with headquarters in Via Selice Provinciale, 17/A, 40026 Imola BO Italy, Tax code 00287010375, VAT No. IT00498321207, Tel.: +39-0542-607111, Fax: +39-0542-642354, E-mail: - - (hereafter also referred to as "the COMPANY”).

The Data Protection Officer (DPO) for the COMPANY is Massimiliano Bovesi – PEC:

Chat Service Privacy Policy
The following policy on the processing of personal data (hereinafter also referred to as “Privacy Policy”) is provided by the Company in its capacity as Data Controller of personal data collected through the chat service available through specific widgets on its websites (hereinafter “Chatbox”, “Chat” or “Chat Service”) or which, through this service, are provided directly by users. The Company believes it is essential to protect users’ privacy and provides this Privacy Policy so that the user can make an informed choice when using the Chat.

In general, all personal data (hereinafter also referred to as “Personal Data” and/or “Data”) that the user provides to the Company through the Chat Service or that will be collected in the context of use of this service will be processed in accordance with the principles recognised by the applicable data protection regulation, such as the principles of transparency, fairness, lawfulness, data minimisation, purpose limitation and storage limitation, accuracy, integrity and confidentiality.

The Privacy Policy is divided into individual sections (hereinafter referred to collectively as “Sections” and/or individually as “Section”), each of which deals with a specific area, in order to allow a more immediate and easier reading and search of topics.

With reference to the processing of personal data related, more generally, to the use of the website and cookies, please refer to the specific Privacy Policy available at the following link:


The Data Controller is the Company as identified above in the header. If the Company has appointed the Data Protection Officer, the contact details will be available in the header.


The Data will be subject to processing by the Company, according to the limits set by the applicable legislation, for the following purposes:
  1. to allow the performance of operations strictly connected and instrumental to the management of the Chat Service, in particular, recording and manage your specific requests (Provision of the Service);
  2. to allow the fulfilment of obligations provided for by laws, regulations and EU standards, or instructions given by authorities empowered to do so by law and supervisory and control bodies, as well as to allow the execution of any accounting and fiscal obligations (Legal Obligations).
The Personal Data processed through Chatbox belong to the categories indicated below.

Contact data, Chatbox usage data and any special categories of Personal Data

During the use of the Chat Service, the company may collect information such as: Data subject’s name, country and location, contact e-mail, IP address, Chat Service usage data.

Additional Data may be collected during Chat communication and may consist of data that the user voluntarily chooses to provide to the Company when using this service.

The Chat Service by its nature has free text fields where you can provide the Company with information that may contain Personal Data. Since these are free fields, you may choose to provide us (even inadvertently) with special categories of Personal Data such as data revealing political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the identification in a univocal manner of an individual, data relating to health or sexual life or sexual orientation. The Company asks you not to disclose any of these types of Data. Since the indication of such information is, as mentioned above, totally optional, should you choose to do so, the Company has the right to choose not to proceed with the processing of the entered data belonging to the particular categories indicated above, or to process such information only with your explicit consent and in compliance with current legislation.

Personal data referring to other persons

As mentioned in the previous paragraph, since the Chat Service has free text fields where you can send any type of message, these may actually contain Personal Data relating to other data subjects. In all cases in which you decide to share such Data with the Company, you will be considered as autonomous data controller and, as such, you will have to take all legal obligations and responsibilities. Therefore, in this regard, the user grants the Company the widest indemnity with respect to any dispute, claim, request for compensation for damage caused by processing, etc. by persons whose Personal Data have been forwarded by you in violation of applicable data protection regulations. Since, in such a case, the Company would not collect this information directly from the data subjects (but, indirectly, from you), you guarantee that such specific processing may be based on the consent of such data subjects or on another appropriate legal basis that legitimises the processing of the concerned information.


The provision of Data that are preceded by an asterisk (*) in the Chatbox is considered necessary and indispensable by the Company in order to be able to provide the Service.

The provision of Personal Data, and the related processing for the purpose of providing the Service, is strictly functional to the Chat Service and therefore, to be able to manage and process the requests you spontaneously send. Consequently, failure to provide the Data requested for this purpose, or the ascertained incorrectness of those provided, may make it impossible for the Company to correctly process your request.

The provision of Personal Data, and the related processing for the purposes related to Legal Obligations, is necessary for the Company to comply with the relevant obligations. When you provide Personal Data to the Company, the latter must process them in accordance with applicable laws which may include the storage and disclosure to the competent authorities for compliance with tax, customs or other obligations.


Personal Data will be disclosed to Sacmi personnel in charge of handling requests who are authorised to process the personal data contained therein in order to achieve the purposes previously indicated and who have committed themselves to confidentiality or have, in any case, received an appropriate legal obligation of confidentiality.

Personal Data may also be brought to the attention of third parties appointed as Data Processors, as they process Data on behalf of Sacmi, as the company providing the Chat Service platform. Some of your Personal Data may also be shared with recipients located in countries outside the EU or the European Economic Area. In this regard, the Company points out that the processing of your Personal Data by these parties will be carried out in compliance with applicable legislation. Therefore, transfers will be carried out by means of adequate guarantees, such as adequacy decisions, standard contractual clauses approved by the European Commission, accompanied by the simultaneous implementation of additional measures of a legal, technical and organisational nature or other guarantees aimed at providing adequate protection of Personal Data in line with the relevant European provisions. For further information write to the Data Controller at

Personal Data may, where required, be communicated to the competent financial offices, or to other Public Administrations, in accordance with the provisions of the laws in force. Personal Data are not intended for publication or dissemination.


The Personal Data processed for the purpose of providing the Service will be kept by the Company for the time strictly functional to the performance of the requested Service. More specifically, the requests collected through Chat and the Data contained therein will be kept only for the time necessary to allow the Company to identify the correct closure of the request. At the end of this period, the Data that allow the identification, even indirect, of a natural person (such as name, surname, e-mail, IP address) will be made anonymous and kept, in the form of aggregate data, for statistical purposes.

The Personal Data processed for the purposes of Legal Obligations will be kept by the Company for the period provided for by specific legal obligations or applicable regulations.


As Data subjects, you have the right, exercisable at any time, to:
  • request access to your Personal Data (and/or a copy of such Personal Data), as well as further information on the processing in progress on them;
  • request the rectification or updating of your Personal Data processed by the Company, if they are incomplete or not updated;
  • request the deletion of your Personal Data from the Company’s databases, where you consider the processing to be unnecessary or unlawful;
  • request the limitation of the processing of your Personal Data by the Company where you consider that your Personal Data are incorrect, not necessary or unlawfully processed, or where you have objected to their processing;
  • to exercise the right to the portability of the Data, i.e. to obtain in a structured, commonly used and machine-readable format a copy of the Personal Data concerning you provided to the Company, or to request its transmission to another Data Controller;
  • to oppose the processing of your Personal Data, using a legal basis relating to your particular situation, which you believe should prevent the Company from processing your Personal Data;
You may exercise the above rights by writing to the email address or to one of the different addresses indicated in the heading of this Privacy Policy.

The Company also informs you that you always have the right to lodge a complaint with the competent Control Authority (for example, that of the Country in which you have your habitual residence, in Italy the Data Protection Authority) if you believe that the processing of your Data is in breach of the applicable legislation on the protection of personal data.


This Privacy Policy version 1.0 is in force as of 19/10/2020. The Company reserves the right to modify or simply update its content, in part or in full, also due to changes in applicable regulations. The Company may inform you of such changes as soon as they are introduced and they will be binding as soon as they are published. The Company kindly invites you to visit this section on a regular basis in order to be aware of the most recent and updated version of the Privacy Policy so that you are always up to date on the Personal Data collected and the use made by the Company.


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