Privacy Policy

1.1The data controller is Antonio Sasso, an Italian self-employed professional (libero professionista), VAT number IT04607290717, Via Giuseppe di Vittorio 171/B, 71043 Manfredonia (FG), Italia (the "Operator", "we", "us"), which operates the Manuroute platform (the "Platform").

1.2Contact for any privacy question or request: hello@manuroute.com.

1.3Customers and producers. When an order is assigned, the producer receives the customer data needed to produce and ship it (name, shipping address, phone number where the carrier requires it, and the file). For this data the producer acts as an independent data controller: it decides how to pack and ship the parcel and holds its own contract with the carrier. The producer is bound by the producer terms to use the data only to fulfil that order, to keep it confidential, not to reuse it for any other purpose (including marketing or contacting the customer outside the job chat), and to delete it, together with the file, 30 days after the order is completed. We remain the controller for all data processed on the Platform itself.

2.1Account data. Name, email address, phone number (producers, for verification), password or login through a third-party provider (for example Google or GitHub), language, country, role (customer, producer or both), your confirmation that you are 18 or over, and your marketing email preference (opt-in status and the date of the double opt-in confirmation).

2.2Producer verification (KYC/KYB). Producers verify their identity and, at higher trust levels, their business through Stripe Connect. Identity documents and bank details are collected and processed by Stripe; we receive the verification status and the information Stripe makes available to platforms (such as name, address, payout account details). We also collect machine data, machine verification photos (including serial number and test-print photos), materials and the countries producers ship to.

2.3DAC7 tax data. For producers, as required by Council Directive (EU) 2021/514 ("DAC7") and the Italian implementing rules: name, address of residence, tax identification number or VAT number, date of birth for individuals, payout account identifier, and the total consideration paid and number of transactions per reporting period.

2.4Order data. Uploaded print files and the data extracted from them (printer model, nozzle, filaments, weight, time, plate previews), declared use of the part, acceptance criteria, prices, fees, payment status, order history and events.

2.5Payment data. Payments are processed by Stripe. We do not store full card numbers; we receive payment identifiers and status.

2.6Photos. Photos uploaded by producers (print plate, part, part on a scale, parcel) and by customers (in case of dispute).

2.7Shipping data. Customer shipping address, the producer's sender address where it appears on the parcel, carrier and tracking number.

2.8Communications. Messages in the job chat, dispute statements and evidence, support requests, reviews.

2.9Technical and log data. IP address, device and browser information, login events, file download logs, security and audit logs, error reports. To keep automated abuse away from the sign-in link, the waitlist and the quote without an account, those forms use Cloudflare Turnstile: it checks signals from your browser and its connection (such as the IP address, browser characteristics and how the page is used) to tell people from bots, without tracking cookies, and returns a one-time token that our server verifies with Cloudflare. Rate limits store only salted hashes of IP and email addresses, and counts of refused requests, never the addresses themselves.

2.9.1Files we cannot read. When an upload is refused (for example an STL or a file from a slicer we do not read yet), we keep only its type, the slicer named in its first lines, its size, the day and the country your connection comes from, and your answer if you choose to say what you wanted to print. The file itself is deleted at once, or never leaves your browser. These records are not linked to your account.

2.10Analytics data. Product usage events, only if you consent (section 8).

2.11Waitlist data. Email address, whether you joined as a customer or a producer, language and country if provided, and the date you confirmed the address. Joining the waitlist is confirmed by double opt-in: we email a confirmation link and write to you about the launch only after you confirm.

2.12Feedback and help requests. What you write in the help and feedback panel or answer to a short question when you stop at a step (for example a quote you do not order), the page it was sent from, the language, window size and browser, a screenshot if you add one, and, if you are not signed in, the email address you leave so we can answer you. A help request without an account needs that address.

2.13Catalog accounts and their buyers. When a customer with a catalog (a merchant) orders for one of its own buyers, we process the buyer's name, shipping address and phone number, given by the merchant, to make and ship that order, and keep them with the order. The merchant is the one who informs its buyer of this; we never contact the buyer. For the merchant itself we also keep the trade name, the optional company name and VAT number, its catalog items, its API keys (stored as hashes), its webhook endpoint and the log of the events sent to it, and the saved card's identifiers from Stripe. The JSON download of the account data (section 7.1) includes the catalog profile, the items, the keys (without their hash) and the orders.

Marketing emails. We send marketing emails only to people who have given a separate, explicit opt-in for them, distinct from the account registration and from transactional emails. Every opt-in is confirmed by double opt-in: you receive a confirmation email and are added to the marketing list only after clicking the link in it. This applies to everyone, in every country. Every marketing email contains an unsubscribe link that works with one click; unsubscribing stops marketing emails but not the transactional emails needed to run your orders and your account.

Automated processing. Matching an order to a producer, trust levels, order limits and the reliability score are calculated automatically from the criteria described in the Terms.

4.1Other users. The assigned producer receives the file and the data needed to produce and ship the order. The customer sees the producer's trust level, and may see the producer's sender details on the parcel. Contact happens only through the job chat.

4.2Processors. We use the following providers, who process data on our behalf under data processing agreements:

4.3Login providers. If you sign in with Google or GitHub, that provider shares basic profile data with us under its own privacy policy.

4.4Authorities. The Agenzia delle Entrate (DAC7 reporting and tax), and other authorities or courts where the law requires it.

4.5Advisers. Our accountant and lawyer, bound by professional confidentiality, where needed.

4.6We do not sell personal data and we do not use uploaded files for any purpose other than the order.

4.7A merchant's buyers. For an order a merchant places for its buyer, the assigned producer and the carrier receive the buyer's name, address and phone number to produce and ship it, as for any order (4.1); the merchant sees them with its orders. The merchant's webhook endpoint receives the status and tracking of its orders, never the buyer's address.

5.1Some processors are established in, or may access data from, countries outside the European Economic Area, in particular the United States. Where this happens, transfers rely on an adequacy decision (such as the EU-US Data Privacy Framework, for providers certified under it) or on the European Commission's Standard Contractual Clauses, as set out in each provider's data processing agreement.

5.2Orders may also involve producers located outside the EEA (for example in the United Kingdom or the United States). Such a producer receives only the shipping data needed to fulfil the order (name, shipping address, phone number where the carrier requires it, and the file), and nothing else about the customer. The transfer relies on the European Commission's Standard Contractual Clauses, which are incorporated in the producer terms that every producer accepts, together with the confidentiality, no-reuse and 30-day deletion obligations described in section 1.3. For producers in the United Kingdom, the transfer may also rely on the Commission's adequacy decision for the UK.

5.3Hosting regions. Everything the Platform controls is hosted in the European Union: the database on Neon in an EU region, file storage on Cloudflare R2 with EU jurisdiction, product analytics on PostHog's EU cloud, and the web application's server functions on Vercel in an EU region. Transfers outside the EEA are therefore limited to the cases in sections 5.1 and 5.2, mainly support, security and account-level processing by providers established in the United States.

7.1Under the GDPR you have the right to:

• access your data and receive a copy;
• rectify inaccurate data;
• erase your data, unless we must keep it by law or to handle an open order or dispute;
• restrict processing in the cases set by the law;
• data portability: you can download your account data as a JSON file from your account settings;
• object to processing based on legitimate interest;
• withdraw consent at any time (for analytics, the waitlist and marketing emails), without affecting earlier processing. Emails you can stop carry a one-click unsubscribe link, and email programs that support it show their own unsubscribe button.

7.2You can close your account from your account settings. Open orders, disputes and payouts are completed or resolved first. You are signed out at once and can keep the account by signing in within 30 days; after that, the account data is deleted or anonymised, and data required by law is kept for the periods above.

7.3To exercise your rights, write to hello@manuroute.com. We reply within one month, extendable where the law allows. We may ask you to confirm your identity.

7.4You have the right to lodge a complaint with the Italian data protection authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or with the authority of your country of residence or work.

8.1Technical cookies. We use only the cookies and similar technologies that are strictly necessary for the Platform to work: login session, security, language preference and storing your consent choice. These do not require consent. When you upload a file for a quote without an account, a random key in a technical cookie (mr_guest, 7 days) links the file and its quote to your browser; we store only a hash of it. When you sign in to reserve or pay, the file moves to your account and the key no longer matters. A first-party cookie (mr_attr, 30 days) records where your first visit came from: the campaign parameters of the link (utm_source, utm_medium, utm_campaign), a referral code, the page you landed on, the host of the referring site and the day. It holds no identifier, is never shared, and is copied onto an order or reservation you make so we can count orders per channel in aggregate.

8.2PostHog analytics. With your consent we use PostHog to understand how the Platform is used and improve it. PostHog is not loaded until you accept it in the consent banner, and you can change your choice at any time from the cookie settings.

8.3We do not use advertising or profiling cookies.

9.1We protect data with measures including: encryption of files at rest; uploads only through signed URLs, with a 200 MB limit and server-side checks of the real file type; download links that expire after 24 hours; file access limited to the assigned producer while the order is accepted or in production; a log of every download; rate limiting; a bot check (Cloudflare Turnstile) on the public forms; a daily limit on emails; secrets kept out of the code; two-factor authentication for administrators; an immutable audit log; daily database backups.

9.2If a personal data breach occurs, we will notify the competent authority and affected users where the GDPR requires it.

The Platform is for adults only: you must be at least 18 years old to open an account, and you confirm this when you register. The Platform is not intended for minors and we do not knowingly collect their data. If we learn that an account holder is under 18, we close the account and delete its data, except what we must keep by law. If you believe a minor has given us personal data, write to hello@manuroute.com and we will remove it.

We may update this policy. We will inform registered users of material changes by email or on the Platform before they take effect.

Antonio Sasso, Via Giuseppe di Vittorio 171/B, 71043 Manfredonia (FG), Italia, hello@manuroute.com.