Legal Information
Effective Date: 14 June 2026
Last Updated: 14 June 2026
Privacy Policy
1. Data Controller
The data controller responsible for the processing of personal data collected through this website is velvet ocean media, with registered office at VIA ROMA, N. 131 FRATTAMINORE (NA) Italy. For any privacy-related inquiries, you may contact us at [email protected].
2. Categories of Personal Data Processed
We collect and process the following categories of personal data when you interact with our services:
- Identification Data: Full name, email address, and phone number submitted via contact forms.
- Technical Data: IP address, browser type and version, operating system, referring URLs, and device identifiers collected automatically through server logs and analytics tools.
- Usage Data: Pages visited, time spent on pages, click patterns, and navigation paths collected through cookie-based analytics.
- Communication Data: Any content you submit through contact forms, email correspondence, or direct messages.
3. Legal Basis for Processing (Article 6, GDPR)
Your personal data is processed on the following legal bases:
- Consent (Art. 6(1)(a)): For newsletter subscriptions and non-essential cookie placement.
- Contractual Necessity (Art. 6(1)(b)): For processing data required to fulfill a service agreement or respond to your pre-contractual inquiries.
- Legitimate Interest (Art. 6(1)(f)): For website analytics, fraud prevention, and service improvement, subject to a balancing test against your fundamental rights.
4. Purpose of Processing
Personal data is processed for the following purposes:
- Responding to your inquiries and providing requested information about our services.
- Executing contractual obligations related to digital marketing and SEO services.
- Analyzing website usage to improve user experience and service quality.
- Complying with legal obligations, including tax and accounting regulations under Italian law.
- Preventing fraudulent activity and ensuring the security of our digital infrastructure.
5. Data Retention
Personal data is retained for the minimum period necessary to fulfill the purposes for which it was collected:
- Contact form submissions: Retained for 24 months from the date of submission, unless an ongoing business relationship is established.
- Contractual data: Retained for the duration of the contract plus 10 years, in compliance with Italian civil and tax law retention requirements.
- Analytics data: Aggregated and anonymized after 26 months; raw data is automatically deleted.
6. Data Recipients and Transfers
Your data may be shared with the following categories of recipients:
- Infrastructure Providers: Cloud hosting and email service providers operating within the European Economic Area (EEA).
- Analytics Providers: Google Analytics (with IP anonymization enabled and data processing agreement in place).
- Legal Authorities: Tax authorities, courts, and regulatory bodies where required by law.
We do not transfer personal data outside the EEA without appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission as per Article 46(2)(c) GDPR.
7. Data Subject Rights (Articles 15-22, GDPR)
Under the General Data Protection Regulation, you have the following rights:
- Right of Access (Art. 15): Request a copy of all personal data we hold about you.
- Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data.
- Right to Erasure (Art. 17): Request deletion of your data where there is no compelling legal ground for continued processing.
- Right to Restriction (Art. 18): Request limitation of processing in certain circumstances.
- Right to Data Portability (Art. 20): Receive your data in a structured, commonly used, machine-readable format.
- Right to Object (Art. 21): Object to processing based on legitimate interests, including direct marketing.
- Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days of receipt of your verified request.
8. Right to Lodge a Complaint
If you believe that the processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali (Italian Data Protection Authority):
Piazza Venezia, 11 — 00187 Roma, Italy
Website: www.garanteprivacy.it
Email: [email protected]
9. Security Measures
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS 1.3), access controls, regular security audits, and staff training on data protection obligations.
10. Changes to This Policy
We reserve the right to modify this Privacy Policy at any time. Changes will be published on this page with an updated effective date. We encourage you to review this policy periodically. Significant changes will be communicated via email to registered users.
Refund Policy
1. Scope
This Refund Policy governs all services provided by velvet ocean media ("the Provider"), registered at VIA ROMA, N. 131 FRATTAMINORE (NA) Italy. It applies to digital marketing, SEO, advertising, and content creation services delivered to clients ("the Client").
2. Project-Based Services
For project-based engagements, the following refund terms apply:
- Pre-Project Cancellation: If the Client cancels the project before work has commenced, a full refund of any advance payment will be issued within 14 business days.
- Partial Cancellation: If the project is cancelled after work has commenced but before the delivery milestone, the Client is entitled to a refund proportional to the undelivered portion of the project scope, calculated based on the agreed project milestones and deliverables.
- Post-Delivery: Once a deliverable has been delivered and accepted (or 7 business days have elapsed without written objection), no refund will be issued for that deliverable.
3. Retainer and Subscription Services
For ongoing retainer or subscription-based services:
- The Client may terminate the retainer with 30 days' written notice at the end of any billing cycle.
- Unused portions of the current billing cycle are non-refundable unless the Provider fails to deliver the agreed-upon services due to reasons attributable to the Provider.
- Upon termination, the Provider will deliver all work completed up to the termination date within 5 business days.
4. Satisfaction and Quality Guarantees
If the delivered work materially deviates from the agreed project scope or quality standards outlined in the service agreement, the Client may request:
- Revision: Up to two rounds of revisions at no additional cost, provided the request is submitted within 14 days of delivery.
- Partial Refund: If revisions cannot resolve the quality issue, a partial refund of up to 50% of the affected deliverable's value may be negotiated in good faith.
5. Non-Refundable Items
The following are not eligible for refunds:
- Third-party costs incurred on behalf of the Client (advertising spend, software licenses, stock assets).
- Work completed and accepted in accordance with the project scope.
- Services rendered under a written agreement with specific non-refundable terms.
6. Refund Process
To request a refund, the Client must submit a written request to [email protected] with the project reference, invoice number, and description of the issue. The Provider will acknowledge receipt within 2 business days and resolve the matter within 14 business days.
7. Governing Law
This Refund Policy is governed by Italian law. Any disputes arising from this policy shall be submitted to the exclusive jurisdiction of the courts of Naples, Italy, without prejudice to the mandatory consumer protection rights under Directive 2013/11/EU and Regulation (EU) 2017/1979 (ODR Regulation).
Terms of Service
1. Acceptance of Terms
By engaging the services of velvet ocean media ("the Provider"), registered at VIA ROMA, N. 131 FRATTAMINORE (NA) Italy, you ("the Client") agree to be bound by these Terms of Service. These terms constitute a legally binding agreement between the parties. If you do not agree to these terms, do not engage our services.
2. Scope of Services
The Provider offers digital marketing services including, but not limited to, local SEO, PPC campaign management, Google Business Profile optimization, content marketing, social media advertising, and reputation management. The specific scope, deliverables, timelines, and pricing for each engagement are defined in a separate Service Agreement or Statement of Work (SOW) executed by both parties.
3. Obligations of the Client
The Client agrees to:
- Provide timely access to relevant accounts, platforms, and materials necessary for service delivery.
- Designate a primary point of contact with decision-making authority for project approvals.
- Review and approve deliverables within 7 business days of submission, or they shall be deemed accepted.
- Ensure all provided materials and content do not infringe upon third-party intellectual property rights.
- Make payments in accordance with the agreed payment schedule.
4. Obligations of the Provider
The Provider agrees to:
- Perform services with reasonable care, skill, and diligence in accordance with industry standards.
- Deliver work within the timelines specified in the Service Agreement, subject to timely Client cooperation.
- Maintain confidentiality of all Client information and proprietary data.
- Comply with all applicable data protection regulations, including the GDPR.
- Provide regular progress updates and performance reports as agreed in the SOW.
5. Payment Terms
- Invoices are payable within 14 days of the invoice date unless otherwise specified in the Service Agreement.
- Late payments will incur a statutory interest rate of 8 percentage points above the ECB reference rate, in accordance with Directive 2011/7/EU on late payments in commercial transactions.
- The Provider reserves the right to suspend services if payment is overdue by more than 15 days.
- All quoted prices are exclusive of applicable VAT (IVA), which will be charged at the prevailing Italian rate (22%).
6. Intellectual Property
- Upon full payment, all deliverables created specifically for the Client under a Service Agreement shall be assigned to the Client.
- The Provider retains ownership of all pre-existing intellectual property, tools, frameworks, and methodologies used in service delivery.
- The Client grants the Provider a non-exclusive, revocable license to use Client branding, logos, and case studies for promotional purposes, unless expressly prohibited in writing.
7. Limitation of Liability
To the maximum extent permitted by applicable law:
- The Provider's total aggregate liability under any Service Agreement shall not exceed the total fees paid by the Client for the services giving rise to the claim.
- The Provider shall not be liable for indirect, incidental, consequential, or punitive damages, including loss of profits, revenue, data, or business opportunities.
- The Provider does not guarantee specific ranking positions, traffic volumes, or conversion rates, as these are influenced by factors beyond our control (search engine algorithm changes, market conditions, third-party actions).
8. Confidentiality
Both parties agree to maintain the confidentiality of all proprietary and sensitive information exchanged during the course of the engagement. This obligation survives the termination of the Service Agreement for a period of 3 years. Confidential information shall not be disclosed to third parties without prior written consent, except as required by law.
9. Termination
- Either party may terminate a Service Agreement with 30 days' written notice.
- The Provider may terminate immediately if the Client breaches any material term and fails to cure within 15 days of written notice.
- Upon termination, the Client shall pay for all services rendered up to the termination date.
- Sections on Confidentiality, Intellectual Property, and Limitation of Liability survive termination.
10. Governing Law and Dispute Resolution
These Terms are governed by Italian law. Any disputes shall first be submitted to mediation under the rules of the Camera di Commercio di Napoli. If mediation fails within 60 days, disputes shall be submitted to the exclusive jurisdiction of the courts of Naples, Italy. This does not affect the Client's right to bring proceedings in the courts of their domicile under Article 18 of Regulation (EU) No 1215/2012.
11. Amendments
The Provider reserves the right to amend these Terms at any time. Material changes will be communicated in writing with at least 30 days' notice. Continued engagement of services after the notice period constitutes acceptance of the amended terms.