Privacy Policy
pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”)
Version dated 15 July 2026
1. Introduction
Martha SRLS (“Martha”, “we”) respects your privacy and processes your personal data in compliance with Regulation (EU) 2016/679 (“GDPR”) and applicable Italian law. This notice describes what data we collect when you visit www.marthapalermo.it, when you register for courses, masterclasses, events or the newsletter, when you make a purchase through the site’s shopping cart or join the patron program, and what rights you have.
2. Data Controller
- Company name: Martha SRLS
- Registered office: Via Siracusa 32, 90141 Palermo (PA), Italy
- VAT/Tax ID: 06914480824
- Company Registration Number (REA): PA 424780
- Certified email (PEC): martha@pec.cgn.it
- Email: info@marthapalermo.it
- Phone: +39 333 100 8512
3. What data we collect
3.1 Browsing data — During normal browsing, our IT systems automatically collect certain data (IP address, browser type, pages visited, access time), used only in aggregate form for statistical and site-security purposes, except as described for analytics cookies.
3.2 Data you provide voluntarily
- Contact details submitted via the contact form or information requests;
- Personal and payment data provided when registering for annual courses, masterclasses, workshops, seminars, house concerts or other paid events;
- Data provided when purchasing through the site’s e-commerce cart;
- Data provided by those joining the “Become a Patron” program;
- Email and name provided when subscribing to the newsletter;
- CV and data provided in the “Work with us” section.
3.3 Images and audio/video recordings — During masterclasses, courses, house concerts and events, we take photographs and audio/video recordings for promotional purposes, published on the website and on Martha’s social media channels (Facebook, Instagram, LinkedIn, YouTube), subject to specific consent collected separately at registration or at the event.
3.4 Payment data — Payments made through the site are handled directly by the payment service providers Stripe, PayPal, Satispay and Nexi. Martha does not store payment card data, which is processed exclusively by these providers under PCI-DSS security standards.
4. Purposes and legal basis of processing
| Purpose | Categories of data | Legal basis (Art. 6 GDPR) |
|---|---|---|
| Allowing browsing and ensuring site security | Browsing data | Legitimate interest (Art. 6.1.f) |
| Responding to information requests | Contact data | Pre-contractual measures (Art. 6.1.b) |
| Managing registrations for courses, masterclasses, workshops, events | Personal, contact, payment data | Performance of a contract (Art. 6.1.b) |
| Managing purchases through the shopping cart | Personal, billing, payment data | Performance of a contract (Art. 6.1.b) |
| Managing Patron program participation | Personal and payment data | Performance of a contract / consent (Art. 6.1.a-b) |
| Sending the newsletter | Name and email | Consent (Art. 6.1.a) |
| Publishing photos/videos for promotional purposes | Images, audio/video | Specific consent (Art. 6.1.a) |
| Complying with accounting and tax obligations | Personal and billing data | Legal obligation (Art. 6.1.c) |
| Establishing/defending a legal claim | Data relevant to the dispute | Legitimate interest (Art. 6.1.f) |
| Statistical analysis of site usage (analytics) | Anonymised/pseudonymised data | Consent (Art. 6.1.a), see Cookie Policy |
5. Who we share data with (recipients)
- Hostinger, for website hosting and technical management (servers located in Europe);
- MailerLite, for sending the newsletter;
- Stripe, PayPal, Satispay and Nexi, for online payment processing;
- Google LLC, for Google Tag Manager, Google Analytics and YouTube (embedded content);
- Accounting, tax and legal advisors engaged by Martha;
- Public authorities, where required by law or a competent authority’s order.
6. Transfer of data outside the European Union
The site uses services provided by Google LLC (Google Tag Manager, Google Analytics, YouTube), PayPal and Stripe, companies with (also) a US presence, which may involve a transfer of personal data outside the European Economic Area, based on the Standard Contractual Clauses approved by the European Commission and additional safeguards provided by these vendors. Hostinger (EU-based servers), MailerLite, Satispay and Nexi operate on European infrastructure. For all other processing, data remains within the European Union.
7. Data retention periods
| Type of data | Retention period |
|---|---|
| Contact data | 24 months from last contact |
| Registrations for courses, masterclasses, events | 10 years (tax/accounting obligations) |
| Billing and payment data | 10 years (Art. 2220 Italian Civil Code) |
| Newsletter data (MailerLite) | Until consent is withdrawn |
| Images and audio/video recordings | Until consent is withdrawn |
| Analytics cookies | See the site’s Cookie Policy |
| “Work with us” applications | 12 months from receipt |
8. Minors
Martha’s advanced training courses and masterclasses are generally intended for adult musicians. Should a minor take part in Martha’s activities, processing of related data and any consent to photos/videos requires prior consent from the person exercising parental responsibility (Art. 8 GDPR).
9. Cookies
The site uses technical cookies and third-party cookies (e.g. Google Analytics) subject to consent via the cookie banner. Details in the Cookie Policy (www.marthapalermo.it/informativa-cookies/).
10. Your rights
Access, rectification, erasure, restriction, objection, portability, withdrawal of consent (marketing, photos/videos), complaint to the Italian Data Protection Authority (www.garanteprivacy.it). Write to info@marthapalermo.it or martha@pec.cgn.it; we will respond within 30 days.
11. Mandatory nature of data provision
Necessary for browsing and for requested services; optional for newsletter and photos/videos.
12. Changes to this notice
Updates will be published on this page with the revision date indicated.
Martha SRLS – Via Siracusa 32, 90141 Palermo, Italy – VAT/Tax ID 06914480824 – REA PA 424780 – PEC martha@pec.cgn.it – info@marthapalermo.it