Privacy Policy of

This Application collects some Personal Data of its Users.


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Data Controller

Asgenia S.r.l.
via dell'Oca 27 - 00186 Rome
VAT ID: 12457321003

Email address of the Data Controller: This email address is being protected from spambots. You need JavaScript enabled to view it.

Types of Collected Data

Among the Personal Data collected by this Application, independently or through third parties, there are: Tracking Tool; Usage Data; name; email.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the Data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, this Application may be unable to provide the Service. In cases where this Application specifically states that some Data is optional, Users are free to refrain from communicating such Data, without this affecting the availability of the Service or its operation.
Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.
The use of Cookies - or other tracking tools - by this Application or by the owners of third-party services used by this Application is for the purpose of providing the Service requested by the User, in addition to any other purposes described in this document.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application.

Methods and Location of Data Processing

Processing Methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data.
Processing is carried out using computers and/or IT-enabled tools, organizational methods, and with strictly related purposes. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.


The Data is processed at the Data Controller's operating offices and in any other places where the parties involved in the processing are located. For further information, please contact the Data Controller.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the processing location, the User can refer to the section on the details about the processing of Personal Data.

Retention Period

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period to comply with legal obligations or based on User consent.

Purposes of Processing Collected Data

User Data is collected to allow the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: Statistics, Contacting the User, and Displaying content from external platforms.

For detailed information on the purposes of processing and the Personal Data processed for each purpose, the User can refer to the "Details about the processing of Personal Data" section.

Details about the Processing of Personal Data

Personal Data is collected for the following purposes using the following services:

  • Contacting the User

  • Statistics

  • Displaying content from external platforms

Additional Information for Users

Legal Basis of Processing

The Data Controller processes Personal Data concerning the User if one of the following conditions exists:

  • The User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be permitted to process Personal Data without the User's consent or another legal basis specified below, until the User objects ("opt-out") to such processing. However, this is not applicable if the processing of Personal Data is regulated by European data protection law;
  • The processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures;
  • The processing is necessary to comply with a legal obligation to which the Data Controller is subject;
  • The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
  • The processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

It is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and, in particular, whether the processing is based on the law, provided for by a contract, or necessary to conclude a contract.

Further Information on Storage Time

Unless otherwise specified in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period to comply with legal obligations or based on User consent.


  • Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until such contract is fully performed.
  • Personal Data collected for the purposes of the Data Controller's legitimate interests will be retained as long as needed to fulfill such purposes. Users can find further information about the Data Controller's legitimate interests in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User's consent, the Data Controller may retain Personal Data longer until such consent is revoked. Additionally, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, at the expiration of this term, the right to access, delete, rectify, and the right to data portability cannot be exercised anymore.

User Rights

Users can exercise certain rights regarding the Data processed by the Data Controller.

In particular, within the limits set by law, the User has the right to:

  • withdraw consent at any time. The User can withdraw their consent to the processing of their Personal Data previously expressed.
  • object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent.
  • access their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and receive a copy of the processed Data.
  • verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
  • obtain the limitation of the processing. The User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
  • obtain the deletion or removal of their Personal Data. The User can request the deletion of their Data by the Data Controller.
  • receive their Data or have it transferred to another Data Controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to obtain its transfer without hindrance to another Data Controller.
  • file a complaint. The User can file a complaint with the competent data protection supervisory authority or take legal action.

Users have the right to obtain information about the legal basis for the transfer of Data abroad, including to any international organization regulated by international law or established by two or more countries, such as the UN, as well as about the security measures taken by the Data Controller to protect their Data.

Details about the right to object

When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing at any time, free of charge, and without providing any justification. If Users object to the processing for direct marketing purposes, their Personal Data will no longer be processed for such purposes. To find out if the Data Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise their rights, Users can make a request to the contact details of the Data Controller indicated in this document. The request can be made free of charge, and the Data Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectifications, deletions, or limitations to the processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller will inform the User about these recipients if requested.

Additional Information about Processing

Legal Defense

The User's Personal Data may be used by the Data Controller in court or in the preparatory stages leading to possible legal action for defense against misuse in the use of this Application or related services by the User.
The User acknowledges that the Data Controller may be required to disclose the Data upon request of public authorities.

Specific Information

Upon the User's request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific services or the collection and processing of Personal Data.

System Logs and Maintenance

For operation and maintenance needs, this Application and any third-party services used by it may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User's IP address.

Information not contained in this policy

Additional information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details available. Therefore, please check this page frequently, referring to the last modification date indicated at the bottom.

If the changes affect processing activities based on consent, the Data Controller will collect the User's consent again, if necessary.

Definitions and Legal References

Personal Data (or Data)

Any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

Information collected automatically through this Application (or third-party services integrated into this Application), including: the IP addresses or domain names of the computers used by the User connecting with this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details related to the itinerary followed within the Application, with particular reference to the sequence of pages visited, the parameters related to the operating system, and the User's IT environment.


The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Data Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural person or legal entity, public authority, service, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures related to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool through which the Personal Data of Users is collected and processed.


The service provided by this Application as defined in its relevant terms (if any) on this website/application.

European Union (EU)

Unless otherwise specified, any reference to the European Union in this document is intended to include all current member states of the European Union and the European Economic Area.


Cookies are Tracking Tools consisting of small pieces of data stored within the User's browser.

Tracking Tool

By Tracking Tool, any technology - e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that allows tracking Users, for example, by collecting or saving information on the User's device.

Legal references

Unless otherwise specified, this privacy notice exclusively concerns this Application.