Privacy Policy

PRIVACY POLICY & DATA GOVERNANCE FRAMEWORK

Last Updated: February 2026

1. DATA CONTROLLER (TITOLARE DEL TRATTAMENTO)

The Data Controller for this website and the "Decision Protocol™" framework is: Lamberto Iezzi - Strategic Risk Advisor & Founder - based in Venice - EU. Email for privacy inquiries: office@decisionprotocolinstitute.com

2. PURPOSE OF DATA PROCESSING

We process personal data solely for the following operational purposes:

• Contractual Fulfillment: To deliver digital license keys, invoices, and product updates (via our Merchant of Record, Lemon Squeezy).

• Legal Compliance: To maintain fiscal records required by Italian and EU tax authorities.

• Commercial Communications: To send the "Shadow AI Amnesty Policy" (Lead Magnet) and subsequent educational updates. You may unsubscribe from these communications at any time.

3. MERCHANT OF RECORD & FINANCIAL CLEARING

To ensure strict adherence to global VAT/GST regulations and digital services directives (EU Directive 2006/112/EC), we utilize a delegated Merchant of Record (MoR) structure.

• Lemon Squeezy, LLC: Acts as the reseller and MoR for all transactions.

• Data Handling: Your payment details (Credit Card numbers) are processed directly by Lemon Squeezy via PCI-DSS Level 1 secure vaults. The Institute does not access, store, or handle your financial data.

4. ADVERTISING & ANALYTICS (GOOGLE ADS)

To measure the effectiveness of our "Forensic Governance" awareness campaigns, this website uses tracking technologies provided by Google LLC (Google Ads and Google Analytics).

• Conversion Tracking: We use cookies to understand if a user clicks on our ad and subsequently downloads a framework. This data is anonymized and used solely for statistical analysis.

• Remarketing: We may use data to show relevant educational ads to users who have previously visited our site.

• Opt-Out: Users can opt-out of Google's use of cookies by visiting Google's Ad Settings or the Network Advertising Initiative opt-out page.

5. DATA RETENTION & SECURITY

• Fiscal Data: Retained for 10 years as mandated by Italian corporate law.

• Marketing Data: Retained until the user requests unsubscription ("Right to be Forgotten").

• Security: We employ enterprise-grade encryption (TLS/SSL) for all data in transit.

6. USER RIGHTS (GDPR)

Under the General Data Protection Regulation (EU) 2016/679, you have the right to:

• Access your personal data.

• Request correction or deletion of your data.

• Object to processing for marketing purposes.

• Request data portability. To exercise these rights, please contact the Data Controller at office@decisionprotocolinstitute.com.