"Componi" Privacy Policy pursuant to Articles 13 et seq. of Reg. UE 2016/679 ("GDPR").
Version 1 — 2025 · Document code DP-INF-11
This policy is intended to explain the manner in which Fortop S.r.l. collects, processes and retains the personal data relating to Data Subjects in their capacity as users of the "Componi" service, accessible at www.componi.ai.
1. Data controller
The data controller is Fortop S.r.l., with registered office in Milano (MI), Corso Sempione n. 10, VAT and Tax Code 02001910500.
Fortop S.r.l. may be contacted: • by writing an e-mail to info@fortop.it; • by ordinary mail, at the registered office address indicated above.
2. Data Protection Officer (DPO)
Fortop S.r.l. has appointed a Data Protection Officer ("DPO"). This function may be contacted at dpo@fortop.it.
3. Categories of data processed
In pursuit of the purposes indicated, Fortop S.r.l. will process the following categories of personal data:
• contact data: first name, last name, email address (*); • account data: access credentials (username, password) (*); • user-generated content: text inputs, preferences, feedback and any other content that the Data Subject provides through the service; • navigation data: IP address, browser type, operating system, pages visited, time of access (*); • usage data: information on how the Data Subject interacts with the service, including the features used and the preferences expressed.
4. Sources of the data processed
The main source of personal data is the Data Subject.
5. Consequences of failure to provide the data
The provision of the personal data marked with the symbol (*) is mandatory: in their absence, it is impossible for Fortop S.r.l. to carry out the related processing activities, as provided for by the purposes listed below.
The provision of all other personal data is optional: in its absence, Fortop S.r.l. will not be able to carry out all or part of the intended processing.
6. Purposes, legal bases and retention period
Purpose
Legal bases
Retention period
(1) Ensure the correct technical functioning of the Website for the provision of the Componi service and the generation of the requested output
art. 6 (1) (b), for the fulfilment of needs related to the contract
No longer than the duration of the contract between Fortop S.r.l. and the Data Subject, save for any obligations or needs that justify extended retention.
(2) Communicate with the Data Subject in response to support requests
art. 6 (1) (b), for the fulfilment of needs related to the contract
(3) Maintain the security of the service and prevent unlawful acts, fraud and/or violations
art. 6 (1) (c), for the fulfilment of a legal obligation to which Fortop S.r.l. is subject
7. Categories of persons who may process the data
Within the limits of the obligations, tasks and purposes indicated above, the personal data will be processed exclusively by staff (employees and/or external collaborators) of Fortop S.r.l., as well as by third parties appointed as Processors pursuant to art. 28 GDPR.
The list of Processors may be requested from Fortop S.r.l. by writing to the contacts indicated.
8. Scope of communication and dissemination of the data
The personal data may be disseminated exclusively upon the express consent given by the Data Subject.
Fortop S.r.l. may also communicate the personal data to third parties (independent controllers) even without the consent of the data subject, for the sole purpose of complying with legal obligations, including:
• public and private bodies, including following inspections or audits (for example the Tax Administration, Social Security Institutions); • parties who may access the data by virtue of a legal provision (for example Tax Police Authorities, Judicial Authorities).
9. International transfers
In relation to the technological tools used by Fortop S.r.l. and/or its Processors, the personal data may be transferred outside the European Economic Area ("EEA"): in such cases Fortop S.r.l. guarantees that the transfer will take place exclusively to Countries (i) deemed adequate by the European Commission, (ii) that have entered into Standard Contractual Clauses or (iii) that have entered into other mechanisms of suitability for transfer outside the EEA.
It is always possible to contact Fortop S.r.l. at the contacts indicated for more information on the transfer of your personal data outside the EEA.
10. Rights of the Data Subject
At any stage of the processing the Data Subject may exercise the rights provided for by the GDPR, and in particular the right to:
• access their own personal data, as well as to obtain their rectification or erasure; • obtain the restriction of the processing concerning them; • object to the processing, where Fortop S.r.l. exercises a legitimate interest of its own; • obtain the portability of the data, where provided for; • withdraw consent, where provided for: withdrawal does not affect the lawfulness of processing already carried out on the basis of the consent previously given; • lodge a complaint with the supervisory authority (in Italy, the Data Protection Authority — Garante, www.gpdp.it).
The exercise of the rights referred to above may take place by sending a request to the e-mail address indicated above.