller’s legitimate interests under Article 6(1)(f). Required fields are needed to handle the request; the form cannot be submitted without them. Acknowledging the notice is not marketing consent. No third-party analytics, advertising pixels or commercial profiling are active. Spam protection uses automated technical assessments, without decisions producing legal or similarly significant effects on individuals.

4. Retention

Emails are retained as needed to answer requests, manage any resulting relationship and meet applicable obligations. Criteria depend on the request and the protection of rights. Technical security data is limited to these purposes: submission limits use a 10-minute window per IP address. This window does not necessarily mean technical files or logs are deleted after 10 minutes. Cookie durations are listed in the Cookie Policy. Ask the controller for details or deletion where applicable.

5. Providers, recipients and external services

Authorised staff and technical providers may access data for assigned hosting, maintenance and email tasks. InCloud S.r.l creates and maintains the website; emails use the company’s mail service. Google reCAPTCHA loads automatically on form pages and processes IP addresses, browser/device information and interaction signals to prevent spam, fraud and abuse; server verification also transmits the IP address. Under the service documentation updated in 2026, Google acts as processor for reCAPTCHA customer data. OpenStreetMap automatically supplies map tiles on coverage pages and receives the IP address and request metadata. We do not use device geolocation. WhatsApp and Google Maps are external links, contacted only when followed. Website fonts, libraries, images and the 3D model are hosted locally.

6. Transfers and security

International providers may process data outside the European Economic Area; GDPR Chapter V safeguards and the services’ processing terms apply. Ask the controller for information about recipients and applicable safeguards. Production is configured for HTTPS and email delivery uses TLS. The form applies CSRF protection, validation, spam filtering and rate limits. Do not include passwords or confidential documents in your message.

7. Your rights

Where Articles 15–22 GDPR apply, you may request access, correction, erasure, restriction, portability and object to processing. If processing is based on consent, you may withdraw it without affecting earlier lawful processing. Write to [email protected]. You may complain to the Italian Data Protection Authority or your competent local authority. If spam protection prevents submission, contact us by phone or email.

Counting contact clicks

To understand which pages help visitors contact us, we record phone and WhatsApp clicks: click type, page path without parameters, language, date and a random code for each event. The record contains no names, contact details, form contents, IP addresses, user agents or advertising identifiers. We add no cookies or visitor identifiers for this count. Events are kept on the server for up to 90 days and may be forwarded to the controller’s reporting system through a configured webhook. They are used to produce counts by page and contact type, are not linked to people and are not sent to Google Ads. Future advertising attribution will require separate configuration and updated privacy choices.

Optional cookies, Analytics and Google Ads

The site initialises Google Consent Mode v2 with analytics_storage, ad_storage, ad_user_data and ad_personalization denied by default. Google Analytics and Google Ads tags remain physically unloaded until you choose “Accept optional”; without the identifiers configured on the server they are not loaded even after acceptance. With consent, page views and contacts via phone, WhatsApp and the form may be measured, together with the page and the type of service. You can change your choice from “Manage cookies”. Internal counting without identifiers continues for operational security and aggregate measurement.

Garante per la protezione dei dati personali ↗ · Google reCAPTCHA ↗ · OpenStreetMap ↗