PRIVACY & DISCRETION

Last updated: August 12, 2026

Discretion first

Most privacy policies are written for regulators. This one begins with the part that matters to you.

Discretion is not a compliance obligation for me — it is the reason artists and opera houses let me bring guests through doors that are otherwise closed. I have spent my career among people whose privacy is essential to their work, and the habit is permanent.

In practice:

• I do not publish or name my clients. Not on this site, not on social media, not in conversation. If you would like to be mentioned, that requires your explicit permission, in writing, each time.

• I never sell, rent or share your personal information for marketing. Not to anyone, for any price.

• I keep client information to the minimum I actually need, and I hold it only as long as it's useful to you.

• I don't discuss one client with another, including in general terms.

• When I make a booking or an introduction on your behalf, I share only what is strictly necessary — usually a name and a number of guests, and sometimes nothing more than "a guest of mine."

If you have a specific concern about how your information is handled, write to me directly and we will arrange things the way you prefer.

The formal part

Who is responsible for your data

BIAGGI Opera Privé, c/o Biaggi Arts Consulting, LLC, [FULL REGISTERED ADDRESS], is the controller of personal data collected through this website and in the course of providing services. Contact: daniel@biaggioperaprive.com.

What I collect, and why

For each kind of information, I've set out where it comes from, what I use it for, and the legal basis I rely on.

Your name, email address, telephone number and the message you send me
From the enquiry form on this site, or from writing to me directly. I use it to reply to you and to discuss a possible engagement. Legal basis: your request, and the steps leading toward a contract between us.

Your postal address and billing details
From you, once we decide to work together. I use it to invoice you and administer the engagement. Legal basis: performance of our contract.

Preferences for an evening — seating, timing, interests, and the names of your guests
From you, in conversation. I use it to arrange the engagement properly. Legal basis: performance of our contract.

Dietary requirements, accessibility needs, and any related health information
Only if you choose to tell me. I use it to make arrangements that work for you. Legal basis: your explicit consent. See the note below.

Your first name and email address, if you join the private list
From you, when you subscribe. I use it to send you my monthly letter, and nothing else. Legal basis: your consent, which you can withdraw at any time.

Technical information — your IP address, browser type, and the pages you view
Collected automatically when you visit this site. I use it to keep the site working and to understand in broad terms which pages people read. Legal basis: my legitimate interest in operating and improving the site.

Records of our engagements and correspondence
Created as we work together. I use them to serve you well over time, and to meet my accounting obligations. Legal basis: performance of our contract, and legal obligation.

A note on sensitive information. Dietary requirements and accessibility needs can reveal information about health or belief, which receives special protection in Europe and Switzerland. I ask for it only when it's needed to arrange something for you, I record only what is necessary, I pass on only what a restaurant or venue must know, and I delete it once the engagement is complete. You are never obliged to provide it, and you may withdraw it at any time.

Who else sees your information

Only where necessary, and only what is necessary:

• My website host and form provider (Framer), which stores site enquiries.

• My email and calendar provider, where correspondence and appointments live.

• My accountant and payment providers, for invoicing and record-keeping.

• Venues, restaurants and similar, where a reservation requires it — normally a name and a party size.

• Professional advisors, where I am obliged to seek advice or where the law requires disclosure.

I use no advertising networks, no data brokers, and no third-party marketing tools. I do not sell personal information, and I do not "share" it for cross-context behavioural advertising as those terms are used under California law.

International transfers

I operate between Switzerland, the European Union and the United States, and some of my service providers are based in the United States. Where personal data is transferred out of the EEA, Switzerland or the UK, I rely on appropriate safeguards — an adequacy decision where one applies, or the European Commission's Standard Contractual Clauses with the relevant Swiss and UK addenda. You may ask me for details of the safeguards in place.

How long I keep it

• Enquiries that don't lead to an engagement: up to 24 months, then deleted.

• Client records: for the duration of our relationship and then as required for accounting and legal purposes — normally ten years for financial records.

• Sensitive information about dietary or accessibility needs: deleted once the engagement is complete, unless you ask me to keep it for future occasions.

• Private list subscriptions: until you unsubscribe, plus a minimal record that you did so, to ensure I don't write to you again.

Security

I keep this proportionate and real rather than impressive-sounding:

• Client information is held in access-controlled, encrypted business accounts protected by multi-factor authentication, not on unsecured personal devices.

• Data is encrypted in transit to and from this website, and at rest with my providers.

• Devices are encrypted, password-protected and kept current with security updates.

• I do not store card or bank credentials. Payments are handled by regulated providers.

• Access is limited to me and, where strictly necessary, to a small number of professional advisors bound by confidentiality.

• Where a suitable option exists, I prefer providers offering European or Swiss data residency.

• Should a breach occur that presents a risk to you, I will notify you and the relevant authority without undue delay, and within 72 hours of becoming aware where the law requires it.

No system is perfectly secure. What I can commit to is that the amount of information I hold about you is small, deliberately.

Your rights

Depending on where you are, you may ask me to: give you a copy of the personal data I hold about you; correct it; delete it; restrict or object to how I use it; provide it in a portable format; or withdraw a consent you previously gave. You may also ask me not to send you the private list at any time, by replying to any letter or writing to me.

Write to daniel@biaggioperaprive.com and I will respond within one month. If I need longer because a request is complex, I'll tell you why and when to expect an answer.

If you are in the European Economic Area you may complain to your national data protection authority; in Switzerland, to the Federal Data Protection and Information Commissioner; in the UK, to the Information Commissioner's Office. I would much rather you came to me first.

California residents. I do not sell or share personal information, and I do not use or disclose sensitive personal information beyond the purposes described above. You may exercise your rights to know, delete, correct and opt out by writing to me at the address above, and I will not discriminate against you for doing so.

Cookies

This site uses only what it needs to function, plus basic aggregate analytics to tell me which pages people read. It carries no advertising or tracking cookies, and no cross-site tracking. Where consent is required for non-essential cookies, you'll be asked before any are set, and you can change your choice at any time. Your browser will also let you refuse cookies entirely; some parts of the site may then work less well.

Children

This site and these services are not directed at anyone under 18, and I do not knowingly collect information about children.

Changes

If I change this policy I'll update the date above. Material changes affecting how I use information about existing clients will be communicated directly.

Contact

daniel@biaggioperaprive.com · +1.917.941.0399