Code of conduct

This page sets out the rules Enrico Giubertoni applies to his engagements. They are the same rules contained in the contracts he signs, published here so that they can be read in advance and without a request.

No fee, commission or reimbursement is received from the providers of the platforms, agencies or tools mentioned in a project. Where a project requires a technology, the selection criterion is the client’s result, and the decision remains with the client.

Professional secrecy is a clause of the engagement contract, together with the duty of diligence and periodic updates. It is therefore a contractual obligation, with the same force as the rest of the contract.

• The client’s non-disclosure agreement is signed on the client’s own template, before the first meeting in which data or systems are examined.
• The obligation remains in force after the engagement ends.
• An external collaborator may take part in an engagement only with the client’s written authorisation.

Data that a company shares during an engagement is used for that engagement only. It is excluded from the training of models, from collections prepared for other clients and from public materials, and at the end of the project it is returned or deleted upon written request. Where the processing concerns personal data, Enrico Giubertoni signs the appointment as processor provided for in Article 28 of Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR).

An analysis engagement requires access to advertising tools, contact management systems and measurement platforms. Access is granted to named accounts, so that each one can be traced and revoked individually, and at the end of the project Enrico Giubertoni initiates the request for revocation.

The method and the protocols remain the property of Enrico Giubertoni. For the outputs produced for the project, namely analyses, blueprints, guidelines and reports, the client receives a perpetual, non-exclusive right of use for its own internal purposes, extended to the companies of its group. Sale to third parties and sub-licensing require a written agreement.

A client’s name may appear among the references, in line with the practice stated in the contracts. The client’s figures, documents and project details remain confidential and become public only with written authorisation. The content of this site describes methods, and where it describes a case it omits the data that would make the client identifiable.

An engagement that would require Enrico Giubertoni to work, in the same period and on the same market, for two companies in direct competition is declined, and the reason is given. If a conflict arises after a project has started, it is disclosed immediately and the client decides how to proceed.

Any complaint on these points may be sent to the email address published in the footer of the site, and receives a reply within five working days. Those who prefer to speak directly will find the WhatsApp channel in the same footer.