{"id":65141,"date":"2026-10-24T11:26:57","date_gmt":"2026-10-24T09:26:57","guid":{"rendered":"https:\/\/www.i-com.it\/?page_id=65141"},"modified":"2026-10-24T22:42:32","modified_gmt":"2026-10-24T20:42:32","slug":"newsletter-privacy-information","status":"publish","type":"page","link":"https:\/\/www.i-com.it\/en\/newsletter-privacy-information\/","title":{"rendered":"Newsletter privacy information"},"content":{"rendered":"

Last updated: October 24, 2026<\/strong>
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\nThis privacy notice is provided in accordance with Article 13 of EU Regulation 2016\/679 (GDPR) and concerns the personal data processed as part of the newsletter service, in the manner described below.
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\nDATA CONTROLLER<\/strong><\/p>\n

The Data Controller for the personal data collected is I-Com, Institute for Competitiveness, located at Piazza dei Santi Apostoli 66, 00187 Rome (RM), Italy; tel.: (+39) 064740746; e-mail: info@i-com.it<\/a>.<\/p>\n

The personal data provided may be shared with duly appointed recipients who will process the data as data processors and\/or persons authorized to process data, for the purpose of fulfilling contractual obligations or related objectives.<\/p>\n

A complete list of the data processors and persons authorized to process personal data may be obtained by sending a request to the e-mail address: info@i-com.it<\/a>.
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\nDATA TRANSFER<\/strong><\/p>\n

In the event that personal data is transferred outside the European Union\u2014for technical or operational reasons and to ensure high service continuity\u2014the Data Controller shall ensure that such transfer is based on an adequacy decision by the European Commission. This is to guarantee that the level of protection afforded to individuals under current legislation, and specifically under EU Regulation 2016\/679, is not compromised.
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\nDATA COLLECTED<\/strong><\/p>\n

The personal data processed is either provided directly by the data subject or collected automatically. Data provided directly by the data subject refers to any personal data supplied to the Data Controller by the data subject, through any means.<\/p>\n

Technical data\u2014such as IP addresses, user-agent strings, and information contained in system logs\u2014may also be processed. Such processing is limited to what is necessary for technical requirements, security, the prevention of abuse, the identification of automated traffic, and the proper functioning of the service.<\/p>\n

When newsletters are sent, the platform used\u2014subject to the data subject’s consent\u2014allows for the detection of whether a message has been opened (via a tracking pixel\u2014a tiny, invisible image) and whether any links within the newsletter have been clicked, with such actions being linked to the specific recipient.<\/p>\n

If tracking is disabled, opens and clicks are still recorded but are not linked to the individual recipient; this data is used solely to generate aggregate statistics regarding the quality of the mailing list and the mailings themselves.
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\nPURPOSE OF PROCESSING<\/strong><\/p>\n

The legal basis for the processing of personal data is the fulfillment of contractual or pre-contractual obligations, or compliance with legal obligations to which the Data Controller is subject. Consequently, any refusal to allow such processing, or a failure to provide\u2014or the provision of inaccurate or incomplete\u2014data, may result in the inability to properly deliver the service or the inability of the Data Controller to respond to requests for information submitted by the data subject.<\/p>\n

Providing data for the purpose of receiving newsletters\u2014whether for promotional, commercial, informational, or research-related purposes\u2014is optional. Refusing to provide consent for this processing means that you will not be kept informed about commercial initiatives and\/or promotional campaigns, nor will you receive offers or other promotional material. Individual tracking of opens and clicks allows for the measurement of interest in communications, as well as the optimization of their content and frequency\u2014including by reducing or ceasing mailings to recipients who show no interest over an extended period. The legal basis for this processing is the data subject’s consent, pursuant to Article 122 of the Personal Data Protection Code and Article 6, paragraph 1, letter a) of EU Regulation 2016\/679. Providing consent is optional and distinct from consenting to receive the newsletter; data subjects may choose to grant it at the time of subscription by selecting the “Allow personal tracking” option (which is not pre-selected). Refusing or withdrawing consent does not prevent a user from receiving the newsletter.
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\nWITHDRAWAL OF CONSENT<\/strong><\/p>\n

Data subjects may withdraw their consent to receive promotional and commercial communications at any time by sending a request to the email address info@i-com.it<\/a> or by clicking the unsubscribe link provided in the footer of every promotional or commercial email received.<\/p>\n

Furthermore, data subjects may withdraw their consent for individual tracking at any time\u2014without unsubscribing\u2014by using the “Manage preferences and tracking” link found in the footer of every newsletter. In such cases, they will continue to receive communications, subject only to the anonymous, aggregated statistical analysis described above. Withdrawing consent is as simple as granting it.<\/p>\n

The withdrawal of consent does not affect the lawfulness of any processing carried out prior to such withdrawal.
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\nRECIPIENTS<\/strong><\/p>\n

Personal data provided may be disclosed to appropriately appointed recipients, who will process such data in the capacity of data processors and\/or persons authorized to process data.<\/p>\n

The Data Controller does not disclose any information about data subjects to third parties without their consent, unless required by law. In any event, the dissemination of processed personal data is excluded. A complete list of data processors, joint controllers, and persons authorized to process personal data may be requested by sending an email to info@i-com.it<\/a>.
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\nPROCESSING METHODS<\/strong><\/p>\n

Personal data are processed using automated tools for the time strictly necessary to achieve the purposes for which they were collected. A yearly review of stored data is conducted to delete any information deemed obsolete, unless legal requirements mandate its retention.<\/p>\n

Data processing generally takes place at the Data Controller\u2019s premises, carried out by staff or external collaborators duly designated as data processors. A complete list of data processors and persons authorized to process personal data may be requested by sending an email to info@i-com.it<\/a>.<\/p>\n

Specific security measures are implemented to prevent data loss, illicit or incorrect use, and unauthorized access.<\/p>\n

Data related to subscriptions are retained until the user unsubscribes\u2014an action the data subject may take at any time via the link provided in every newsletter. For recipients who have consented to individual tracking, their subscription and the associated data processing remain valid until they unsubscribe or until 12 months have passed since their last recorded direct interaction (click, open, or reply). Once this period has elapsed, the Data Controller will cease sending communications and delete the data, unless the data subject confirms that they wish to continue receiving such communications. For recipients who have not provided such consent\u2014and whose interactions are therefore not linked to a specific profile\u2014the Data Controller will request confirmation of their subscription every 12 months (calculated from the date of initial subscription or the most recent confirmation) and will delete the data if no such confirmation is received. Data related to individual tracking are retained until the consent is withdrawn or the subscription is cancelled. This is without prejudice to any legal obligations or the need to protect the rights of the Data Controller.
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\nRIGHTS OF THE DATA SUBJECT<\/strong><\/p>\n

Pursuant to Articles 15\u201321 of EU Regulation 2016\/679, every data subject is granted a number of rights.<\/p>\n