Privacy Policy
1. Introduction
This privacy policy serves as information pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 ("GDPR") and applies to personal data relating to you collected and processed by Manuel Zompetta, as identified below, in his capacity as operator of Prometrica's services, through the website www.prometrica.ai (the "Site").
2. Data Controller
- Data Controller: Manuel Zompetta
- Address: Via Amerigo Vespucci 41 - 00153 - Rome
- VAT Number: 17931621001
- Email: info@prometrica.ai
3. Data Collected
Personal data collected through the Site may include:
a) identification and professional data such as name, surname, and professional role;
b) contact data such as professional email address and telephone number;
c) data relating to your business activity such as business model, sector of activity, and other economic and commercial indicators;
d) information relating to access and use of the Site such as internet protocol (IP) address, browser type and device parameters used to connect to the Site, name of the internet service provider (ISP), date and time of visit, visitor's referral and exit web page, possibly the number of clicks and other information, also collected through cookies and other tracking tools;
e) data voluntarily provided in the context of using the services included in the subscription.
The data we collect is provided by you at the time of registration and when you navigate the Site. The provision of your personal data is optional but necessary for the pursuit of the purposes listed below; if you do not provide us with your personal data, we may not be able to pursue such purposes.
4. Purposes and Legal Basis of Processing
Personal data collected through the Site may be processed to:
a) allow you to register, subscribe, and use the services included in the subscription;
b) respond to your questions and fulfill your requests for information;
c) send you - also through automated communication systems - commercial communications of an informational or promotional nature, also aimed at direct sales, relating to products and services;
d) comply with legal or regulatory obligations to which we are subject;
e) ensure the security of the Site as well as the services offered through them, through the collection and automated analysis - also in anonymized and aggregated form - of log information in order to prevent fraudulent activities, block attempts to damage computer systems, protect users, and ascertain any liability in case of offenses;
f) analyze the use of our services to optimize their operation and for the training and refinement of our artificial intelligence models;
g) exercise or defend a right in court;
h) carry out activities preparatory to or connected with extraordinary operations such as mergers, acquisitions, and transfers of business units.
The processing of your personal data for the purposes referred to in letters (a) and (b) does not require your consent as it is necessary to follow up on your requests, pursuant to Article 6(1)(b) GDPR. The processing of your personal data for the purposes referred to in letter (c) requires your consent pursuant to Article 6(1)(a) GDPR. The processing of your personal data for the purpose referred to in letter (d) does not require your consent as it is necessary to comply with legal obligations to which we are subject, pursuant to Article 6(1)(c) GDPR. The processing of your personal data for the purposes referred to in letters (e), (f), (g), and (h) does not require your consent as it is necessary for the pursuit of our legitimate interests, pursuant to Article 6(1)(f) GDPR.
5. How Do We Process Your Personal Data?
We adopt and require our suppliers to adopt appropriate technical and organizational measures to ensure an adequate level of protection of your personal data against the risks of destruction, loss, or alteration (accidental or unlawful) of personal data as well as unauthorized communication or access to them. Anonymous data may be used for the purpose referred to in point f) above.
Our "Prometheus" and "Pro Sales Scan" services analyze the categories of personal and commercial data provided through proprietary algorithms. The logic applied aims to correlate such information with statistical models and industry benchmarks in order to: a) identify areas of criticality and potential commercial risks; b) highlight growth opportunities and process optimization; c) develop insights, strategies, and personalized recommendations. The Systems, however, do not perform individual profiling activities within the meaning of Article 4(4) GDPR.
The importance of such processing lies in the ability to provide high value-added output (consisting of reports, predictive analyses, and summary documents), which serves as a strategic support tool for commercial decisions.
You are not subject to any decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, within the meaning and for the purposes of Article 22 GDPR.
The output generated by our systems is purely consultative and supportive in nature. The final evaluation, interpretation of results, and consequent commercial decision are and remain under human control and intervention, which are decisive in the decision-making process.
6. Categories of Recipients to Whom Data May Be Communicated
The processing of personal data will be carried out by means of subjects expressly and specifically designated as authorized persons appropriately instructed; such subjects will process data in accordance with the instructions received from the Data Controller, according to operational profiles attributed to them in relation to the functions performed. Data may also be communicated and processed by third parties acting as independent data controllers or processors, belonging to the following categories:
- our employees or collaborators in any capacity;
- public or private entities, natural or legal persons, who carry out processing activities on our behalf or to whom we are required to communicate your personal data by virtue of legal or contractual obligations;
- suppliers of goods and services and consultants, such as IT service providers, including Generative Artificial Intelligence functionalities (Google Generative AI), lawyers, accountants, etc.
Where such third parties are designated as processors pursuant to Article 28 GDPR, their operations will be governed by an appropriate Data Processing Agreement. Processors will operate under the direct authority of the Controller and in compliance with documented instructions provided by the latter, with an express prohibition on processing data for different or additional purposes than those strictly necessary for the execution of the contractual services entrusted. Data will not be subject to disclosure and will not be sold.
We inform you that, in the event that some of the recipients to whom your personal data is communicated are established outside the European Economic Area, we will transfer your personal data, in the absence of adequacy decisions and where none of the derogations referred to in Article 49 GDPR apply, on the basis of the standard contractual clauses referred to in Article 46(2)(c) and (d) GDPR.
7. Duration of Processing and Storage
Your personal data will be stored for different periods of time depending on the purposes for which they were collected. Specifically:
- data collected to subscribe and proceed with the purchase of products offered through the Site will be stored for a period of time equal to the duration of the contractual relationships in place with you and for the subsequent 10 (ten) years from their termination or, in any case, for the limitation period provided from time to time by law for rights for whose ascertainment, exercise, or defense the processing is necessary;
- data collected to respond to your questions and fulfill your requests for information will be stored until your request has been fulfilled;
- data collected to offer you our services will be stored as long as your account remains active and in any case for a period of time not exceeding the achievement of the purposes for which the data is processed;
- data collected for marketing purposes will be stored for 2 years.
Data collected for the additional purposes indicated above will be stored for the time strictly necessary to pursue such purposes or for the time we are required to store them based on applicable legal provisions. At the end of the storage period, the collected data is deleted or anonymized.
8. Data Subject Rights
Pursuant to Articles 15 to 22 GDPR, you have the right to ask us to:
- be informed about the purposes and methods of processing your personal data;
- access your personal data and receive a copy;
- rectify incomplete, inaccurate, or outdated data;
- delete your personal data;
- limit the processing of your personal data, where applicable pursuant to GDPR;
- object to processing, in whole or in part, where applicable pursuant to GDPR;
- obtain the portability of your personal data, where applicable pursuant to GDPR.
In the event that consent is required for the processing of personal data, you may also revoke at any time the consent already given, without prejudice to the lawfulness of the processing based on the consent given before the revocation.
You can exercise the above rights and request any information on the processing of your personal data by contacting:
- Email: info@prometrica.ai
In addition, you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) (www.garanteprivacy.it), in the event that you believe that the rights you hold pursuant to GDPR have been violated.
9. Minors
Our services are intended for an adult audience. The collection of personal data relating to persons under the age of 18 is not authorized. In the event that such collection occurs involuntarily, we will proceed without delay to delete the acquired information.
10. Changes to This Privacy Policy
We may update this privacy policy from time to time to reflect changes to our services or applicable regulations. In such case, we will publish the updated version on this page, indicating the new effective date. The date of last update is indicated at the bottom of this document.