Section 01 Introduction and Who We Are

Trovi.co (“Trovi,” “we,” “our,” or “us”) is a real estate information platform operated by Trovico LLC, a company incorporated in the United States, with its principal place of business at 5900 Balcones Drive, Austin, TX 78731. Our platform is designed to assist American citizens, residents, and other prospective buyers in discovering, researching, and connecting with real estate opportunities throughout Italy, including residential properties, villas, farmhouses, historic estates, apartments, and land. We operate as an information and lead-generation service that connects prospective buyers with licensed Italian real estate agencies. We are not ourselves a licensed real estate broker, agent, or transaction intermediary in any jurisdiction.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you visit our website at trovi.co (the “Site”), communicate with us, submit inquiries about properties, or otherwise interact with our services. It also explains the rights you hold with respect to your personal data and how you may exercise them.

Our platform serves users across the United States, Italy, the European Union, the United Kingdom, and other jurisdictions globally. We are subject to multiple privacy frameworks, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the EU General Data Protection Regulation (GDPR), the UK GDPR as implemented by the Data Protection Act 2018, the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended), the UK Privacy and Electronic Communications Regulations 2003 (PECR), and, where applicable, the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA). We have designed this Policy to comply with all of these frameworks.

For purposes of EU and UK GDPR, Trovico LLC is the data controller of personal information collected through this Site. Trovico LLC is established in the United States and does not currently have a designated EU representative under Article 27 GDPR or a UK GDPR representative under Article 27 UK GDPR. We are actively in the process of appointing representatives in both jurisdictions and will update this Policy upon appointment. In the interim, EU and UK residents may direct all privacy-related requests directly to Trovico LLC at privacy@trovi.co or at 5900 Balcones Drive, Austin, TX 78731, United States. We will respond within the same timeframes that would apply to requests directed to a local representative.

By using our Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use our Site or submit personal information to us.

Section 02 Information We Collect

2.1 Information You Provide Directly

When you interact with Trovi.co, you may voluntarily provide personal information. This includes information entered when submitting a property inquiry through our contact forms — your full name, email address, telephone number, and the content of your message. We collect only the minimum information necessary to respond to your request and connect you with the relevant Italian agency. We do not ask for financial account details, passport numbers, or other sensitive identifiers through our Site.

If you book a consultation through our integrated scheduling system (powered by Calendly), we collect your name, email address, and any information you provide at the time of booking. If you contact us directly by email or other channel, we retain the contents of that correspondence, including any personal information it contains.

When you use our search functionality, you may enter location terms, property preferences, price ranges, and bedroom requirements. We may associate these inputs with your session or, where you have a persistent cookie identifier, with your browsing profile, in order to understand what our users are looking for and to improve our service.

2.2 Information Collected Automatically

When you visit our Site, certain information is collected automatically through your browser and device. This includes your IP address, browser type and version, operating system, referring URLs, the pages you visit, the time and duration of your visit, and clickstream data. This information is collected through server logs and through cookies and similar tracking technologies described in Section 3.

We collect general geographic location derived from your IP address. We do not collect precise geolocation data without your explicit consent. We do not use browser fingerprinting techniques to identify individual users.

2.3 Information from Third Parties

We receive property listing data from Apimo, a French real estate software and API platform used by the Italian agencies whose listings appear on our Site. This data includes property details, agency contact information, listing photographs, pricing, and location data. Trovi.co acts as an independent controller of this listing data once received, and we are responsible for its handling in accordance with this Policy.

Section 03 Cookies and Tracking Technologies

Our Site uses cookies and similar technologies to operate core functionality, analyze usage, and improve your experience. We use three categories of cookies: strictly necessary cookies required for the Site to function; analytics cookies that help us understand how visitors interact with our Site in aggregate; and preference cookies that remember your settings across sessions. We do not use advertising or behavioral retargeting cookies, and we do not knowingly permit third-party advertising networks to place cookies on our Site.

For analytics, we use Google Analytics 4 (GA4). Unlike its predecessor, GA4 does not store IP addresses at the logging level — IP addresses are used only to derive approximate geolocation during processing and are not retained in analytics reports. We have configured our GA4 implementation to limit data retention to fourteen months and to disable advertising features and signals. By using our Site, you transmit technical data to Google as described in Google’s Privacy Policy.

Where required by applicable law, including the EU ePrivacy Directive, UK PECR, and other cookie consent laws, we obtain your consent before setting non-essential cookies. When you first visit our Site from a jurisdiction requiring consent, a consent banner will be presented. You may withdraw consent at any time through your browser settings or our cookie preference tool. Declining non-essential cookies will not prevent you from using the core functionality of our Site.

Do Not Track: Our Site does not currently respond to Do Not Track (DNT) browser signals, as there is no universally accepted standard for interpreting such signals. California Business and Professions Code Section 22575 requires this disclosure. If a standard is established, we will reassess our approach. You may limit tracking through your browser’s cookie settings or the opt-out tools provided by analytics providers.

Section 04 How We Use Your Personal Information

We collect and use personal information only for specified, explicit, and legitimate purposes and do not process it in ways incompatible with those purposes. We are committed to collecting only the minimum personal information necessary to fulfill each purpose — a principle known as data minimization — and we do not use personal information for secondary purposes without a valid legal basis.

We use your inquiry information — your name, contact details, and the content of your message — to respond to your questions, provide information about properties you have expressed interest in, connect you with the appropriate Italian real estate agency, and follow up with you during the course of your property search. This is the primary purpose of our service.

We use automatically collected technical information to operate, maintain, and secure our Site, to diagnose and fix technical problems, and to analyze how our Site is used in aggregate so that we can improve its content and functionality. This processing is not used to build individual profiles.

Where you have provided consent or where permitted by applicable law, we may use your contact information to send you newsletters, Italian real estate market updates, buying guides, and other promotional content related to Trovi.co’s services. You may unsubscribe from marketing communications at any time by clicking the unsubscribe link in any email or by contacting us at privacy@trovi.co. We will honor your opt-out within ten business days.

We do not use your personal information for automated decision-making that produces legal or similarly significant effects without human review. We do not build individual profiles for the purpose of behaviorally targeting advertising at you.

Section 05 Sharing Your Personal Information

We do not sell your personal information to third parties. We do not rent or trade your personal information to third-party marketers. We also do not share your personal information with third parties for cross-context behavioral advertising purposes.

When you submit a property inquiry, we share your name, contact information, and inquiry content with the relevant Italian real estate agency. Under EU GDPR, Trovi.co and the receiving Italian agency may in certain circumstances be considered joint data controllers under Article 26, as both parties jointly determine the purpose of processing the inquiry. We are formalizing joint controller arrangements with partner agencies as required by Article 26 GDPR and will update this Policy when complete. Each agency processes your data in accordance with its own privacy policy once your information is received by them.

We use third-party service providers — including web hosting, email delivery, analytics, CRM, and scheduling software — to help us operate our Site. These providers are permitted to use your information only to provide services to us and are contractually bound to protect your information. Where required by EU and UK GDPR, we have entered into Data Processing Agreements incorporating Standard Contractual Clauses. Under CCPA, these providers are designated as Service Providers and are contractually prohibited from using your information for any other purpose.

We may disclose personal information where required by law or court order, or where we have a good-faith belief that disclosure is necessary to protect the rights, property, or safety of Trovi.co, our users, or the public. In the event of a merger, acquisition, or restructuring, personal information may be transferred as part of that transaction, and we will notify affected users.

Section 06 Legal Bases for Processing (EU & UK GDPR)

For users located in the EU, EEA, UK, and Italy, this section explains the legal bases on which we rely to process your personal data. We process personal data only where a valid legal basis exists.

When you submit a property inquiry or consultation request, we process your data on the basis of Article 6(1)(b) GDPR — processing is necessary for pre-contractual steps taken at your request. By submitting an inquiry, you are initiating a pre-contractual relationship in which processing your contact information is essential to providing any response.

For sending marketing communications, we rely on your consent under Article 6(1)(a) GDPR where required by law, or on legitimate interests under Article 6(1)(f) where consent is not required under applicable national law.

For the operation, security, and analytics of our Site, we rely on legitimate interests under Article 6(1)(f) GDPR. Our legitimate interests are: maintaining a functional and secure online service, understanding how our Site is used in order to improve it, and conducting our business as an Italian real estate information platform. The processing involved is limited to technical and behavioral data that does not reveal sensitive characteristics; you would reasonably expect such processing from a commercial website; and the data is not used to make consequential decisions about you. We are satisfied that our legitimate interests are not overridden by your fundamental rights in this context.

For compliance with legal obligations applicable to Trovico LLC, we rely on Article 6(1)(c) GDPR.

Section 07 International Data Transfers

Trovico LLC is incorporated and operated in the United States. When you interact with our Site from the EU, EEA, UK, Italy, or other countries, personal information you submit is transferred to and processed in the United States. The United States does not have an adequacy decision from the European Commission under EU GDPR or from the UK ICO under UK GDPR, meaning it is considered a third country that does not automatically guarantee the same level of data protection.

For transfers of personal data from the EEA to the United States, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission under Article 46(2)(c) GDPR — specifically the 2021 SCCs issued by Commission Implementing Decision (EU) 2021/914. For transfers from the United Kingdom, we rely on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs as applicable.

When you submit an inquiry that is forwarded to an Italian real estate agency, data flows from Trovico LLC in the United States to the agency in Italy, which is within the EEA. This transfer from the US to the EU does not require special safeguards under GDPR, which restricts transfers from the EEA to third countries rather than transfers to the EEA.

For Canadian residents, we take reasonable contractual and operational steps to ensure that personal information transferred to the United States receives comparable protection in accordance with PIPEDA. To request a copy of our transfer mechanisms, contact privacy@trovi.co.

Section 08 Your Privacy Rights

8.1 EU GDPR, UK GDPR & Italian Law

If you are located in the EU, EEA, UK, or Italy, you have the right to access the personal data we hold about you and to receive a copy in a portable format. You have the right to correct inaccurate or incomplete data. You have the right to erasure of your data where it is no longer necessary for its original purpose. You have the right to restrict our processing in certain circumstances. You have the right to object to processing based on our legitimate interests, including the absolute right to object to direct marketing at any time. Where processing is based on consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, submit a request to privacy@trovi.co. We will respond within thirty (30) days, extendable by sixty (60) days in complex cases with notice. If you are not satisfied with our response, you may lodge a complaint with your local supervisory authority: Italy — Garante per la protezione dei dati personali (www.garanteprivacy.it); UK — Information Commissioner’s Office (www.ico.org.uk).

8.2 CCPA/CPRA — California Residents

California residents have the right to know what personal information we collect, access specific pieces of that information, request deletion, correct inaccuracies, and opt out of any sale or sharing for advertising (we do not sell or share for advertising). You have the right to limit use of sensitive personal information and the right to non-discrimination for exercising these rights.

Under the California Shine the Light law (Cal. Civ. Code § 1798.83), we confirm that we do not disclose personal information to third parties for their own direct marketing purposes.

Submit a verifiable consumer request to privacy@trovi.co. We will respond within forty-five (45) days, extendable by a further forty-five (45) days in complex cases. You may designate an authorized agent with written authorization. For complaints: California Privacy Protection Agency (www.cppa.ca.gov).

8.3 PIPEDA — Canadian Residents

Canadian residents have the right to access personal information we hold about you and to challenge its accuracy. Contact us at privacy@trovi.co. We will respond within thirty (30) days. For complaints: Office of the Privacy Commissioner of Canada (www.priv.gc.ca).

Section 09 Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, accidental loss, alteration, disclosure, or destruction. All data transmitted between your browser and our servers is encrypted using Transport Layer Security (TLS) 1.2 or higher. Personal information stored on our servers is protected by AES-256 encryption at rest.

Our Site is hosted on infrastructure maintained with industry-standard physical and logical security controls, including restricted data center access, intrusion detection, and regular security audits. We use WordPress as our content management system, kept current with security patches. Administrative access is protected by strong credential requirements and multi-factor authentication.

We limit access to personal information to personnel and service providers who require it for their functions. All such parties are subject to confidentiality obligations and contractual restrictions on further processing.

In the event of a personal data breach posing a high risk to your rights and freedoms, we will notify the relevant supervisory authority within seventy-two (72) hours as required by GDPR Article 33, and will notify affected individuals without undue delay as required by GDPR Article 34. For California residents, breach notification will comply with California Civil Code Section 1798.82.

Section 10 Data Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, including any legal, regulatory, or accounting requirements.

Property inquiry information is retained for three (3) years from the date of submission, reflecting the typical length of a considered real estate purchase process and the period during which pre-contractual claims may arise. If you request deletion before this period expires and no legal obligation requires retention, we will comply promptly.

Automatically collected technical data and server logs are retained in identifiable form for no longer than twelve (12) months. Analytics data processed through Google Analytics 4 is retained for fourteen (14) months under our current configuration. Aggregated, de-identified analytical data that cannot be linked to any individual may be retained indefinitely for statistical purposes.

Email and written correspondence is retained for five (5) years. Marketing preference records are retained for the duration of your relationship with Trovi.co and for five (5) years thereafter. Property listing data received from Apimo is retained for as long as listings are displayed on our Site, plus up to twelve (12) months thereafter.

When personal information is no longer needed, it is securely deleted or anonymized. Where immediate deletion is not technically possible, the data is isolated from active processing and deleted at the next scheduled backup rotation cycle.

Section 11 Children’s Privacy

Our services are not directed to individuals under the age of eighteen (18). The purchase of real estate requires the legal capacity to enter into contracts. We do not knowingly collect personal information from minors. If you are under eighteen, please do not submit any personal information through our Site.

If we become aware that we have collected personal information from a child under eighteen without appropriate parental consent, we will delete that information promptly. If you are a parent or guardian who believes your child has submitted information to us, please contact privacy@trovi.co immediately.

Section 12 Third-Party Links and Services

Our Site may contain links to third-party websites, including Italian real estate agencies, legal services, currency exchange providers, and financial advisors. This Privacy Policy applies only to our own Site and services. We encourage you to review the privacy policies of any third-party site you visit through a link on our Site.

Our integration with Calendly means that interactions with the scheduling widget are governed by Calendly’s privacy policy in addition to this Policy. Our use of Google Analytics 4 involves data transmission to Google as described in Section 3 and in Google’s Privacy Policy.

Section 13 Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, applicable law, or business operations. When we make material changes, we will update the “Last Updated” date and, where required by applicable law or where changes are significant, provide more prominent notice through a banner on our Site or an email notification to users who have provided their email address.

Your continued use of our Site after the effective date of any update constitutes acceptance of the revised Policy. If you do not agree to the revised Policy, you should discontinue use of our Site and contact us to request deletion of your personal information.

Section 14 Contact Information

For any questions, concerns, or requests relating to this Privacy Policy or our handling of your personal information, please contact us through any of the following channels. We aim to respond to all privacy-related inquiries within thirty (30) days.