Privacy Policy

Last updated: 16 April 2026

Operator: ADG Management LLC (EIN: 38-4388279), 30 N Gould St Ste N, Sheridan, WY 82801, United States ("ItalyPath", "we", "us", "our").

Contact: info@italypath.com

1.1. Who we are and what this policy covers

ItalyPath is a service operated by ADG Management LLC that connects individuals seeking to relocate to Italy ("Applicants", "you") with independent, licensed Italian immigration lawyers ("Lawyers"). This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and the rights you have over your data.

ItalyPath is not a law firm and does not provide legal advice. We are a matching and referral service.

1.2. Data Controller

ADG Management LLC acts as the Data Controller for the personal data collected through italypath.com (the "Site") and related services.

1.3. What personal data we collect

(a) Information you provide through the matching form:

Full name
Email address
Phone number (optional)
Country of residence and nationality
Visa pathway of interest (elective residency, digital nomad, citizenship by descent, family reunification, other)
Detailed personal, economic and family information relevant to assessing your immigration situation
Any free-text information you choose to share with us about your situation

(b) Information collected automatically when you use the Site:

IP address and approximate location derived from it
Browser type, operating system, device identifiers
Referring URL, pages visited, time spent, interactions with the Site
Cookie identifiers (see Cookie Policy)

(c) Information we receive from third parties:

Analytics providers, advertising platforms, and Lawyers you are matched with.

We do not knowingly collect data from children under 16.

1.4. Why we use your data and on what legal basis

Purpose	Legal basis (GDPR)
To assess your matching form and connect you with a suitable Lawyer	Performance of a contract (Art. 6(1)(b))
To send you the Lawyer's contact details and follow-up communications	Performance of a contract (Art. 6(1)(b))
To share your data with the matched Lawyer	Performance of a contract and your explicit consent
To improve our matching algorithm and service quality	Legitimate interest (Art. 6(1)(f))
To send marketing communications (only if you opted in)	Consent (Art. 6(1)(a))
To comply with legal obligations, prevent fraud	Legal obligation (Art. 6(1)(c))
To analyse Site usage through cookies	Consent (Art. 6(1)(a)) for non-essential cookies

Note on sensitive information: the data you submit about your family, ancestry, and economic situation is not, in most cases, a "special category" under Article 9 GDPR, but we treat it with the same level of care.

1.5. Who we share your data with

Matched Lawyer(s): once we identify a suitable Lawyer, we share your form data with them so they can contact you.
Service providers (Data Processors): hosting providers, email delivery services, CRM providers, analytics providers.
Legal and regulatory authorities: where required by law.
Advisors: our accountants, lawyers, and auditors, under confidentiality obligations.

We do not sell your personal data.

1.6. International data transfers

ADG Management LLC is established in the United States. Our Lawyers are established in Italy.

For transfers from the EU/UK, we rely on:

EU–U.S. Data Privacy Framework, where applicable
Standard Contractual Clauses approved by the European Commission
UK International Data Transfer Addendum for transfers from the UK
Your explicit consent, where we rely on it

1.7. How long we keep your data

Matching form data: up to 24 months from your last interaction.
Marketing communications data: until you withdraw consent.
Cookie data: see Cookie Policy.
Accounting and tax records: as required by law (up to 10 years).
Data shared with a matched Lawyer: governed by the Lawyer's own privacy policy.

1.8. Your rights

Under GDPR / UK GDPR:

Right of access to your data
Right to rectification of inaccurate data
Right to erasure ("right to be forgotten")
Right to restriction of processing
Right to data portability
Right to object to processing
Right to withdraw consent at any time
Right to lodge a complaint with your local Data Protection Authority

Under CCPA/CPRA (California residents):

Right to know what personal information is collected, used, shared, or sold
Right to delete personal information
Right to correct inaccurate personal information
Right to opt-out of the sale or sharing of personal information
Right to non-discrimination for exercising your rights

To exercise any rights, contact us at info@italypath.com. We respond within 30 days (GDPR) or 45 days (CCPA).

1.9. Security

We implement reasonable technical and organisational measures to protect your data, including encryption in transit (TLS), access controls, logging, and vendor due diligence.

1.10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the latest version.

Contact

For questions about these documents or to exercise your rights, contact:

info@italypath.com

ADG Management LLC, 30 N Gould St Ste N, Sheridan, WY 82801, United States