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Tinexta InfoCert S.p.A. – Website Privacy Policy
Website Privacy Policy
This policy is provided pursuant to Article 13 of Regulation (EU) 2016/679 (the “Regulation” or “GDPR”)
to those who browse the website indicated below: www.tinextainfocert.infocert.it (the “Website”).
This policy describes how the Website is managed with regard to the processing of personal data
relating to visitors who browse it. It should also be noted that this policy applies exclusively to the
Website, to the exclusion of any other website to which the visitor may be redirected via links that may
be available on the Website.
1. WHO IS THE DATA CONTROLLER?
Tinexta InfoCert S.p.A. (“Infocert”), with its registered office in Rome (RM), Piazzale Flaminio No. 1/B,
00196, VAT No. 07945211006, in the person of its current legal representative, is the data controller for
your personal data (“InfoCert” or the “Data Controller”).
2. HAS INFOCERT APPOINTED A DATA PROTECTION OFFICER?
The Data Controller has appointed a Data Protection Officer (“DPO”). The DPO can be contacted by
email atdpo_tinexta@legalmail.it , or by writing to:
Data Protection Officer
Tinexta S.p.A.
Piazzale Flaminio, 1B
00196 - Rome (RM)
3. WHAT IS PERSONAL DATA? WHAT ARE THE PURPOSES OF PROCESSING YOUR DATA AND
THE RELEVANT LEGAL BASIS?
“Personal Data” means any information capable of identifying, directly or indirectly, a natural person; in
this case, you, the person browsing the Website (“Data”).
In particular, the Data Controller processes the following Data:
i. the IP address, domain name and URL of the device used;
ii. browsing data;
iii. browsing history;
Tinexta InfoCert SpA
Piazzale Flaminio 1/B, 00196 – Roma (RM) , Italy Company subject to the management and coordination of Tinexta SpA
T +39 06 836691 F +39 06 833669634 P.IVA 07945211006 REA n. 1064345
info@infocert.it Share Capital subscribed and paid-up € 21,099,232.00
infocert.it infocert.digital
as well as, solely in the case of requests you make via forms or pages available on the Website:
iv. your first name and surname;
v. your contact details (i.e. telephone number and email address);
vi. any other data you may have provided voluntarily and which is necessary to process your request.
When you visit the Website, InfoCert may therefore collect your Data both indirectly (e.g., by tracking
your device’s IP address and URL in order to monitor use of the Website) and directly (e.g., if you
voluntarily enter your Data into specially provided forms or create a profile on the Website); in the latter
case, the processing will be governed by specific privacy notices prepared and provided from time to
time by the Data Controller, to which you are referred for further details.
Your personal data, whether collected directly or indirectly, may be processed by the Data Controller for
the purposes of carrying out activities relating to the management and administration of the Website, as
well as to improve the visitor’s browsing experience and to carry out – where applicable, also jointly with
each of the social media platforms and/or each of the technology service providers listed here, including
but not limited to: Meta Platforms Ireland Ltd., LinkedIn Inc., Google Ads, Microsoft Advertising Bing,
Spotify – promotional and marketing activities relating to all products or services, whether our own or
those of other companies within the Tinexta Group and/or third parties, including through promotional
messages on the pages of the social media platform or technology service provider, or within advertising
spaces on other websites.
Processing carried out jointly with each social media platform or technology service provider – which is
only possible if you have given your specific consent to the installation of cookies for targeted advertising
and other tracking tools with similar functions (e.g. pixels, etc.) – will be limited to the processing
activities strictly necessary for selecting the criteria used to determine the scope of the campaign,
defining the relevant audience, matching users registered on the social media platform or the technology
service provider’s systems, selecting the criteria necessary for carrying out the activity, publishing the
promotional message and, where applicable, the production by the social media platform or the
technology service provider of statistical reports on the campaign’s performance.
For any further processing activities carried out by the social media platform or the technology service
provider in its capacity as an independent data controller, please refer to the privacy notice pursuant to
Article 13 or 14 of the GDPR, provided by the relevant social media platform or technology service
provider, to whom any requests to exercise your rights under the GDPR relating to the processing carried
out by them as independent data controllers may also be addressed. InfoCert is not responsible and
accepts no liability whatsoever for any processing operations carried out by the social media platform
or the technology service provider that go beyond the social media marketing activities described here.
In any event, we undertake to ensure that the information collected and used is appropriate to the Data
Controller’s purposes and that this does not constitute an invasion of your privacy.
Tinexta InfoCert SpA
Piazzale Flaminio 1/B, 00196 – Roma (RM) , Italy Company subject to the management and coordination of Tinexta SpA
T +39 06 836691 F +39 06 833669634 P.IVA 07945211006 REA n. 1064345
info@infocert.it Share Capital subscribed and paid-up € 21,099,232.00
infocert.it infocert.digital
Tinexta Infocert S.p.A. will process your personal data in connection with the management of its website
and to achieve the purposes pursued through it, based on one of the legal grounds provided for in Article
6 of the GDPR, and in particular:
1) to grant you access to the service (Website), ensure its normal operation, provide access to
your Personal Area, or respond to your requests, pursuant to paragraph 1, letter b);
2) to carry out processing activities that fall within its legitimate interests (e.g., to develop the
Website, ensure better usability and security) based on the provisions of paragraph 1, letter f);
Should it be necessary to process your data for different purposes and based on a different legal basis,
Tinexta Infocert Sp.A. may obtain your specific consent, in accordance with paragraph 1, subparagraph
a), or may do so pursuant to a legal obligation under paragraph 1, subparagraph c), and in any case
based on specific additional information supplementing this notice.
4. COOKIES
Cookies are packets of information sent by a web server (e.g. the website) to the user’s web browser,
which are automatically stored on the user’s computer and automatically sent back to the server each
time the website is accessed.
InfoCert uses cookies and other tracking tools (e.g., pixels) in order to provide contextualised information
to visitors to the Website and to obtain statistics on visits.
By default, almost all web browsers are set to allow or block cookies. Visitors can configure their device’s
browser to accept or block all cookies, or to display a warning whenever a cookie is proposed, so that
they can decide whether to accept it or not. Users may, however, change the default settings and disable
cookies (i.e. block them permanently) by selecting the highest level of protection.
For further information on the characteristics, types, use and methods for removing, deleting or disabling
cookies on the Website, please refer to the specific “Cookie Policy”.
5. ARTIFICIAL INTELLIGENCE SYSTEMS
In carrying out certain processing activities via the Website and in support of these activities, Infocert
utilises artificial intelligence tools, specifically for the following purposes:
- providing online assistance: “Trusty” is Infocert’s artificial intelligence-based virtual assistant, designed
to improve interaction with its customers by providing immediate support directly within Infocert’s main
products and on its website.
Tinexta InfoCert SpA
Piazzale Flaminio 1/B, 00196 – Roma (RM) , Italy Company subject to the management and coordination of Tinexta SpA
T +39 06 836691 F +39 06 833669634 P.IVA 07945211006 REA n. 1064345
info@infocert.it Share Capital subscribed and paid-up € 21,099,232.00
infocert.it infocert.digital
It should be noted that users always have the option to contact Infocert by sending an e to the contact
details provided on the website.
The processing of any personal data collected is intended to assist users in resolving issues relating to
the services, either through simulated conversations, in writing or verbally. Such processing will take
place in accordance with the legal basis set out in Article 6(1)(b) of the GDPR, as the processing is
necessary for the performance of a contract to which the data subject is a party or for the implementation
of pre-contractual and post-contractual measures.
The texts of the simulated conversations will in any case be recorded in anonymised form for statistical
purposes and to improve the service.
Should the analyses in question involve the processing of data, appropriate measures will be
implemented to ensure data security (such as, for example, pseudonymisation); in such cases, the
processing will be carried out on the basis of the Data Controller’s legitimate interest pursuant to Article
6(1)(f) of the GDPR.
All personal data processed will be automatically deleted five days after collection. Should your data be
processed for the purposes of feeding and improving algorithms, it will be anonymised beforehand.
- AI Search Bar: the website provides a search bar designed to direct users to the relevant InfoCert
products based on their search queries, answer information-related questions, and offer personalised
sales support based on the user’s browsing behaviour. The tool does not transmit personally identifiable
data directly to the AI system.
This processing will take place in accordance with the legal basis set out in Article 6(1)(b) of the GDPR,
as the processing is necessary for the performance of a contract to which the data subject is a party or
for the implementation of pre-contractual and post-contractual measures. For certain features, where
the use of tracking cookies is necessary to achieve the aforementioned purpose, you may give your
consent, on the basis of Article 6(a) of the GDPR, as further explained in the Website’s Cookie Policy;
- To develop, improve and monitor the website on the basis of its legitimate interest, as referred to in
Article 6(1)(f) of the GDPR;
- To monitor the security and proper functioning of its products and systems , on the basis of its legitimate
interest, as referred to in Article 6(1)(f) of the GDPR.
Where possible, Infocert will preferably use pseudonymised or anonymised data (including aggregated
data). Furthermore, given that the website does not require the processing of data falling within special
categories, the processing of such data using artificial intelligence systems is excluded: in any event,
users must not enter such data.
Infocert uses only artificial intelligence systems that comply with legal requirements (EU Regulation
1689/2024 and Law 132/2025) and the fundamental principles of accountability, non-exclusivity, non-
discrimination and transparency, without implementing automated decision-making processes within the
meaning of Article 22 of the GDPR.
Tinexta InfoCert SpA
Piazzale Flaminio 1/B, 00196 – Roma (RM) , Italy Company subject to the management and coordination of Tinexta SpA
T +39 06 836691 F +39 06 833669634 P.IVA 07945211006 REA n. 1064345
info@infocert.it Share Capital subscribed and paid-up € 21,099,232.00
infocert.it infocert.digital
You may at any time request further information from Infocert regarding the existence of a process
integrated with artificial intelligence systems and exercise your rights in relation to the protection of
personal data, within the limits set out by the applicable legislation.
Should Infocert use artificial intelligence tools for purposes other than those indicated, it shall, in its
capacity as Data Controller, provide specific information and, where necessary, obtain adequate and
specific consent for the processing of personal data.
6. WHERE DO WE TRANSFER YOUR DATA?
The server on which the Website is hosted is located within the European Union.
Your data may be transferred to external companies that provide Infocert with website maintenance and
development services and, more generally, IT services, which have been specifically appointed as data
processors; furthermore, where such disclosure is possible or required by law, your data may be
disclosed to other companies or public bodies located within the European Economic Area, which will
process it for their own purposes in their capacity as independent data controllers.
Your Data may also be transferred to third-party companies located outside the European Economic
Area that provide outsourced technology services to the Data Controller; should such a transfer be
necessary, we will ensure that the recipients of your Data have implemented appropriate security
measures to guarantee its protection in accordance with the Regulation.
If you have given your consent to the use of targeted advertising cookies (for details, please refer to the
“Cookie Policy”), certain Data will be processed by providers of social media platforms or technology
services, each acting as a joint controller with InfoCert. Further information regarding the relationship
between the joint controllers is available on request.
7. HOW LONG DO WE RETAIN YOUR DATA?
We process your data for the time strictly necessary to achieve the purposes set out in paragraph 3
above. The retention periods for data collected indirectly by the Data Controller via cookies are set out
in the relevant Cookie Policy.
Should you have provided us with your Data directly via the Website, it will be deleted once your request
has been dealt with or in accordance with the terms set out in the relevant privacy notices provided from
time to time by the Data Controller.
We reserve the right to retain so-called log data for longer periods, in order to be able to deal with any
criminal offences committed against the Website (e.g., hacking).
Tinexta InfoCert SpA
Piazzale Flaminio 1/B, 00196 – Roma (RM) , Italy Company subject to the management and coordination of Tinexta SpA
T +39 06 836691 F +39 06 833669634 P.IVA 07945211006 REA n. 1064345
info@infocert.it Share Capital subscribed and paid-up € 21,099,232.00
infocert.it infocert.digital
8. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?
As a data subject, you have the right to:
• access the Data and request a copy thereof;
• request the rectification or updating of the Data, where it is inaccurate or incomplete;
• to request, in certain circumstances, the erasure of the Data or the restriction of the processing
of the Data;
• request the portability of the Data;
• object to the processing of the Data (where applicable);
• withdraw consent, where the processing of the Data is based on the aforementioned legal basis.
Finally, you may lodge a complaint with the Data Protection Authority at any time.
To obtain further information regarding your rights, you may contact the Data Controller at the email
address richieste.privacy@legalmail.it, or the Data Protection Officer (DPO) at dpo_tinexta@legalmail.it.
9. FINAL PROVISIONS
InfoCert reserves the right to amend and/or update this privacy notice, including in light of legislative
and regulatory developments in the applicable data protection legislation, as well as in response to any
measures taken by the competent authorities.
[Last updated: July 2026]
Tinexta InfoCert SpA
Piazzale Flaminio 1/B, 00196 – Roma (RM) , Italy Company subject to the management and coordination of Tinexta SpA
T +39 06 836691 F +39 06 833669634 P.IVA 07945211006 REA n. 1064345
info@infocert.it Share Capital subscribed and paid-up € 21,099,232.00
infocert.it infocert.digital