Legal & Privacy

Privacy Policy

AJB Subsea Srl (“AJB Subsea”, “we”, or “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard personal data obtained through our website www.ajbsubsea.com and through our business communications, including those carried out under our commercial brand Sentiq Defence.

1. Data Controller

For the purposes of this Policy, any reference to AJB Subsea, the website, or to data processed by us also applies to activities, communications and materials issued under the Sentiq Defence brand, which is owned and operated by AJB Subsea Srl and does not constitute a separate legal entity.

2. Data Collected

We may collect:

• Identification and contact information (name, surname, email, phone number, company) that you voluntarily provide when contacting us by email or telephone;
• Limited technical data (such as approximate geographic region, pages visited and aggregate traffic statistics) collected in anonymous, aggregated form by our privacy-friendly, server-side website analytics.

Our website does not use tracking cookies, advertising cookies, or third-party profiling tools. We do not collect sensitive data and do not perform automated decision-making or profiling.

3. Purpose and Legal Basis

Personal data are processed for:

• Responding to inquiries or contact requests, including those relating to Sentiq Defence solutions (Art. 6.1(b) GDPR);
• Managing professional and commercial relationships under both AJB Subsea and Sentiq Defence activities (Art. 6.1(b) GDPR);
• Complying with legal obligations (Art. 6.1(c) GDPR);
• Legitimate interest in maintaining the security and functionality of our website (Art. 6.1(f) GDPR).

Email addresses collected through inquiries are used solely to respond to the request and to manage the related professional relationship. We do not send marketing communications, newsletters, or commercial promotions without explicit, prior consent.

4. Processing and Retention

Data are processed using secure digital systems (including Microsoft 365 Business Premium) and are stored only as long as necessary to fulfil the purpose of collection or to comply with applicable legal obligations. As indicative reference periods:

• Contact form and inquiry-related email correspondence: up to 24 months from the last meaningful exchange, unless a professional relationship is established;
• Data related to ongoing or concluded commercial and professional relationships: for the entire duration of the relationship and for 10 years thereafter, in line with Italian civil and tax-law obligations (Art. 2220 of the Italian Civil Code; D.P.R. 600/1973);
• Unsolicited curricula vitae or profiles received: up to 12 months, after which they are erased unless the data subject has expressly consented to longer retention.

Upon expiry of the applicable retention period, data are erased or anonymised in a secure manner.

5. Data Sharing and Transfers

Data may be shared with:

• IT, hosting and cloud service providers supporting our website and communications (including Microsoft Corporation, Aruba S.p.A., and Netlify Inc.);
• Professional consultants or legal advisors supporting AJB Subsea’s operations, including those carried out under the Sentiq Defence brand;
• Technology partners, OEMs and integrators where strictly necessary to respond to specific commercial or advisory requests, with appropriate confidentiality undertakings in place;
• Public authorities, where required by law.

Some of these service providers (such as Microsoft Corporation and Netlify Inc.) are based in the United States. Transfers of personal data to such providers are protected under the EU-U.S. Data Privacy Framework, where the provider is certified, or, in the alternative, under Standard Contractual Clauses adopted by the European Commission pursuant to Art. 46 GDPR. Copies of the relevant safeguards can be requested at info@ajbsubsea.com.

6. Data Subject Rights

Under Articles 15–22 GDPR, you have the right to access, rectify, or erase your personal data; to restrict or object to processing; to data portability; and to withdraw consent where applicable. Requests can be sent to info@ajbsubsea.com or via certified email at ajbsubsea@pec.it, whether the request relates to AJB Subsea or Sentiq Defence activities. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it).

7. Audience and Minors

This website and the services provided by AJB Subsea Srl — whether under the AJB Subsea or Sentiq Defence brand — are addressed to professionals, public institutions and corporate entities (B2B/B2G context). The site is not directed to consumers as defined under Italian Legislative Decree 206/2005 nor to individuals under the age of 16. We do not knowingly collect personal data from minors. Should we become aware that personal data of a minor has been provided, it will be erased without undue delay.