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General Privacy Notice to art. 13 EU Reg. 679/2016
Pursuant to Article 13 of EU Regulation 679/2016 and the legislation in force in Italy regarding the processing of personal data, we inform you of the following.

a) Data Controller and contact details
The Data Controller of the data collected, provided and/or obtained during navigation on this website is INDIGO AI S.r.l., Gae Aulenti 1 - Tower B, 20154, Milano (MI), Italy, e-mail: compliance@ndg.ai.

‍b) Personal data processed and purposes of the processingThe Company provides conversational artificial intelligence (chatbot) platforms to business clients. Such services are delivered in the capacity of data processor on behalf of its clients, who act as data controllers and determine the purposes and means of the processing of personal data relating to end users.Any personal data processed through the chatbot platforms is not collected or processed by the Company as data controller within the scope of this website, but is governed by specific contractual arrangements with clients (Data Processing Agreements) and by the privacy notices provided by such clients to data subjects. For further information regarding the processing of personal data carried out in connection with the conversational AI services, please refer to the relevant contractual documentation and to the privacy notices of the respective clients.
Only and exclusively the following data will be processed:
b1. technical cookies, in case of mere consultation of the website;
b2. email, in case of request for subscription to the newsletter;
b3. all data necessary for the identification of the subject and for payment, and voluntarily provided by the same, in case of purchase of products or activation of services, also in demo format (Demo);
b4. The website, moreover, subject to consent, also processes analytical and profiling cookies. Please refer to the specific Cookie Policy for more detailed information in this regard.

Technical cookies do not require user consent and are necessary for the functioning of the website. Analytical and profiling cookies, on the other hand, require consent, which can be withdrawn at any time through the cookie banner or browser settings.

It is recalled that cookies are small text files that the websites visited by the user send and store on their computer or mobile device, to then be retransmitted to the same websites at the next visit. Technical cookies, in particular, are those strictly necessary to ensure the operation of the website, remembering, for example, the actions and preferences of the user during language selection or the purchase of a product. – manage the purchase of resources, materials and products available on the website.

‍c) Legal basis of the processing
The legal basis of the processing of your data is:
– legal, as regards technical cookies;
– consent-based, as regards the data processed for sending the newsletter;
– contractual, in case of processing of data necessary for the purchase of a product or service.

The personal data collected during navigation within our website will be processed exclusively for the purpose of:
– allowing access and navigation of the website;
– allowing subscription to the newsletter;
– managing the purchase of resources, materials and products available on the website.

‍d) Purposes and legal bases of the processing
The purposes of the processing of the above-mentioned personal data and the respective legal bases are identified as follows:
- technical cookies are processed to allow access, use and navigation of the website (purpose) and the legal basis that legitimizes their processing is of a legal nature (legal basis);
- analytical and profiling cookies are processed to allow the improvement of the web platform used by Indigo.ai to offer its services and to study user behavior in order to improve the browsing experience (purpose); their processing is based on consent, freely expressed by the user at the first access to the website through the appropriate Cookie banner and can be modified at any time by the user through the appropriate procedure for changing preferences contained in the Cookie Policy; analytical cookies collect aggregated and anonymized data on user behavior in order to improve the platform and browsing experience;
- the email address for newsletter subscription is processed to allow subscription to the newsletter service managed by Indigo.ai (purpose) and the legal basis that legitimizes its processing is the user's consent expressed by activating the appropriate checkbox (consent-based legal basis); it is recalled that consent to receive the newsletter may be withdrawn at any time either by using the appropriate "opt-out" button at the bottom of each newsletter, or by contacting Indigo.ai at the above-mentioned contacts;
- the data necessary for the purchase of a product or service, also in "Demo" mode, are processed in order to allow the User to use a service or product of Indigo.ai (purpose) and, therefore, the legal basis that legitimizes the processing is of a contractual nature (contractual legal basis) for all information strictly necessary for the provision of the service, and of a consent nature (consent-based legal basis) for any additional personal information not strictly necessary and that the user has in any case made available to Indigo.ai. In the event that data processing based on consent is initiated, the right to withdraw consent at any time remains without prejudice, without however affecting the lawfulness of the processing based on consent given before the withdrawal. Personal data provided for the purchase of products or services, if additional to those strictly necessary, will be processed only with the user's consent, which may be withdrawn at any time without affecting the lawfulness of the processing based on strictly necessary data.

‍e) Legitimate interest of the Controller
The processing of your data may also take place for the legitimate interest of the Controller. In particular, it may take place for purposes related to company security, IT network security and the security of processed data, and to communications following the termination of the contract pursuant to art. 6(1)(f) GDPR.
In the event that data processing is carried out on the basis of the legitimate interest of the Controller, the processing will not be carried out before having adequately assessed the possible prevalence of interests or fundamental rights and freedoms of the data subject that require protection of personal data.
In any case, your right to object to processing based on legitimate interest remains unaffected. Data subjects may object at any time to processing based on legitimate interest, without prejudice to the lawfulness of processing carried out before the objection.
You may exercise this right by writing to: admin@ndg.ai.

‍f) Recipients of personal data
Your personal data will be communicated only to:
- all subjects authorized to processing by the Controller pursuant to art. 29 par. 4 GDPR by reason of their inclusion in the company staff and the existence of a subordination relationship;
- any subjects appointed by Indigo.ai as external processors pursuant to art. 28 GDPR and involved in a systematic way in the processing of data;
- subjects to whom the right of access to such data is recognized by virtue of general regulatory provisions in force or specific lawful provisions of a public authority.
The complete list of external processors is held by the company. In no case will such data be disclosed.

‍g) Transfer of data to third countries
Your personal data are not transferred to Third Countries, i.e. countries outside the European Economic Area (EEA).
Should access to your data by such countries be allowed, the strictest logistical and IT security measures would be adopted to prevent and avoid the risk of unauthorized access or use for purposes different from those indicated above.
If external providers located outside the EEA are used, the transfer will take place exclusively on the basis of Standard Contractual Clauses approved by the European Commission or other guarantees compliant with arts. 44 et seq. GDPR.

‍h) Data retention period
The data provided by you will be processed for the time strictly necessary to achieve the purposes indicated above and subsequently retained for the time strictly required by the legislation in force in relation to the individual categories of personal data.
In particular:
- technical cookies will be processed and retained for the duration of the browsing session only;
- analytical cookies will be retained in accordance with the duration provided by each provider, as indicated in the cookie policy;
- the email address for newsletter subscription will be processed only for the duration of the subscription and subsequently retained, for protection purposes, for 5 years;
- the data collected and processed for the purchase of a product or service or for a “Demo” will be processed for the duration of the contract and subsequently retained for 5 years.
The retention period may be extended in case of disputes by the User or Customer, both judicial and extrajudicial. In case of extrajudicial disputes, no personal data will be retained beyond the maximum limit of 10 years from the withdrawal of consent or termination of the contract/service. The retention period may be modified in accordance with specific legal or tax obligations, limiting retention to the data strictly necessary.

‍i) Rights of the data subject
As data subjects, you have the right to exercise all rights provided for by arts. 12 et seq. GDPR.
In particular, you may request information about your data, access to them and their rectification, erasure, restriction of processing or object to their processing. You also have the right to data portability.
To exercise these rights, you may send a request to the Controller: compliance@ndg.ai.

‍l) Right to withdraw consent
Your personal data have been collected in a pre-contractual and contractual context aimed at fulfilling obligations towards the data subject based on the existing relationship, as well as legal obligations. Therefore, as a rule, no further processing based on consent is envisaged and, consequently, there is generally no consent to be withdrawn.
However, where additional processing based on consent is carried out, you will have the right both to refuse consent and to withdraw it at any time.

‍m) Right to lodge a complaint
You may lodge a complaint with the Italian Data Protection Authority or with the competent judicial authorities.

‍n) Mandatory nature of the data
The processing of technical cookies is mandatory, as it is necessary for the functioning of the website. Processing based on consent is optional.
The provision of your data in the pre-contractual and contractual phase for the purchase of a product, service or Demo must be considered mandatory as it is necessary for the establishment and execution of the service. Failure to provide data will make it impossible to start or continue the service.

‍o) Automated decision-making processesThe Data Controller does not carry out any processing based on automated decision-making processes.‍‍