Privacy Policy

Last updated: 13 October 2026

This Privacy Policy explains what personal data The Top Of Descent collects through thetopofdescent.com, why, and what rights you have over it.

Who is responsible for your data

The data controller is Daniele Raina, editor of The Top Of Descent, Milan, Italy.

For any questions about your data, or to exercise your rights, write to hello@thetopofdescent.com.

What data we collect and why

Newsletter. When you join the list, we collect your email address, your first and last name (if you choose to provide them), whether you ticked the consent box, and the date and time of your sign-up. We use this data only to send you the newsletter and messages related to it, such as the confirmation email. Legal basis: your consent (Article 6(1)(a) GDPR). You can withdraw it at any time.

Emails you send us. If you write to hello@thetopofdescent.com with a tip, a press release, an invitation or a correction — we receive your email address, your name and whatever you choose to include. We use it to read and reply to your message. Legal basis: our legitimate interest in handling correspondence about the publication (Article 6(1)(f) GDPR).

Technical data. Like any website, our hosting provider records technical information in server logs when you visit, such as your IP address, browser type, and the pages requested. These are used to keep the site secure and working. Legal basis: our legitimate interest in the security and operation of the site (Article 6(1)(f) GDPR).

Analytics. We use Google Analytics to understand how the site is used: which pages are read, how visitors arrive, and from which kind of device. Google Analytics uses cookies and processes data such as an online identifier and approximate location. It is only activated if you accept statistics cookies in the cookie banner. Legal basis: your consent (Article 6(1)(a) GDPR).

We do not sell your data, and we do not use it for advertising.

How long we keep it

Newsletter list: until you unsubscribe or ask us to delete your data. The record of your consent is kept for as long as we need to be able to prove it.
Emails: as long as the correspondence is relevant to the publication’s work and is reviewed at least once a year; messages no longer needed are deleted.
Server logs: for the period set by our hosting provider, normally a few weeks.
Analytics data: for 14 months.

Who processes your data on our behalf

We use a small number of service providers, who process data only on our instructions:

Aruba S.p.A. (Ponte San Pietro, Italy), which hosts the website, its database and the email service, with servers in Italy.
Google Ireland Limited, for Google Analytics. Data may be transferred to the United States; Google relies on the EU-US Data Privacy Framework and Standard Contractual Clauses.
MailerLite (UAB MailerLite, Vilnius, Lithuania), which stores the newsletter list and sends the newsletter on our behalf.

Your rights

Under the GDPR, you have the right to:

access the personal data we hold about you;
have it corrected if it is inaccurate;
have it deleted;
restrict or object to its processing;
receive it in a portable format;
withdraw your consent at any time, without affecting what was done before.

To exercise any of these rights, write to hello@thetopofdescent.com. We will reply within one month.

You also have the right to lodge a complaint with a supervisory authority. In Italy, this is the Garante per la protezione dei dati personali (garanteprivacy.it).

Cookies

How we use cookies, and how to change your choices, is explained in our Cookie Policy. You can change your preferences at any time through the “Cookie settings” link at the bottom of every page.

Changes to this policy

If this policy changes, we will update this page and the date at the top.