1. Controller and scope
ONMAKE S.r.l., Piazza Giuliano della Rovere 8, 00121 Rome (RM), Italy, VAT IT17261401008, email info@onmake.it, certified email onmake@pec.onmake.it, is controller of the processing relating to xTdC account, subscription, security and support management. For privacy requests use info@onmake.it stating "Privacy xTdC"; technical support may also be reached at support@onmake.it. This address is not presented as the contact of an appointed DPO.
This notice covers xTdC and its connection to the shared ONMAKE account; it supplements the general account notice for the specific processing described here and does not authorise new uses of other applications' data. Reading this notice does not mean consenting to all processing.
2. Roles concerning calculation data
Calculation data (inputs, projects, results, reports, job data and details of the persons entered on cover sheets) stays on the user's device and in the files the user saves: in normal use ONMAKE does not receive or process it, either as controller or as processor. A user who enters personal data of clients or third parties is controller or processor of that processing and ensures notices and legal bases. ONMAKE is controller of account, subscription, security and support data, and of billing data.
3. Data processed and sources
Processed data includes email address, account identifier, credentials and authentication or recovery information, security settings, language and, if enabled, membership of an organisation. Purchasing requires billing data, address, and any tax code, VAT number, certified email and recipient code; from Stripe ONMAKE receives transaction references and status, not the full card number.
When an xTdC page is opened, the shared sign-in script checks on the ONMAKE database the account's permissions, subscription and any block or suspension, and records use: user, app, page-session identifier, start time and time of last activity, updated every two minutes while the tab is in the foreground. IP address, date and time, browser and device information needed for compatibility and security, authentication outcomes and error logs are also processed.
Calculation content is not sent to ONMAKE in normal use. Support requests may contain data the user provides voluntarily: it should be minimised before sending. The information comes from the user, from the operation of the service and from strictly necessary suppliers.
4. Purposes and lawful bases
Account creation, authentication, plan activation, requested processing, service communications and necessary support rely on contract performance or requested pre-contractual steps (article 6(1)(b)). For organisational users not personally party to the contract, contact and entitlement management relies on the legitimate interest in securely providing the organisational relationship (point (f)), subject to proportionality assessment.
Invoicing, statutory tax retention, responses to authorities and mandatory compliance rely on legal obligations (point (c)). Fraud and abuse prevention, security, proportionate evidential records and legal claims rely on legitimate interests (point (f)), unless a specific legal obligation applies. The interest is to protect users, the service and rights; it does not authorise indiscriminate examination of document content.
xTdC subscription does not activate marketing, commercial profiling or non-essential tracking. Any introduction requires relevant information and separate, withdrawable consent where required (point (a)). Service activation and terms acceptance are not consent for these purposes. For content processed as a processor, ONMAKE does not substitute its own lawful basis for the customer's, but follows lawful instructions under article 28.
5. Local processing, third parties and Connect
Calculations run in the browser. Projects, module states and transfers between modules are kept in the browser's local storage and sessionStorage and in the files the user saves (document 04). Browser storage may survive closing the tab and is not the same as saving on ONMAKE servers; clearing browser data or using private browsing may lose it: users keep copies of the projects they want to keep.
When the print or report window of some modules is opened, the browser loads the KaTeX stylesheet (version 0.16.9) from cdn.jsdelivr.net: the calculation content is composed locally, but the content-delivery network operator may receive ordinary technical connection data, such as the IP address and the browser identifier.
The "Open in Editor" command (ONMAKE Connect) opens Editor Ultra in a new window on app.onmake.it and delivers to that window, with a random channel and once only, the report and sheets the user chose (up to 50 MB). From then on the data is processed under Editor Ultra's documents.
The location declared by ONMAKE is: application server on Microsoft Azure, Italy North region; account data in the Supabase project in the EU Frankfurt region; website and service email on Aruba in Italy.
6. Recipients and access
Authorised ONMAKE staff bound by confidentiality and necessary hosting, database, email, payment, invoicing and support providers have access to data: Microsoft Azure and Supabase support infrastructure and authentication; Aruba supports the website and email; Openapi S.p.A. supports invoice transmission; the Italian Revenue Agency receives tax flows. Stripe acts in the roles relevant to each activity, including independently for its own legal obligations and payment security.
The content-delivery network operator jsDelivr (cdn.jsdelivr.net) receives technical connection data when the print or report window of some modules is opened (section 5). Authorities and advisers bound by confidentiality may receive data only where necessary and with applicable safeguards.
7. International transfers
European server locations do not automatically exclude access or processing outside the EEA by provider groups. ONMAKE permits a transfer only on a GDPR Chapter V basis: an applicable adequacy decision verified for the recipient, or appropriate safeguards such as relevant standard contractual clauses, transfer assessment and supplementary measures where necessary. General acceptance of terms is not used as derogation consent for routine transfers.
Customers and individuals may request recipient identities, countries, applicable safeguards and copies of relevant information from info@onmake.it, with only unnecessary confidential details redacted. A new transfer of entrusted content must also comply with the DPA and customer instructions. The Italy/EU commercial scope does not remove these European obligations.
8. Retention
Project data in the browser persists until the user clears it, the browser removes it or an app function intervenes; remote deletion of copies on unreachable devices is not promised. Cookies and lifetimes are described in document 04.
Invoices and tax records are kept for ten years or any longer legally required period; deleting the account does not delete them. Shared-account data remains while the account is needed for other requested services; ending xTdC alone does not delete it. Use and security logs and support data are kept for the time needed for the purposes described; contract data and strictly necessary evidence are kept for the relationship and, to the extent needed for obligations and defence, for the applicable limitation period.
9. Security, automation and AI
ONMAKE adopts measures proportionate to risk, including account authentication, permission and subscription checks, channel protection, updates and incident handling. No certifications or absolute absence of vulnerabilities are claimed.
xTdC contains no AI features and sends no calculation data to AI providers. Calculations follow the software's procedures; internal use of AI tools by ONMAKE staff is distinct and does not involve sending customer content. Automatic controls on permissions, payment and security may refuse or limit access; they are not commercial profiling. Users may request human review of a block at info@onmake.it.
10. Rights, required information and changes
Where applicable, individuals may request access, rectification, erasure, restriction and portability, object to legitimate-interest processing and withdraw consents actually given without affecting earlier lawfulness. ONMAKE responds without undue delay and normally within one month, extendable only in the circumstances and with the notice required by the GDPR. Requests are normally free; exceptions must be justified under law.
For data in documents processed on behalf of a customer, ONMAKE forwards the request to the competent party and assists. GDPR portability concerns the data and conditions in article 20 and does not replace broader contractual document return. Individuals may complain to the Italian Garante or the authority in their habitual residence, workplace or place of the alleged infringement, and seek judicial remedies.
Email and information necessary for performance or tax obligations are required for the corresponding service; optional profile information and promotional consent are not. Refusing unnecessary information does not prevent the basic service. Material notice changes are communicated appropriately before new processing; an update cannot legitimise incompatible processing or replace required consent.