In compliance with the provisions of EU Regulation 2016/679 (European Regulation for the protection of personal data), we provide you with the necessary information regarding the processing of personal data provided. This is information provided pursuant to art. 13 of EU Reg. 2016/679 679 (European Regulation for the protection of personal data).

PREMISE
The objective is the creation of a corporate virtual assistant, accessible to the public exclusively through the official iGuzzini website.
The chatbot is designed to support users in navigating the site and searching for information, through interaction in written natural language.
The system provides answers relating to:

• the descriptive and technical-lighting characteristics of iGuzzini products;
• the projects carried out by the company;
• suggestions on the most suitable products for specific application contexts;
• general information about the company.

The chatbot does not provide commercial information relating to product prices, as such data is not available within the website and does not require the insertion of personal data. 

TYPE OF TREATABLE DATA

Personal data that can be processed: “personal data”: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is considered to be one who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or one or more elements characteristic of his physical, physiological, genetic, psychological, economic, cultural or social identity; (C26, C27, C30). 
Your data will be processed according to principles of correctness, lawfulness, transparency, in compliance with the purposes and methods indicated below, collecting them to the extent necessary and exact for the processing.
The following data may be processed during the use of the chatbot:

• Conversational data: textual inputs (questions, requests) and generated responses;
• Technical metadata relating to the interaction (e.g. timestamp, session status).

Users are invited not to provide personal data in conversations, as the service does not require or intentionally process it.

DATA CONTROLLER, pursuant to art. 4 of EU Reg. 2016/679, is Iguzzini Illuminazione SPA with registered office in Via Mariano Guzzini n. 37, 62019 Recanati (MC), Tel. 071-75881, privacy@iguzzini.com in the person of the legal representative pro-tempore.

 

PURPOSE OF THE PROCESSING

1.  User assistance: the data is processed to provide personalized support to the user through the company chatbot, accessible exclusively upon registration on the iGuzzini website. The service allows users to obtain information on company products, projects and services through written interaction in natural language. 
   • LEGAL BASIS. The processing of data for access and provision of the service is based on the execution of the contract or pre-contractual measures (art. 6, paragraph 1, letter b) GDPR), in addition to legitimate interest (art. 6, paragraph 1, letter f) GDPR). 
   • STORAGE PERIOD. For the purpose of user assistance, conversation data is stored exclusively for the time strictly necessary to provide the service. In particular, conversations are kept in the active system for a maximum of 48 hours, in order to allow the user to continue or resume the interaction without loss of context. 
   • After this period of inactivity, the system automatically performs a checkpoint cleaning: the user loses the previous session and can only start a new conversation. The data deleted from the active system is no longer accessible to the chatbot and is no longer used for assistance purposes. 
   • NATURE OF PROVISION Optional but necessary to use the service: The provision of data is necessary to access the chatbot service. 
   • The use of the chatbot remains optional: the user can freely choose whether or not to activate the conversation. The chatbot does not require the insertion of personal data, and the user is invited not to provide identifying, sensitive or irrelevant data for the information purposes of the service.
2. Improvement of the service, through technical analysis of conversations; 
   • LEGAL BASIS Legitimate interest of the Data Controller (art. 6, paragraph 1, letter f) GDPR)
   • STORAGE PERIOD. To improve the service, conversation data is kept in the active system for a maximum period of 48 hours, after which an automatic procedure for cleaning inactive checkpoints is activated. After removal from the active system, the data is no longer accessible to the user or the chatbot, but is stored in a confidential database accessible to the Data Controller for a maximum period of 24 months, exclusively for technical and statistical purposes connected to improving the service. At the end of this period, the data is permanently deleted or anonymized.
   • NATURE OF PROVISION. For the purpose of improving the service (technical analysis and optimization of chatbot responses), the provision of data is optional, but based on the legitimate interest of the Data Controller. The user can freely choose whether or not to use the chatbot; however, if used, the data provided (conversational inputs) may be temporarily analyzed for technical purposes of monitoring, improving performance and quality of service. This data is not used to identify the user or for marketing purposes, unless separate consent is given for the latter purpose.

METHODS OF PROCESSING The data is processed using IT tools, through automated processes controlled by iGuzzini. Conversations are managed through generative Artificial Intelligence systems provided by Google LLC, in particular through: 

• Google LLC's "gemini-2.5-flash" model for analyzing questions and generating answers;
• Google LLC's "gemini-embedding-001" model for the semantic representation of questions;
• OpenAI's "omni-moderation-latest" model to moderate potential offensive/dangerous language;

The suppliers ensure that:

• the transmitted data is not used to train the models;
• the information is processed only for the time necessary to process the request;

the data is deleted from Google systems as soon as possible.

 
RECIPIENTS OR CATEGORIES OF DATA RECIPIENTS The data can be processed exclusively by:

• Authorized personnel of iGuzzini illuminazione S.p.A.
• Technology service providers, in particular:
  • Google LLC (provider of LLM Gemini models);
  • Google Cloud Platform (API management and cloud infrastructure)
  • OpenAI (chat moderation model provider);

Other suppliers appointed as Data Processors pursuant to art. 28 GDPR, where applicable.

 
DATA TRANSFER TO A THIRD COUNTRY. The use of Gemini models involves a possible transfer of data outside the European Economic Area, in particular to the United States, where Google LLC is based. This transfer takes place in compliance with articles 44 and following of the GDPR, and is based on Standard Contractual Clauses (SCC) approved by the European Commission, as well as on the additional guarantees offered by Google regarding the protection of personal data.

 
RIGHTS OF THE INTERESTED PARTIES. You can assert your rights as expressed by EU Regulation 2016/679 articles 15 and following, by contacting the Data Controller at privacy@iguzzini.com.

 
You have the right, at any time, The user has the right to:

• access your personal data;
• request the rectification, cancellation or limitation of processing;
• oppose the processing;
• revoke the consent given at any time (without prejudice to the lawfulness of the processing based on the consent before the revocation);

Without prejudice to any other administrative and jurisdictional appeal, if you believe that the processing of data concerning you violates the provisions of EU Reg. 2016/679, pursuant to art. 15 letter f) of the aforementioned EU Reg. 2016/679, you have the right to lodge a complaint with the Guarantor for the protection of personal data (Supervisory Authority www.garanteprivacy.it).

 
INFORMATION CHANGES. The owner reserves the right, at its discretion, to change, modify, add or remove any part of this privacy policy, at any time. In order to facilitate the verification of any changes, the information will contain an indication of the date of updating the information.

Update date 18/07/2025

The Data Controller
iGuzzini Illuminazione Spa