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DRAFT — SUBJECT TO LEGAL REVIEW

Privacy notice

Preliminary version pending legal review. Points marked “TO BE VERIFIED WITH COUNSEL” must not be published before that review.

Controller

[DA COMPLETARE: RAGIONE SOCIALE], [DA COMPLETARE: INDIRIZZO], VAT [DA COMPLETARE: P.IVA]. Contact: [DA COMPLETARE: EMAIL], PEC [DA COMPLETARE: PEC].

Data we process

  • Contact details: name, email, phone and WhatsApp number if provided.
  • Supply data from your bill or typed in: provider, usage, prices, address, POD/PDR codes.
  • For businesses and public bodies: name, VAT number, tax code.
  • Messages exchanged on WhatsApp or the website chat.
  • Technical browsing data and, with consent, statistics and marketing cookies.
  • Any IBAN or other bank details on the bill are not used for the comparison. TO BE VERIFIED WITH COUNSEL and the technical lead: whether and when they are masked before being sent to the reading system.

Automated systems

We use automated extraction to read bills. No decision is based solely on automated processing: a person checks every result. TO BE VERIFIED WITH COUNSEL (Art. 22 GDPR).

Recipients

Service providers acting as processors: hosting, storage, email, WhatsApp (Meta), text extraction, maps, analytics. Current list: [TO BE COMPLETED]. Energy or service providers only if you choose to activate an offer.

Transfers outside the EU

Where a provider processes data outside the EU, transfers rely on the safeguards in Chapter V GDPR. [TO BE COMPLETED per provider]. TO BE VERIFIED WITH COUNSEL.

Retention

Uploaded documents: [TO BE COMPLETED, proposed 90 days after the request closes]. Analysis results: [TO BE COMPLETED]. Marketing data: until consent is withdrawn.

Your rights

You can request access, rectification, erasure, restriction, portability and object to processing (Arts. 15-22 GDPR), and withdraw consent at any time. Write to [DA COMPLETARE: EMAIL]. You can complain to the Italian Data Protection Authority (www.garanteprivacy.it).