Last updated: 26 August 2026
This Privacy Policy describes how VAULTS1 S.R.L. (hereinafter also referred to as “VAULTS1”, “we”, “us” or the “Data Controller”) collects, uses, stores and protects the personal data of users of the website www.cassettasicurezza.it, customers and persons who come into contact with VAULTS1 or use its safe deposit box rental services.
VAULTS1 processes personal data in accordance with:
Regulation (EU) 2016/679 – General Data Protection Regulation (GDPR);
Italian Legislative Decree No. 196 of 30 June 2003 (Personal Data Protection Code), as amended by Legislative Decree No. 101/2018;
applicable provisions and measures issued by the Italian Data Protection Authority;
applicable Italian and European legislation concerning personal data protection and electronic communications.
This Privacy Policy applies, among other situations, when the Data Subject:
visits www.cassettasicurezza.it;
requests information about our services;
books or rents a safe deposit box;
enters into a contract online or at a VAULTS1 location;
creates or uses a customer account;
accesses VAULTS1 premises and the vault;
uses additional services;
participates in the Partnership Programme;
makes a payment;
contacts VAULTS1 by email, telephone or other channels;
consents to receive commercial communications;
interacts with analytics tools or online advertising campaigns, subject to consent where required.
Simply browsing the website or reading this Privacy Policy does not constitute consent to processing activities for which the law requires a specific expression of consent.
VAULTS1 S.R.L.
Tax Code and VAT Number: 14378300967
Registered office: Via Vincenzo Monti, 47 – 20123 Milan (MI), Italy
Email: info@cassettasicurezza.it
Telephone: +39 347 913 9108
Website: www.cassettasicurezza.it
For matters relating to personal data protection or to exercise your rights under the GDPR, you may write to:
indicating, where appropriate, “Personal Data Protection” in the subject line.
If VAULTS1 appoints a Data Protection Officer (DPO) pursuant to Articles 37 et seq. of the GDPR, the relevant contact details will be published and kept up to date on the website.
VAULTS1 processes personal data in accordance with the principles established by the GDPR, including:
lawfulness, fairness and transparency;
purpose limitation;
data minimisation;
accuracy;
storage limitation;
integrity and confidentiality;
data protection by design and by default;
accountability of the Data Controller.
We collect only personal data that is adequate, relevant and necessary for the specific purposes pursued.
Depending on your relationship with VAULTS1, we may process the following categories of personal data.
first and last name;
date and place of birth, where necessary;
Italian tax code;
details of an identity document;
a copy of the identity document, only where necessary and supported by an appropriate legal basis;
details of the representative of a legal entity;
any information necessary to verify identity or authority to represent another person or entity.
address;
email address;
telephone number;
other contact details provided by the Data Subject.
vault location;
size of the safe deposit box;
number or identifier of the safe deposit box;
service start date;
rental period;
contract status;
additional services requested;
key issued;
administrative information relating to delivery and return of the key;
information relating to renewals, amendments or termination of the contract.
access code or identifier;
dates and times of access;
electronic entry records;
access attempts;
events and anomalies recorded by security systems;
information necessary to manage security incidents;
video surveillance images.
identity of the payer;
amount;
date and status of payment;
transaction references;
bank details visible in the event of a bank transfer;
billing information;
accounting documentation.
IP address;
device type;
browser;
operating system;
date and time of access;
pages visited;
session duration;
traffic source;
online identifiers;
advertising identifiers;
interactions with the website;
conversions and other information collected through cookies or similar technologies, subject to consent where required.
enquiries submitted;
content of emails or messages;
customer support history;
information voluntarily provided by the Data Subject.
When the Data Subject contacts VAULTS1 to request information or advice, we may process:
first and last name;
email address;
telephone number;
content of the request;
any additional information voluntarily provided.
responding to enquiries;
providing information about our services;
preparing an offer;
arranging an appointment;
following up on a booking request.
Article 6(1)(b) GDPR: taking steps at the request of the Data Subject prior to entering into a contract.
Where necessary, processing may also be based on Article 6(1)(f) GDPR, namely VAULTS1’s legitimate interest in efficiently managing requests received and documenting relevant communications.
The service may be requested online or at a VAULTS1 location.
To enter into and perform the contract, we may process:
identification data;
Italian tax code;
identity document details;
address;
contact details;
information relating to the selected safe deposit box;
contract duration;
information relating to the key;
information necessary for assigning an access code;
payment information;
contractual and administrative documentation.
The data is used to:
identify the customer;
process the booking;
enter into the contract;
assign a safe deposit box;
issue the key;
provide the access code;
manage the contractual relationship;
manage renewals, amendments and terminations;
issue invoices;
manage payments;
handle any complaints or disputes;
comply with legal obligations.
Article 6(1)(b) GDPR: performance of the contract and pre-contractual measures;
Article 6(1)(c) GDPR: compliance with legal obligations;
Article 6(1)(f) GDPR: VAULTS1’s legitimate interest in protecting security and its rights, where applicable.
The service may also be used by legal entities.
In such cases, we may process:
company name;
tax code and VAT number;
registered office;
billing information;
identity and contact details of the representative;
documentation relating to representative authority;
information relating to authorised persons, where provided for by the service.
The processing of personal data relating to natural persons representing the customer is based on the performance of the contractual relationship and on the legitimate interest of the parties in properly managing the business relationship.
Where the customer has a personal account, we may process:
identification data;
email address;
credentials or technical authentication information;
contract information;
order information;
information relating to the Partnership Programme;
discounts accrued;
account activity.
Passwords, where used, are handled through appropriate technical security mechanisms and are not stored in plain text.
account management;
authentication;
access to service-related information;
contract management;
management of the Partnership Programme;
account security.
Performance of the contract and VAULTS1’s legitimate interest in providing and protecting the restricted customer area.
VAULTS1 allows authorised customers to access the vault in accordance with the terms of the contract.
The customer receives a personal access code.
For security purposes, the system may record:
customer identifier;
access code or technical identifier;
date and time;
successful access;
access attempts;
failed access attempts;
technical and security events.
Each customer access to the vault may be recorded electronically.
allowing access to authorised customers;
preventing unauthorised access;
ensuring the safety of customers and staff;
protecting premises and property;
preventing and investigating incidents;
protecting the rights of VAULTS1 and its customers.
Article 6(1)(b) GDPR: performance of the service;
Article 6(1)(f) GDPR: the legitimate interest of VAULTS1 and its customers in maintaining a high level of security.
Access logs are retained for the period necessary for security purposes and the management of any incidents, taking into account the level of risk associated with the premises and the time limits necessary to protect legal rights.
VAULTS1 facilities are protected by video surveillance systems and other security systems.
Video surveillance may involve the processing of:
images of individuals;
date and time;
location within monitored areas;
events visible within the camera’s field of view.
safety of individuals;
protection of property;
protection of the premises;
prevention of unauthorised access;
prevention and investigation of incidents;
prevention of unlawful conduct;
protection of the rights of VAULTS1 and its customers.
Article 6(1)(f) GDPR: legitimate interest in ensuring the safety of persons, property and premises used for the safekeeping of valuables.
Areas subject to video surveillance are identified by means of appropriate first-level notices in accordance with applicable legislation.
More detailed information on the processing may be made available to Data Subjects through a specific video surveillance privacy notice.
Images are retained only for the period strictly necessary for security purposes, determined according to the principles of necessity, proportionality and data minimisation.
A retention period longer than 72 hours is adopted only where necessary in view of specific security requirements, the level of risk associated with the premises or other circumstances documented by the Data Controller.
Images relating to an incident may be retained for longer where necessary:
at the request of a judicial or law enforcement authority;
to investigate an incident;
to establish, exercise or defend a legal right;
to comply with a legal obligation.
Access to recordings is restricted to duly authorised persons.
VAULTS1 facilities may use advanced technological systems for detecting movements, persons, objects or potentially unusual events as part of its security measures.
Technologies intended solely to detect the presence of a person or object do not necessarily constitute biometric identification systems.
If VAULTS1 were to use biometric technologies intended to uniquely identify a person, for example through biometric facial recognition, such processing would be subject to additional requirements.
Before activating any such processing, VAULTS1 would, where applicable:
identify a lawful basis in accordance with Articles 6 and 9 GDPR;
assess necessity and proportionality;
carry out a Data Protection Impact Assessment (DPIA);
implement enhanced security measures;
provide Data Subjects with a specific privacy notice.
This Privacy Policy does not constitute consent to the processing of biometric data.
The VAULTS1 service consists of the rental of an individual safe deposit box.
As a general rule, VAULTS1 does not systematically inventory the contents of the safe deposit box and does not need to know which items the customer stores inside it.
Any information relating to items stored in the safe deposit box may be processed only where necessary, for example:
at the customer’s request;
to manage an insurance claim;
to manage an incident;
to comply with a legal obligation;
to establish, exercise or defend legal rights;
where such information is voluntarily provided for a specific service.
In such cases, only the data necessary for the specific purpose will be processed.
Where the service includes insurance coverage or the customer requests an increase in coverage, VAULTS1 may process and, where necessary, disclose to the insurance company:
identification data;
contractual data;
information concerning the event;
information relating to the declared value of the property, where necessary;
documentation required for handling the claim.
Depending on the circumstances:
performance of the contract;
compliance with legal obligations;
legitimate interest in managing and investigating a claim;
establishment, exercise or defence of legal claims.
When the customer orders a personal assistance service, we may process:
name;
contact details;
selected location;
date and time of the appointment;
information necessary to organise the service.
To organise and provide the requested service.
Article 6(1)(b) GDPR: taking pre-contractual steps or performance of a contract.
Depending on the options available, payment for services may be made by:
home banking;
bank transfer;
payment card;
PayPal;
cash;
other payment systems that may be made available.
Full payment card details are handled directly by the relevant payment service provider where payment is made through an external platform.
VAULTS1 does not need to know or store the full card number where it is handled directly by the payment service provider.
Depending on the activities performed, payment service providers may act either as independent data controllers or data processors.
performance of the contract;
tax, accounting and administrative obligations.
For administrative, tax, accounting and corporate obligations, we may process:
identification data;
tax code or VAT number;
address;
payment information;
invoices;
contractual information.
Article 6(1)(c) GDPR: compliance with legal obligations to which VAULTS1 is subject.
Customers with an active contract may participate in the VAULTS1 Partnership Programme.
For this purpose, we may process:
Partner identifier;
partnership code;
use of the code;
number of successful referrals;
discounts accrued;
discounts used.
The Partner may view in their account the number of successfully invited participants and the discounts accumulated.
VAULTS1 does not disclose to the Partner the identity or other personal data of the invited person unless this is strictly necessary and supported by an appropriate legal basis.
Performance of the terms of the Partnership Programme and of the contractual relationship with the customer.
During normal browsing of www.cassettasicurezza.it, IT systems may collect certain technical data necessary for the operation of the website.
This may include:
IP address;
date and time;
requested URL;
browser;
operating system;
technical device information;
security logs.
operation of the website;
cybersecurity;
prevention of abuse;
detection of anomalies;
technical management.
Article 6(1)(f) GDPR: VAULTS1’s legitimate interest in ensuring the security and proper functioning of the website.
Analytics or advertising activities that require consent are regulated separately and are not based solely on the legitimate interest in ensuring website security.
The website uses cookies and similar technologies.
Depending on the configuration actually in use, these may include:
Google Tag Manager;
Google Analytics;
Google Ads;
Meta Pixel and Meta Ads tools;
other measurement or advertising technologies.
Strictly necessary technical cookies may be used without consent where they are essential to provide a function requested by the user.
Analytics cookies that cannot be treated as technical cookies, advertising cookies, profiling cookies and other non-essential tracking technologies are used only with the user’s prior consent where required by law.
Such technologies must not be activated before valid consent has been obtained.
Further information is provided in the Cookie Policy and in the website’s Cookie Settings panel.
With the Data Subject’s consent, we may use:
first name;
last name;
email address;
telephone number;
to send:
offers;
promotions;
news;
commercial information;
communications relating to VAULTS1 services.
Article 6(1)(a) GDPR: consent of the Data Subject, together with the applicable provisions of the Italian Privacy Code concerning electronic communications.
Consent may be withdrawn at any time:
via the unsubscribe link included in emails;
by writing to info@cassettasicurezza.it.
Within the limits provided for by Article 130(4) of the Italian Privacy Code, the email address provided by a customer in connection with a service actually purchased may be used to promote the company’s own services that are similar to those already purchased.
In such cases:
the customer must be adequately informed;
the customer must be able to refuse such communications from the outset;
the customer must be able to object free of charge and easily at any time.
This exception does not apply to mere requests for information that have not resulted in an appropriate contractual relationship.
With the Data Subject’s consent, third-party advertising tools may analyse certain interactions with the website in order to:
measure conversions;
attribute a booking to a campaign;
create audience segments;
carry out remarketing;
display more relevant advertising.
Such activity may constitute a limited form of profiling.
Consent of the Data Subject, where required.
VAULTS1 does not make decisions based solely on such advertising profiling that produce legal effects concerning the Data Subject or similarly significantly affect them.
VAULTS1 may maintain profiles on social media platforms.
When a Data Subject interacts with VAULTS1 profiles, we may process, within the limits permitted by the platform:
profile name;
username;
comments;
messages;
reactions;
other interactions voluntarily made.
Social media platforms also process personal data independently as separate data controllers in accordance with their respective privacy policies.
Personal data may be obtained:
directly from the Data Subject;
from their representative;
from the company or entity represented;
from access control systems;
from security systems;
from the website;
from payment service providers;
from analytics and advertising platforms, subject to consent;
from insurance companies;
from banks;
from public registers or other lawfully accessible sources where necessary for specific purposes;
from competent authorities where provided for by law.
Providing data marked as necessary for:
identifying the customer;
entering into the contract;
making payment;
complying with legal obligations;
ensuring the security of the premises
is necessary in order to provide the relevant service.
Failure to provide such data may prevent the conclusion or performance of the contract.
Providing data for:
marketing purposes;
advertising profiling;
non-essential cookies
is optional.
Refusal to provide the relevant consent does not prevent the use of VAULTS1’s main services.
Personal data may be disclosed or made accessible, to the extent necessary, to:
IT service providers;
hosting and infrastructure providers;
software providers;
CRM providers;
web service providers;
security companies;
access control system providers;
video surveillance service providers;
banks and financial institutions;
payment networks and payment service providers;
PayPal;
Stripe, where used;
tax and accounting advisers;
legal advisers;
auditors;
insurance companies;
marketing service providers;
Google;
Meta;
other analytics or advertising providers actually used;
companies belonging to the VAULTS1 group, where necessary and where an appropriate legal basis exists;
tax authorities;
law enforcement authorities;
judicial authorities;
competent administrative authorities.
Service providers processing personal data on behalf of VAULTS1 are appointed, where necessary, as Data Processors pursuant to Article 28 GDPR.
Other entities may act as independent Data Controllers.
An updated list of the main categories of Data Processors may be requested from the Data Controller.
Some technology, advertising, payment or infrastructure providers belong to international corporate groups.
As a result, certain personal data may be transferred or made accessible outside the European Economic Area.
Where this occurs, VAULTS1 ensures that the transfer is carried out in accordance with Articles 44 et seq. GDPR, using mechanisms such as:
an adequacy decision of the European Commission;
the EU-U.S. Data Privacy Framework, where applicable to the recipient;
Standard Contractual Clauses approved by the European Commission;
Binding Corporate Rules, where applicable;
other mechanisms permitted by the GDPR.
Where necessary, supplementary measures appropriate to the nature of the transfer are adopted.
Personal data is retained only for the period necessary for the purposes for which it was collected and, thereafter, for the period necessary to comply with legal obligations or protect legal rights.
As a general rule, for up to 24 months from the last interaction, unless the relationship continues with the conclusion of a contract or longer retention is required for specific reasons.
For the entire duration of the contractual relationship and thereafter, as a general rule, for up to 10 years, without prejudice to different statutory periods or the need to retain data in connection with disputes or proceedings.
For the period required by applicable law, generally 10 years for documentation subject to the relevant retention obligations.
For the period necessary to process the payment and thereafter for administrative, tax and accounting obligations and any disputes.
For a period proportionate to the security requirements of the premises, incident management and the protection of legal rights, in accordance with the internal retention policies adopted by the Data Controller.
As indicated in the dedicated section and in the specific video surveillance notice, in accordance with the principles of necessity and proportionality.
Until consent is withdrawn or the Data Subject objects.
The minimum information necessary to document withdrawal or objection may be retained thereafter in order to ensure that no further unwanted communications are sent.
In accordance with the periods indicated in the Cookie Policy and Cookie Settings panel.
At the end of the applicable retention period, personal data is deleted, anonymised or, where permitted by Italian law, appropriately restricted or retained exclusively for legal protection purposes.
VAULTS1 adopts technical and organisational measures appropriate to the level of risk in order to protect personal data against:
unauthorised access;
loss;
destruction;
alteration;
unauthorised disclosure;
unlawful use.
Such measures may include:
access controls;
authentication;
privilege management;
security event logging;
IT infrastructure protection;
backups;
physical security systems;
incident management procedures;
confidentiality obligations;
staff training.
Access to personal data is limited to employees, collaborators and service providers who require the information to perform their respective duties.
For the ordinary safe deposit box rental service, VAULTS1 does not generally need to process the special categories of personal data referred to in Article 9 GDPR, such as data relating to:
health;
racial or ethnic origin;
religious beliefs;
political opinions;
trade union membership;
sex life or sexual orientation;
genetic data;
biometric data used for the purpose of uniquely identifying a person.
The Data Subject is asked not to voluntarily provide such information unless it is strictly necessary.
If, in a specific situation, it becomes necessary to process special categories of personal data, such processing will be carried out only where one of the conditions provided for under Article 9 GDPR applies and with appropriate safeguards.
The safe deposit box rental service is intended for persons who have the legal capacity required to enter into the relevant contract.
VAULTS1 does not intentionally offer its contractual services directly to minors who cannot validly enter into the contract and does not knowingly use their personal data for marketing purposes.
In the cases and within the limits provided for by Articles 15–22 GDPR, the Data Subject has the following rights.
To obtain confirmation as to whether personal data concerning them is being processed and to receive information about the processing and a copy of the data.
To obtain correction of inaccurate data or completion of incomplete data.
To obtain deletion of personal data in the cases provided for under Article 17 GDPR.
The right to erasure is not absolute. VAULTS1 may continue to retain certain data where this is necessary to comply with a legal obligation or to establish, exercise or defend a legal right.
To obtain restriction of processing in the cases provided for under Article 18 GDPR.
Where applicable, to receive data provided in a structured, commonly used and machine-readable format and transmit it to another data controller.
To object, on grounds relating to the Data Subject’s particular situation, to processing based on legitimate interests.
To object at any time and without providing reasons to the use of personal data for direct marketing, including profiling related to such direct marketing.
To withdraw consent previously given at any time.
Withdrawal does not affect the lawfulness of processing carried out before the consent was withdrawn.
In the circumstances provided for under Article 22 GDPR, not to be subject to decisions based solely on automated processing which produce legal effects concerning the Data Subject or similarly significantly affect them.
The Data Subject may submit a request to:
VAULTS1 S.R.L.
Via Vincenzo Monti, 47
20123 Milan (MI)
Italy
or:
Recommended subject line:
“Data Protection – Exercise of Rights”
The request should indicate:
the identity of the Data Subject;
the right they wish to exercise;
sufficient information to identify the personal data concerned by the request.
VAULTS1 may request additional information necessary to verify the identity of the applicant only where there are reasonable doubts concerning their identity.
A response will be provided without undue delay and, as a general rule, within one month of receipt of the request.
In the cases provided for under the GDPR, this period may be extended by a further two months, taking into account the complexity and number of requests. In such cases, the Data Subject will be informed within the time limits provided for by the GDPR.
A Data Subject who considers that the processing of their personal data infringes applicable data protection law has the right to lodge a complaint with:
Garante per la protezione dei dati personali
Italian Data Protection Authority
Information and instructions on how to lodge a complaint are available at:
The Data Subject’s right to apply to the competent judicial authority remains unaffected.
Before lodging a complaint, the Data Subject may also contact VAULTS1 at info@cassettasicurezza.it so that we can review the matter.
VAULTS1 may periodically update this Privacy Policy, for example in the event of:
changes to services;
introduction of new features;
changes to security systems;
opening of new locations;
changes to service providers;
introduction of new technologies;
changes in legislation;
new guidance from competent authorities.
The updated version will be made available at www.cassettasicurezza.it.
The date of the most recent update will always be indicated at the beginning of the document.
Where changes significantly affect the way personal data is processed, Data Subjects will be informed through appropriate means.
VAULTS1 S.R.L.
Tax Code and VAT Number: 14378300967
Registered office and vault:
Via Vincenzo Monti, 47
20123 Milan (MI)
Italy
Email: info@cassettasicurezza.it
Telephone: +39 347 913 9108
Website: www.cassettasicurezza.it