Privacy Policy

The Data Controller for personal data processing is: Emerge Italia di Manuele Fonte Via Andreas Hofer 59 39055 Laives (BZ), Italy VAT: IT02967140217 Email: info@emergeitalia.it Phone: +39 351 415 6549

We collect the following personal data through our forms and services: Identification data: - Full name - Email address - Phone number (optional in some forms) - Company name (optional in some forms) Browsing data: - IP address (for security and anti-spam purposes) - Browser and device technical data Voluntarily provided data: - Messages sent through contact forms - Transcripts of conversations with our AI assistant (EmerGen) - Project information (industry, budget, type) - Website URL (for accessibility verification)

Pursuant to Art. 50 of EU Regulation 2024/1689 (AI Act), we inform you that this website uses an artificial intelligence system. EmerGen - Virtual Assistant EmerGen is a conversational assistant based on large language models (LLM). When you interact with EmerGen: - You are informed that you are communicating with an AI system, not a person - The messages you send are processed by OpenAI LLC (USA) to generate responses - Conversations are stored to improve the service and manage your requests - At the end of the session, the transcript is sent to our team for commercial follow-up Nature of automated processing: - EmerGen does NOT make automated decisions with legal or significant effects on you (Art. 22 GDPR) - Responses are informational and commercial in nature - Any final decision (quotes, contracts, services) is always made by human personnel Data transfer to OpenAI: Conversation data is transferred to OpenAI LLC in the United States. The transfer is based on: - Standard Contractual Clauses (SCC) approved by the European Commission - Supplementary technical measures (encryption in transit and at rest) - OpenAI's Data Processing Addendum compliant with GDPR For more information: https://openai.com/policies/privacy-policy Your specific rights: - Be informed that you are interacting with an AI - Obtain information about the system's logic - Request deletion of transcripts - Opt for human interaction by contacting us directly

Personal data is processed for the following purposes: Service-related purposes: 1. Responding to contact requests and quote inquiries 2. Managing consultation bookings via calendar 3. Providing virtual assistant service (EmerGen) 4. Verifying eligibility for provincial grants 5. Performing website accessibility checks 6. Sending communications related to requested services 7. Preventing abuse, spam, and fraudulent activities 8. Fulfilling legal obligations Commercial and marketing purposes (with consent): 9. Sending newsletters, promotions, and commercial communications 10. Sending personalized offers about our services 11. Invitations to events, webinars, and promotional initiatives Profiling purposes (with consent): 12. Analyzing preferences and interests to personalize content and offers 13. Creating profiles based on site interactions and service usage 14. Remarketing advertising on third-party platforms

Personal data processing is based on: - Consent (Art. 6.1.a GDPR): for sending communications and collecting data through forms - Contract performance (Art. 6.1.b GDPR): to provide requested services and manage bookings - Legitimate interest (Art. 6.1.f GDPR): for site security, fraud prevention, and service improvement - Legal obligation (Art. 6.1.c GDPR): to fulfill tax and legal obligations For commercial, marketing, and profiling purposes, your explicit and specific consent is required (Art. 6.1.a and Art. 7 GDPR). Such consent is always optional and can be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Pursuant to Art. 13.2.e) of the GDPR, we inform you that: Mandatory data: Some data is necessary to provide the requested services. These are marked with an asterisk (*) in forms and typically include name, email, and message. Without this data, we cannot respond to your requests or provide the service. Optional data: Other data (phone, company, additional details) is optional and helps improve service quality. Not providing this data does not prevent you from using basic services. Consequences of non-provision: - Mandatory data: inability to process requests, book consultations, or use the virtual assistant - Optional data: no consequences, but we may not be able to provide personalized service - Marketing consent: no consequences - you will not receive promotional communications but can still use all our services

With your explicit consent, we may process your data for commercial and profiling purposes. What we mean by profiling: Under Art. 4(4) of the GDPR, profiling consists of automated analysis of your personal data to evaluate preferences, interests, and behaviors. This allows us to offer you more relevant content and offers. How we use this data: - We analyze pages visited and site interactions - We create user segments with similar interests - We personalize commercial communications - We display relevant ads on third-party platforms (remarketing) Your specific rights (Art. 21 and 22 GDPR): - Object at any time to processing for direct marketing - Not be subject to decisions based solely on automated processing that produce legal effects - Request human intervention, express your point of view, and contest the decision How to withdraw consent: - Click the "Unsubscribe" link in any email - Contact us at info@emergeitalia.it - Modify cookie preferences from the site footer Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To deliver our services and analyze website usage, we use the following providers: Google Analytics (Google LLC) Web traffic statistical analysis service Location: USA (DPF adequacy) Data collected: anonymized browsing data, pages visited, visit duration Privacy: https://policies.google.com/privacy Meta Platforms (Facebook/Instagram) Analytics and remarketing service Location: USA (DPF adequacy) Data collected: site interactions for advertising purposes Privacy: https://www.facebook.com/privacy/policy/ Brevo (Sendinblue SA) Transactional email service Location: France (EU) Privacy: https://www.brevo.com/legal/privacypolicy/ Google Calendar API (Google LLC) Booking management and video conferencing Location: USA (DPF adequacy) Privacy: https://policies.google.com/privacy OpenAI (OpenAI LLC) AI service for virtual assistant Location: USA Privacy: https://openai.com/privacy/ Data shared includes only conversation messages. Vercel Inc. Hosting and infrastructure Location: USA (DPF adequacy) Privacy: https://vercel.com/legal/privacy-policy

Some of our providers are based in the United States. Data transfer complies with GDPR through: - EU-US Data Privacy Framework (DPF) for certified providers - Standard Contractual Clauses (SCCs) approved by the European Commission - Supplementary technical measures (encryption, pseudonymization) You can request detailed information about the safeguards in place by contacting us at info@emergeitalia.it

Personal data is retained for the time necessary for the purposes for which it was collected: - Contact data, requests and communications: stored in our database until your explicit deletion request - Tax and accounting data: 10 years as required by law - Browsing and analytics data: according to the respective providers' policies - Cookie preferences: stored locally on your device You can request deletion of your data at any time by contacting us at info@emergeitalia.it

As a data subject, you have the right to: - Access: obtain confirmation of processing and a copy of your data - Rectification: correct inaccurate or incomplete data - Erasure: request deletion of data ("right to be forgotten") - Restriction: restrict processing in certain cases - Portability: receive data in a structured format - Objection: object to processing for legitimate reasons - Withdraw consent: withdraw consent at any time To exercise these rights, contact us at info@emergeitalia.it You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali - www.garanteprivacy.it).

This website uses: - Technical cookies: necessary for site operation - Analytics cookies: to understand how you use the site (with consent) - Marketing cookies: to show you relevant content (with consent) On first visit, you will be asked to express your preferences. You can change them at any time. For more information, please see our Cookie Policy.

We reserve the right to modify this policy at any time. Changes will be published on this page with the update date indicated. We encourage you to periodically review this page.

For any questions regarding the processing of your personal data, you can contact us: Email: info@emergeitalia.it Phone: +39 351 415 6549 Address: Via Andreas Hofer 59, 39055 Laives (BZ), Italy