Privacy Policy

Last updated: 9 November 2026

21AM S.r.l. respects your privacy. This Privacy Policy explains how we process personal data when you visit 21am.com, submit an enquiry or contact our studio.

1. Who is responsible for your data
The data controller is 21AM S.r.l., VAT number IT07019170963, with its registered office at Via Vannucci 5, 20135 Milan, Italy.
Our studio is located at Via California 12, 20144 Milan, Italy.
For privacy enquiries and requests concerning your personal data, contact write@21am.com.

2. Information we collect
Information you provide
When you use our contact form, we collect your first name, surname, email address, reason for contacting us and message. You can also provide your country and company name.
When you contact us by email or telephone, we process the information you share to handle your enquiry.
If you submit a job application, we also process the professional information, portfolio links and documents you provide. Please send only information relevant to your application or enquiry.

Technical information
Our website infrastructure processes technical information needed to deliver and protect the service, including IP addresses, browser and device information, requested pages, access times and diagnostic information.

Website interaction information
We use Microsoft Clarity, subject to consent for optional tracking, to understand how visitors interact with our website. This includes page visits, clicks, scrolling, navigation patterns and technical device information. Clarity uses online identifiers and produces heatmaps and session replays.

3. How we use your information
We process personal data for the following purposes:

- Service and project enquiries: to respond to your request and take steps towards a potential contract. The legal basis is Article 6(1)(b) GDPR where the request concerns a contract with you.
- General enquiries, business contacts, press and collaboration requests: to manage communications and professional relationships, based on our legitimate interests under Article 6(1)(f) GDPR.
- Job applications: to assess your application and manage recruitment, under Article 6(1)(b) GDPR.
- Website operation and security: to deliver the website, troubleshoot errors and prevent misuse, based on our legitimate interests under Article 6(1)(f) GDPR.
- Optional website analytics: to understand website usage and improve the browsing experience, based on consent under Article 6(1)(a) GDPR.
- Legal obligations and claims: to meet applicable obligations or establish, exercise or defend legal claims, under Article 6(1)(c) or Article 6(1)(f) GDPR, as applicable.

Submitting an enquiry does not subscribe you to a newsletter or authorise unrelated promotional communications.

4. Required and optional information
Fields marked as required are needed to submit the contact form and allow us to respond. Country and company information are optional.
Consent to optional tracking is separate from submitting an enquiry. You can decline optional cookies and still browse the website and contact us.

5. Service providers and other recipients
Personal data is accessible to authorised members of 21AM and service providers supporting our website, contact management, email and technical maintenance, where necessary for their work.
The website is built and hosted using Wix, including its content management, media and form functionality. Information submitted through the website is processed through the services used to receive and manage enquiries. Further information about Wix is available in the Wix Privacy Policy .

We use Microsoft Clarity for behavioural analytics. Microsoft also processes information under its own privacy terms, including for security, service improvement and advertising purposes, according to the applicable settings and consent choices. Clarity should therefore not be understood as an exclusively anonymous statistics service. See the Microsoft Privacy Statement .

Providers processing data on our behalf are subject to appropriate data-processing arrangements. Providers processing information for their own purposes are responsible for those activities under their respective privacy notices.

We can also disclose information to professional advisers or competent authorities where necessary to meet legal obligations or protect legal rights.

6. International transfers
Our technology providers operate internationally, so personal data can be processed outside the European Economic Area.
Where required, transfers are subject to safeguards recognised by the GDPR, such as an applicable adequacy decision or European Commission standard contractual clauses, together with supplementary measures where necessary.

You can request information about the safeguards relevant to your data by contacting write@21am.com.

7. How long information is retained
Retention depends on the purpose for which information was collected:

- Enquiries and correspondence: for the handling of the request and related follow-up. Any subsequent retention is limited to records needed for an ongoing business relationship, a legal obligation or the establishment, exercise or defence of claims.
- Job applications: for the recruitment process to which the application relates and any necessary follow-up. Retention for a separate future recruitment purpose requires an appropriate basis and information to the applicant.
- Technical and security information: according to the operational requirements of the relevant service, including error investigation, incident resolution and prevention of misuse.
- Consent records: for as long as needed to record the applicable preference and demonstrate compliance with consent requirements.
- Microsoft Clarity data: Microsoft specifies 30 days for ordinary session playback data and nine months for labelled or favourited sessions, heatmaps and click data. These periods concern information held by Clarity, rather than cookie lifetimes. See Clarity’s retention documentation .

When determining retention, we consider whether the purpose remains active, the relevance of the information, applicable legal requirements and any unresolved disputes. Information that is no longer required is deleted or anonymised.

8. Your rights
Subject to the conditions established by the GDPR, you can request access, correction, erasure, restriction of processing and data portability. You can object to processing based on legitimate interests for reasons relating to your particular situation.
Where processing relies on consent, you can withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

To exercise your rights, email write@21am.com. Requests are generally free of charge and are answered within one month, subject to the extensions and exceptions permitted by law. We can request proportionate information to verify your identity.

You can lodge a complaint with the Italian Data Protection Authority or another competent supervisory authority.

9. Cookies and external websites
Our Cookie Policy explains the use of cookies and similar technologies.
The website contains links to external services, including social networks and Google Maps. When you follow these links, the relevant providers process information under their own privacy notices.

10. Changes to this policy
We update this policy when our services or processing activities change. The date above identifies the latest revision.