Privacy and Cookie Policy
1. Data controller
The data controller for the personal data collected on www.aqualunaebistrot.com is:
SBEM S.r.l., registered office at Via Ezio 30a, 00192 Rome, Italy, VAT no. 14746191007
Email: Lele_83_brazil@hotmail.it · Certified email (PEC): Sbem2018@cert.cna.it
This notice is provided under Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) and Italian Legislative Decree 196/2003 (“Italian Privacy Code”). No Data Protection Officer (DPO) has been appointed, as one is not required for this business.
2. Data we process
Browsing data. The systems that run this website collect some technical data, such as IP address, browser type, pages visited and time of access. This data is used to keep the website working and secure.
Data you provide. When you contact us by email or phone, or book through TheFork, we process the data you give us or receive from the platform: first name, last name, email, phone number, date and party size. This may also include any allergies or intolerances you choose to tell us about, which we use only to serve you safely.
Data collected through cookies and tracking tools. With your consent, we use Google Analytics 4 and Meta Pixel, which collect data about how you use the website and about your device. Details are in the Cookie Policy section.
3. Purposes and legal bases
| Purpose | Legal basis (GDPR) | Required? |
|---|---|---|
| Running and securing the website | Legitimate interest (Art. 6(1)(f)) | Yes, technical |
| Answering requests and managing bookings | Pre-contractual steps or performance of a contract (Art. 6(1)(b)) | Yes, to receive a reply |
| Handling allergies or intolerances you report | Explicit consent (Art. 9(2)(a)) | No |
| Tax and accounting obligations | Legal obligation (Art. 6(1)(c)) | Yes, if you make a purchase |
| Visit statistics with Google Analytics 4 | Consent (Art. 6(1)(a) and Art. 122 Italian Privacy Code) | No |
| Advertising and campaign measurement with Meta Pixel | Consent (Art. 6(1)(a) and Art. 122 Italian Privacy Code) | No |
You can withdraw your consent at any time, with no effect on your use of the website or on your booking.
4. Who we share data with
Your data is never sold or made public. It may be processed by providers acting as data processors (Art. 28 GDPR):
- Aruba S.p.A., for website hosting
- Google Ireland Ltd., for Google Analytics 4
- Studio Ferrara, for tax and accounting obligations
Bookings through TheFork. Bookings are handled through the TheFork platform (La Fourchette SAS, part of the Tripadvisor group), which processes the data collected on its own website and app as an independent controller, under the privacy policy published on thefork.com. SBEM S.r.l. receives from TheFork the data needed to manage your booking.
Meta Pixel and joint controllership. For the collection and transmission of data through Meta Pixel, the controller and Meta Platforms Ireland Ltd. are joint controllers (Art. 26 GDPR), as established by the Court of Justice of the EU (case C-40/17). For any further processing, Meta acts as an independent controller under its own privacy policy.
The up-to-date list of data processors is available on request at Lele_83_brazil@hotmail.it.
5. Transfers outside the EU
Google and Meta may transfer data to the United States. These transfers rely on the European Commission’s adequacy decision on the EU-US Data Privacy Framework of 10 July 2023, to which Google LLC and Meta Platforms Inc. are certified. Standard Contractual Clauses under Art. 46 GDPR also apply.
You can check the companies’ certification on the official website dataprivacyframework.gov.
6. How long we keep data
| Data | Retention period |
|---|---|
| Contact requests | As long as needed to reply, then up to 12 months |
| Bookings | 24 months from the booking date |
| Allergies or intolerances | Deleted once the service has been provided |
| Tax documents | 10 years, as required by law |
| Google Analytics 4 data | 2 months (Google Analytics 4 default setting) |
| Cookies and tracking | See the table in the Cookie Policy |
| Cookie consent records | For the duration of the consent, and no longer than needed to prove it |
7. Your rights
At any time you can ask to:
- access your data and receive a copy (Art. 15)
- correct or update it (Art. 16)
- erase it (Art. 17)
- restrict its processing (Art. 18)
- receive it in electronic format to transfer it elsewhere (Art. 20)
- object to processing based on legitimate interest (Art. 21)
- withdraw your consent, without affecting processing already carried out (Art. 7)
To exercise these rights, write to Lele_83_brazil@hotmail.it or to our certified email Sbem2018@cert.cna.it. We reply within 30 days.
If you believe the processing breaches the GDPR, you can lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali.
8. Cookie Policy
Cookies are small files saved by your browser. On this website we use technical cookies, which do not require consent, and statistics and marketing cookies, which are set only if you accept them in the banner.
Managing your consent. On your first visit, the banner lets you accept all, reject all or choose by category. Closing the banner with the X keeps only technical cookies. You can change your mind at any time using the “Cookie preferences” link at the bottom of every page. The banner will not be shown again for at least 6 months, unless there are significant changes.
| Cookie | Provider | Category | Purpose | Duration |
|---|---|---|---|---|
| cookie_notice_accepted or hu-consent | This website (Cookie Compliance plugin) | Technical | Stores your cookie choices | 6 months |
| _ga | Google Analytics 4 | Statistics | Distinguishes visitors under a pseudonym | 2 years |
| _ga_[ID] | Google Analytics 4 | Statistics | Keeps the session state | 2 years |
| _fbp | Meta Pixel | Marketing | Measures campaigns and shows relevant ads | 3 months |
| fr | Meta (facebook.com) | Marketing | Personalised advertising on Facebook and Instagram | 3 months |
Provider policies: Google (how Google uses data) and Meta.
You can also block or delete cookies in your browser settings. For Google Analytics, an opt-out browser add-on is available.
9. Changes to this policy
This policy may be updated, for example when we add new services or tools to the website. The current version is always published on this page. In case of any discrepancy between language versions, the Italian version prevails.
Last updated: 5 October 2026.
