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Privacy Policy

This privacy policy (the “Privacy Policy“) is provided pursuant to Article 13 of Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR“) and applies to personal data collected through this website and its related subdomains.

This Privacy Policy describes how users’ personal data is collected, used, stored, and protected while browsing the Site, in accordance with the principles of lawfulness, fairness, transparency, and confidentiality set out in the applicable legislation.

Some personal data may be collected and processed through cookies and other tracking tools. For further information on the types of cookies used, their purposes, and how to manage preferences, please refer to the Cookie Policy set out below, which forms an integral part of this document.

Personal data will be processed solely for the purposes and in the manner described in this Privacy Policy.

1.Data Controller

The Data Controller — the party that determines the purposes and means of the processing of personal data, deciding how and why such data is collected and used — is Almawave Labs S.r.l., with registered office at Via di Casal Boccone 188-190, 00137 Rome, a company belonging to the Almaviva Group and subject to the management and coordination of Almaviva S.p.A. (the “Parent Company”).

As part of the centralized services provided to the Group companies (corporate and staff functions), the Parent Company processes personal data on their behalf, generally acting as Data Processor pursuant to Article 28 of the GDPR, on the basis of specific contractual agreements. Within the Group’s organizational structure, activities related to personal data protection are also managed, in part, centrally, in order to ensure consistency and efficiency in managing privacy compliance obligations.

Therefore, for matters relating to the processing of personal data, including the exercise of the rights referred to in point 7 of this document, the Data Controller can be contacted at the e-mail address servizioprivacy@almaviva.it.

2. Data Protection Officer

The DPO can be contacted at the following e-mail address: DPO.gruppoalmaviva@almaviva.it.

3. Categories of Data Subjects and Data Processed

The Data Controller processes the personal data of users browsing the website and any related pages linked to it.

The categories of data processed are as follows:

  • Browsing data (including, by way of example and not limitation, the type of device used, technical information necessary to establish the connection, IP address, domain name, URI, etc.). Such data may be processed through cookies or similar technologies. In this regard, users are invited to read the specific Cookie Policy on the Site;
  • Common data (including, by way of example and not limitation, personal and contact details such as first name, last name, e-mail address, and any further information contained in the request), where voluntarily provided by the data subject by sending communications to the contact addresses indicated on the Site.

4. Purposes, Legal Basis of Processing, and Retention Periods

Personal Data will be processed by the Data Controller, within the scope of its activities, for the following purposes:

4.1 Technical management of the site

As part of the normal operation of the Site, the IT systems and software procedures used to operate it acquire certain personal data whose transmission is implicit in the use of Internet communication protocols (e.g., IP addresses, device data, information on requests made, and technical browsing data).

Such data is processed to ensure the proper functioning, security, and usability of the Site, as well as to derive aggregated and anonymous statistics on its use and, where necessary, to establish liability in the event of unlawful activities.

Where the user has given consent to the use of cookies other than strictly necessary ones, information relating to how the Site is used may also be collected, such as, by way of example, pages visited, time spent on the Site, and interactions carried out during browsing.

The legal basis for this processing is the Data Controller’s legitimate interest pursuant to Article 6(1)(f) GDPR. For processing carried out through cookies and similar technologies requiring user consent, the legal basis is the data subject’s consent pursuant to Article 6(1)(a) GDPR.

Data is retained for the time strictly necessary to achieve the aforementioned purposes.

For further information on the categories of cookies used, their purposes, retention periods, and how to manage or change the preferences expressed, please refer to the Cookie Policy and the Cookie Preference Center accessible via the relevant links on the Site.

4.2 Responding to contact requests

If you contact us using the contact details provided on our website, we will process your personal data to respond to your requests and, where applicable, to contact you again to provide further information about our services. The legal basis for processing your data is the performance of pre-contractual measures taken at the request of the data subject (Article 6(1)(b) of the General Data Protection Regulation, “GDPR”). Contact data will be retained for the time strictly necessary to manage and respond to the request, as well as for any protection needs in the event of disputes.

5. Recipients of Personal Data

The Data Controller processes personal data by adopting appropriate technical and organizational measures to ensure its security and confidentiality. Access to the data is granted exclusively to authorized personnel bound by confidentiality obligations, and to parties who, on behalf of the Data Controller, provide services necessary to achieve the purposes set out in this notice.

Within the scope of the aforementioned purposes, personal data may be disclosed to the following recipients:

  • Other companies of the Almaviva Group, for the provision of specific content or for internal administrative purposes; depending on the case, such companies may act as data processors (pursuant to Article 28 GDPR) or as independent data controllers, in accordance with the agreements in place and the specific purposes of the processing.
  • Service providers acting as data processors (pursuant to Article 28 GDPR), such as external IT or marketing agencies, involved in activities relating to the Website (for example, technical maintenance, web hosting, etc.).
  • Public authorities and/or bodies, in fulfilment of the legal obligations to which the Data Controller is subject (for example, in the event of a fraud investigation).

6. Transfer of Data Outside the European Union

As a rule, your Personal Data is not transferred outside the European Economic Area (“EEA”). Should this occur (for example, where it becomes necessary to share your data with recipients located outside the EEA), we assure you that the processing of your Personal Data will comply with applicable legislation. Any such transfer will therefore only take place where adequate safeguards are in place, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission and, where necessary, additional safeguard measures.

7. Rights of Data Subjects

Data subjects have the right to exercise, at any time and unconditionally, the right of access, rectification, integration, objection, erasure, restriction, and portability of their Personal Data, as provided for in Article 15 et seq. of the GDPR, by sending a written request to the e-mail address servizioprivacy@almaviva.it.

Data subjects also have the right to lodge a complaint with the Data Protection Supervisory Authority, should they believe that the processing of their Personal Data has taken place in violation of applicable legal provisions.

8. Other Websites

The Site may contain links to third-party services, sites, applications, and/or platforms via links or other connection methods (e.g., APIs) made available through the Site itself. Access to and use of such sites, services, applications, or platforms remain outside the activities, controls, and/or security measures adopted by the Data Controller. Users are therefore invited to carefully read the terms of use and privacy notices provided by such third parties in order to understand how they process users’ personal data.

9. Updates to this Notice

This Notice may be subject to changes and revisions as a result of any changes in the processing of personal data carried out or updates to applicable legislation.

All personal data is processed in accordance with the Notice in force at the time it was collected. Any changes to this Notice will be published on this page and, where necessary, will be communicated to data subjects through appropriate means. Users are therefore invited to periodically consult this Notice in order to stay up to date on how their personal data is processed.

Last updated: 31/07/2026