Privacy Policy

Effective date: 27 October 2026

This Privacy Policy explains how personal data is collected and processed when you visit silenzionovel.com (the “Website”), sign up to receive Chapter One of Silenzio, or contact us. We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the applicable Slovenian data protection legislation.

1. Data controller

The controller responsible for the processing of your personal data is:

Palermo Agency, Tina Arsenovic s.p.
Kerenčičeva 5
2000 Maribor, Slovenia
VAT ID: SI59258454
Email: privacy@silenzionovel.com

For any question regarding this policy or the processing of your personal data, please contact us at the email address above.

2. Personal data we process

2.1 Newsletter and Chapter One sign-up. When you subscribe through the form on the Website, we process:

• your email address (required);
• your first name (optional);
• your subscription preferences, namely whether you wish to receive news about Silenzio, including The Road, and whether you wish to be notified when the book club opens;
• the date and time of your subscription and confirmation, and the IP address used at that time (as proof of consent);
• information on email delivery, opens and link clicks.

2.2 Correspondence. When you contact us by email, we process your email address, name and the content of your message.

3. Purposes and legal basis

• Sending Chapter One and confirming your subscription: on the basis of your consent (Article 6(1)(a) GDPR).
• Sending The Road and news about Silenzio: only if you have selected this option, on the basis of your consent (Article 6(1)(a) GDPR).
• Notifying you when the book club opens: only if you have selected this option, on the basis of your consent (Article 6(1)(a) GDPR).
• Measuring email delivery and engagement: on the basis of our legitimate interest in ensuring that our emails are delivered and relevant (Article 6(1)(f) GDPR).
• Keeping records of consent: to comply with our legal obligation to demonstrate consent (Article 6(1)(c) and Article 7(1) GDPR).
• Responding to enquiries: on the basis of our legitimate interest in replying to your message (Article 6(1)(f) GDPR).

You may withdraw your consent at any time by using the unsubscribe link included in every email or by contacting us. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

4. Recipients and processors

We do not sell personal data or share it with third parties for advertising purposes. Personal data is disclosed only to the following service providers, acting as processors on our behalf under a data processing agreement:

• Brevo (Sendinblue SAS, 106 boulevard Haussmann, 75008 Paris, France): email delivery and subscriber management. Data is stored on servers within the European Union.
• Domenca d.o.o. (Slovenia): website hosting.

We do not transfer personal data outside the European Economic Area.

5. Retention period

• Subscriber data is retained for as long as your subscription is active.
• Sign-ups that are not confirmed through the double opt-in email are deleted automatically.
• When you unsubscribe, your data is deleted, with the exception of your email address, which is retained on a suppression list solely to ensure that you are not contacted again.
• Correspondence is retained for as long as necessary to handle your enquiry.

6. Your rights

Under the GDPR, you have the right to:

• access your personal data (Article 15);
• request rectification of inaccurate data (Article 16);
• request erasure of your data (Article 17);
• request restriction of processing (Article 18);
• receive your data in a structured, commonly used format (Article 20);
• object to processing based on legitimate interest (Article 21);
• withdraw your consent at any time (Article 7(3)).

To exercise these rights, please contact us at privacy@silenzionovel.com. We will respond within one month of receiving your request.

You also have the right to lodge a complaint with the supervisory authority: the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec RS, Dunajska cesta 22, 1000 Ljubljana, www.ip-rs.si), or with the supervisory authority in your country of residence.

7. Cookies and local storage

The Website does not use analytics, advertising or tracking cookies. It uses only the following technically necessary storage:

• Local storage (The Road): the date on which you begin The Road is stored in your browser so that the correct places are displayed to you. This information remains on your device and is not transmitted to us.
• Password cookie (Behind the Olive-Green Door): a cookie set by WordPress after the access code is entered, so that the protected content remains accessible during your visit.

You can delete stored data at any time through your browser settings. Fonts used on the Website are hosted on our own server and are not loaded from third-party services.

8. External links

The Website contains links to third-party websites, such as Instagram and online booksellers. We are not responsible for the privacy practices of these websites. Please refer to their respective privacy policies.

9. Minors

The Website is intended for adults. We do not knowingly collect personal data from persons under the age of 16.

10. Changes to this policy

We may update this Privacy Policy from time to time. The current version, with its effective date, is always published on this page. Where changes are material, subscribers will be informed by email.