Privacy Policy

Thank you for using the services of Castello Ruspoli. By means of this document (“Privacy Policy” or “Policy”), you will have access to and become aware of how Castello Ruspoli treats your personal data, whereby our team strongly recommends you read these terms and conditions.

Castello Ruspoli respects and honors your privacy and understands how important it is for you to know and feel safe with the terms of use of your personal data in your interaction with Castello Ruspoli in its online platforms (“Platforms”), as well as in the use of the services it offers (“Services”). For this reason, this Policy clearly describes the data collected by Castello Ruspoli / Scotus Srls, PARTITA IVA 14487011000, with respect to its Service users and subjects (“you”), who has access to such data and for what purposes the data is treated.

In order to have access to the Platforms or use the Services of Castello Ruspoli, you must freely and expressly accept this Privacy Policy, the Free and Clarified Terms of Consent (“Terms of Consent”), and, when using the Platforms, the applicable Terms of Use of Castello Ruspoli (“Terms of Use”). The terms used herein are defined in this Privacy Policy, in the Terms of Consent and/or in the Terms of Use.

This Policy applies to all brands, products and services of Castello Ruspoli, which do not have individual private policies, and are bound to this Policy.

This Policy is in accordance with laws in effect, as well as with the General Data Privacy Law (LGPD – Law 13,709/2018).


For the purposes of this Policy and the applicable laws, Castello Ruspoli understands personal data as any information that identifies you or allows for your identification. Anonymous data, however, is not deemed personal data.

Any and all data collected and requested by Castello Ruspoli refers to the Services provided by Castello Ruspoli, and is used to improve such Services, your experience with the company, as well as the development of new Services that may be of your interest. It also allows for Castello Ruspoli to set up potential partnerships and associations, in the future.

In view of the Services provided, and upon you free, informed, undisputable and express consent, Castello Ruspoli may collect the following data:

1. Profile/Account Information: data such as first name, last name, gender, date of birth, tax identification number (codice fiscal), payment information (such as credit card numbers and billing addresses) and contact information (such as e-mail, telephone number) to set up a profile or account;

2. Self-reported Data: information provided to Castello Ruspoli at your discretion, by means of campaigns, forms, surveys and other functions;

3. Browsing Data: data such as access to pages in the Castello Ruspoli website and data collected during your use of the Castello Ruspoli website, such as location data from your IP address or other means, technical data, such as computers, equipment and devices used, type of network connection and performance of the provider, network and device used, and data obtained from the Contact page in the Castello Ruspoli website; and

4. Additional Data: in the form of and according to the limited consent, as you have agreed to, according to the provisions of this Privacy Policy, the Terms of Consent and the Terms of Use, and as provided for by law.


Castello Ruspoli collects your personal data as follows:

1. Data you share with Castello Ruspoli: whenever you contact Castello Ruspoli via its website, you provide different data, such as full name, e-mail, telephone number, etc., in order to allow for Castello Ruspoli to provide the Services to you;

2. When you access the Platforms and use the Services of Castello Ruspoli: data is collected using cookies and similar technologies, such as pages viewed and browsing devices and equipment used, as well as data on the use of certain functions available at the Platforms or with respect to the Services;

3. Data collected from public and historical records: data extracted from public and historical records, such as newspapers, records of birth/death/marriage, which may contain personal data related to you;


Any personal data Castello Ruspoli collects is treated to meet the following purposes:

1. To improve business activities and campaigns developed by Castello Ruspoli and its business partnerships, as well as to offer personal experiences for you, by means of messages on new services, advertising, campaigns or other marketing tools;

2. To allow for scientific research and surveys to be conducted, which may be either sponsored or developed internally, conducted by or organized with third parties, such as non-profit organizations, academic institutions or companies, based on your consent and in compliance with the private data protection rules required by the applicable laws;

3. To share information with the business partners of Castello Ruspoli, in order to improve the Platforms and Services provided to you, based on your consent and in compliance with the private data protection rules required by the applicable laws; and

4. For other purposes, pursuant to the terms and according to the limits you have consented to, and up to the limits provided for by law.

By agreeing to the Free and Clarified Terms of Consent, you represent to be aware of the personal data treatment measures necessary to provide the contracted Services, and you may also grant specific consent to the activities and purposes mentioned in this Privacy Policy.


Castello Ruspoli may share your personal data with third parties, whenever necessary to provide the contracted Services, or whenever you specifically consent.

Such data is shared in order to achieve the following purposes:

1. To assist in the operation of the Platform and in the provision of the Services, by sharing personal data with out service providers and/or business partners, always strictly as authorized by law and according to your prior and specific consent, when necessary;

2. To allow our service providers and business partners to perform marketing activities, brand assessments, organize advertising campaigns based on interests or similar activities, for Castello Ruspoli;

3. To analyze and solve technical issues and any issues related to potential security risks of the Services provided by Castello Ruspoli;

4. To allow for legal due diligence, as may be strictly necessary, for the purposes of corporate transactions, such as mergers, acquisition or sale of all of the assets of Castello Ruspoli, its business group, in whole or in part, and to transfer any data to the new owner/holder, in the event of change of ownership or control of the Castello Ruspoli or the assets thereof, in whole or in part. The provisions set forth in this Privacy Policy will continue to be applied to your personal data, in the event of transfer thereof to the new owner;

5. To allow for Castello Ruspoli to set up new partnerships, by sharing personal data, to the extent that may be necessary in order to achieve such partnerships, according to your consent, when applicable, and within the limits provided for by the applicable laws;

6. To comply with court orders, according to the strictly necessary terms, as well as to meet the requirements of the applicable laws, events in which the Castello Ruspoli may share the data with government and court authorities. Castello Ruspoli seeks to ensure as much protection as possible for you and for your data. In the events in which Castello Ruspoli is legally ordered to disclose your data, Castello Ruspoli will make its best efforts to notify you prior to sharing such data, except in the events in which is legally prevented to do so;

7. To generate individual data on the use of the Platforms, by you or by the employees of Castello Ruspoli, which data will be shared with the partners of Castello Ruspoli and other companies part of its business group, according to your consent, when applicable, and within the limits provided for by the applicable laws, and provided such parties have a Privacy Policy and business practices with the same level of protection as offered by this Policy;

8. For other purposes, pursuant to the terms and within the limits of the consent granted by you, and according to the limits allowed for or required by law.


Technologies such as cookies (small files stored in the users’ browsers, mobile phones or other devices) are used when you browse the platforms, services and adds of Castello Ruspoli, in order to understand, transfer and protect your data. These technologies may be used to allow Castello Ruspoli to send the most relevant content and offers to you, to improve the Services, as well as to ensure the safety of such Services.

The specific names of the cookies used may vary as the Services are improved and updated, though they are generally limited to the following types of use:

1. Authentication – For example, to inform that you are connected, in order to offer the appropriate resources, as well as to understand how you use the Platforms and Services.

2. Website Safety and Integrity – For example, to help maintain the safety of the Services, to offer support or activate security resources, and to help identify ay activities in violation of the Term of Consent and the Terms of Use.

3. Ads, Ideas and Metrics – For example, to analyze browsing behavior and send adds, to make such adds more relevant for you and analyze the Services and use thereof. For instance, it is possible to use a cookie to understand whether someone who received an add purchased something from the advertiser’s website, or installed the advertised app. Likewise, partners may use cookies or other similar technologies to determine whether Castello Ruspoli promoted one of its adds, and obtain data on the performance thereof, or to inform how you interact with the add.

4. Website Resources and Services – For example, to help offer products and services, when you see or interact with a given content of the Services, and offer other social plug-ins, other experiences and tailored content, or to make suggestions.

5. Performance – For example, to offer the best possible experience, to help route traffic between services and understand the speed at which the Platforms are loaded, for different people. Data may be stored in your browser or device, from time to time, to allow for the used resources to be loaded and respond faster.

6. Analyses and Surveys – For example, to understand, improve and survey services, including when you access websites and apps using your computer or mobile devices. For instance, it is possible to use cookies or similar technologies (including data from your device) to understand how you use social plug-ins and improve them, and data resulting from such analyses may be shared with the business partners of Castello Ruspoli.

You may redefine your web browser to refuse cookies, or to inform you when a cookie is being sent. However, certain website functions may not work properly if the option to accept cookies is switched off.


The pages of the Castello Ruspoli website may contain links to services provided by our business partners, which have their own applicable terms, conditions and policies. However, this Policy is limited to the Platform and the Services provided by Castello Ruspoli itself.

Though Castello Ruspoli always seeks to establish business relationships with trustworthy partners, Castello Ruspoli is not liable for the personal data treatment practices used exclusively by such third parties. For this reason, it is highly recommended for you to read such external terms and policies, prior to providing any personal data during the use of the Services.


When treating your data, Castello Ruspoli will make best efforts to safely store and maintain your data, in compliance with the applicable laws, and according to the terms and conditions set forth in the Free and Clarified Term of Consent you signed, when you contracted the service. For this reason, your personal data and any resulting files will be encrypted, when stored, using high safety levels, including access control measures.

Castello Ruspoli agrees to implement, on an ongoing basis, all the physical, technical and administrative data safety measures to treat you personal data, according to best market practices. The purpose of such measures is to protect your data against unauthorized access, any accidental or illegal destruction, loss, change, communication or any other form of inappropriate or illegal treatment.

To this end, Castello Ruspoli allows its employees and other third parties to have access to your personal data on a need basis, to perform their activities, according to your express instructions and upon contractual obligation of nondisclosure and confidentiality of any personal data treated.


Castello Ruspoli agrees to allow for your rights to be enforced, as best as possible, and as provided for by law, to wit:

1. Confirmation: right to be informed on the existence of data treatment;

2. Access: right to request access to any personal data treated by Castello Ruspoli;

3. Correction: right to request any changes to the personal data treated by Castello Ruspoli, whenever such data is incomplete, inaccurate or outdated;

4. Restriction: right to request anonymity, to block or to eliminate unnecessary or excessive data, or any data treated by Castello Ruspoli in violation of the personal data protection laws;

5. Portability: right to request the transfer the data treated by Castello Ruspoli to a different service provider;

6. Removal: right to request the removal of personal data treated by Castello Ruspoli, at your consent;

7. Information: right to be informed of all the public and private entities with which Castello Ruspoli shares data, and on the possibility to consent such sharing, and the consequences of any related opt-out;

8. Withdrawal of Consent: right to withdraw consent, at any time, by express statement, using any free-of-charge and facilitated process in order to do so; and

9. Review of Automatic Decisions: possibility to review any decisions made by Castello Ruspoli based on the automatic treatment of personal data that affects your interests.

Should you be interested in enforcing any of the aforementioned rights, please contact Castello Ruspoli at the e-mail informed in Item “Miscellaneous”, below.


This Privacy Policy is the valid and effective version of the information on the treatment of your personal data, by Castello Ruspoli. This version governs all the relations between Castello Ruspoli and you, except when you use the services that have their own Privacy Policies, in compliance with the acquired rights, perfect legal acts and final and unappealable decisions.

Castello Ruspoli reserves itself the right to update and modify any of its legal documents, from time to time, including this Privacy Policy.

Castello Ruspoli will previously notify you of any amendment to this Policy that affects any previously granted consent, or which implies financial burden for you. However, any amendments made for legal reasons or as a result of new functions of a given Service will be effective immediately.

If you do not agree or do not feel confortable with any amendments to this Policy, you should suspend the use of the Services. Any future use of the Services will otherwise imply your acceptance of the new version of the Policy.

Should you be wish to enforce any of the aforementioned rights, or if you have any questions related to this document and the practices described herein, please contact Castello Ruspoli at