Privacy notice
How we handle your personal data
Last updated: 14 May 2026
This notice describes how Ascari Capital processes the personal data collected through ascaricapital.it, in compliance with EU Regulation 2016/679 (GDPR).
1. Data controller
The data controller for personal data collected through this site is Ascari Capital, a Search Fund initiative currently in the process of being incorporated as an Italian limited company, with operating office in Lucca, Italy.
The contact person for this notice is Matteo Nardini, Principal. For any privacy-related request please write to matteo@ascaricapital.it.
This section will be updated with the full legal entity name, registered office, and tax ID once the vehicle is incorporated.
2. Data we collect
When you request the Private Placement Memorandum (PPM) via the form on the /investors page, we ask for:
- A valid email address.
- Your confirmation that you are a qualified investor under Italian law (T.U.F. — Testo Unico della Finanza, Legislative Decree 58/1998).
On submission, our server also logs technical data: your IP address, your browser/device User-Agent string, and the date/time of the request. These are used exclusively for security and anti-abuse purposes.
While browsing, a technical cookie (`ascari-locale`) is set to remember your language preference. Full details in the Cookie Policy.
3. Purposes
We process your data for the following purposes:
- Sending you the requested document (PPM) and any related materials.
- Replying to follow-up requests if you initiate a conversation (e.g. booking a call).
- Preventing abuse of the request form (e.g. automated or mass submissions).
- Complying with regulatory obligations applicable to financial services.
4. Legal basis
- Your explicit consent given by ticking the form checkboxes (Art. 6.1.a GDPR) — for sending the PPM and related materials.
- Our legitimate interest (Art. 6.1.f GDPR) — for storing IP and User-Agent data for anti-abuse purposes, in a proportionate and time-limited manner.
5. Retention
- Email and conversation content: up to 24 months from your last interaction, or earlier if you request erasure.
- IP and User-Agent linked to the PPM request: 12 months.
- Cookie `ascari-locale`: 12 months from your last visit.
6. External processors and recipients
To operate the site we rely on two providers, both acting as external data processors under Art. 28 GDPR:
- Resend (Beam Inc., Delaware, USA) — transactional email delivery.
- Vercel (Vercel Inc., USA) — site hosting and technical logs.
We do not share your data with any other third party for commercial, advertising, or profiling purposes.
7. Transfers outside the EU
Resend and Vercel are US-based companies. Personal data transfers to them rely on the Standard Contractual Clauses approved by the European Commission under Articles 44–49 GDPR, which provide an adequate safeguard for the transfer.
8. Your rights
At any time you may exercise the following rights:
- Access to your data (Art. 15).
- Rectification of inaccurate or incomplete data (Art. 16).
- Erasure of your data (Art. 17).
- Restriction of processing (Art. 18).
- Data portability in a structured format (Art. 20).
- Objection to processing based on legitimate interest (Art. 21).
- Withdrawal of consent at any time (Art. 7), without affecting the lawfulness of prior processing.
To exercise these rights, write to matteo@ascaricapital.it. We will respond within one month of receipt.
9. Right to lodge a complaint
If you believe the processing of your data violates the GDPR, you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or another competent supervisory authority.
10. Updates
This notice may be updated. The date of the last revision is always shown at the top of the page. Please review it periodically.