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Privacy Policy

Information on the processing of personal data pursuant to Art. 13 of EU Regulation 2016/679

Last updated: February 12, 2026

1. Data Controller

The Data Controller is Optivo S.r.l., with registered office at Via Michele Lessona 61, 00134 Rome (RM), Italy, VAT IT16678681004, REA Number: RM-1669693, PEC: [email protected].

Data Protection Officer: Gabriele Gangemi.
For any questions regarding the processing of personal data, you can contact the Data Controller at: [email protected].

2. Data Collected and Purposes

The website collects personal data in the following ways:

a) Browsing data
The IT systems and hosting services used to operate the website automatically collect certain personal data whose transmission is implicit in the use of Internet communication protocols (e.g., IP addresses, browser type, operating system, referring URL, pages visited, date and time of the request). Such data is necessary for the operation of the website and is processed for security and technical purposes.

b) Technical cookies
The website uses technical cookies necessary for its operation and, with user consent, behavioral analytics cookies. For more details, see the Cookie Policy.

c) Traffic statistics
The website uses Cloudflare Web Analytics, a web traffic analysis service provided by Cloudflare, Inc. that operates without cookies and without collecting personally identifiable data, analyzing traffic in a fully aggregated and anonymous form.

d) Behavioral analytics (with consent)
With user consent, the website uses Microsoft Clarity, a behavioral analytics service provided by Microsoft Corporation that allows recording anonymized browsing sessions and generating heatmaps to understand how users interact with the site. Clarity installs its own cookies only after explicit user consent. — Clarity disclosure

e) Data voluntarily provided through demo booking
The website allows users to book a free demo through the external service zcal (zcal.co). When a user uses this service, the personal data provided (name, email, any notes) is collected and processed directly by zcal as an independent data controller, according to their own Privacy Policy. Optivo receives such data solely for the purpose of organizing the requested appointment.

3. Legal Basis for Processing

The processing of personal data is based on the following legal grounds pursuant to Art. 6 of EU Regulation 2016/679:

  • Legitimate interest of the Controller (Art. 6(1)(f)): for browsing data, necessary to ensure the operation and security of the website
  • Exemption from consent (Art. 5(3), Directive 2002/58/EC): for strictly necessary technical cookies, exempt from prior consent requirements
  • Performance of pre-contractual measures (Art. 6(1)(b)): for data provided by the user through demo booking, as processing is necessary to take steps at the request of the data subject prior to entering into a contract
  • User consent (Art. 6(1)(a)): for the installation of Microsoft Clarity behavioral analytics cookies, activated exclusively after explicit user consent via the website's cookie banner

4. Third-Party Services

The website uses the following third-party services that may process personal data as data processors or independent controllers:

  • Cloudflare, Inc. (San Francisco, USA) — CDN (Content Delivery Network), DDoS protection and website performance optimization. Cloudflare may process IP addresses and browsing data for security purposes. — Privacy Policy
  • zcal (zcal.co) — Appointment booking service used for free demos. Data provided by the user (name, email) is processed by zcal as an independent controller. — Privacy Policy
  • Cloudflare Web Analytics (Cloudflare, Inc., San Francisco, USA) — Cookieless web traffic statistics service. Does not collect personally identifiable data. — Learn more
  • Microsoft Clarity (Microsoft Corporation, Redmond, USA) — Behavioral analytics service (heatmaps and session recording). Activated only with user consent. — Privacy disclosure

5. Data Retention

Browsing data is deleted immediately after technical processing, except for potential use in investigating computer crimes against the website.

Demo booking data is retained by zcal according to their own privacy policy. Optivo retains contact data received for the time necessary to fulfill the request and any subsequent commercial activity, in compliance with the principles of data minimization and storage limitation (Arts. 5(1)(c) and 5(1)(e) GDPR).

6. Data Subject Rights

Pursuant to Articles 15-22 of EU Regulation 2016/679, data subjects have the right to:

  • Access their personal data (Art. 15 GDPR)
  • Rectify inaccurate data (Art. 16 GDPR)
  • Obtain erasure of data (Art. 17 GDPR)
  • Restrict processing (Art. 18 GDPR)
  • Object to processing (Art. 21 GDPR)
  • Receive their data in a structured, machine-readable format — portability (Art. 20 GDPR)
  • Withdraw consent at any time, without affecting the lawfulness of processing based on consent given before withdrawal
  • Lodge a complaint with the Italian Data Protection Authority — www.garanteprivacy.it

To exercise your rights, write to: [email protected].

7. Data Transfers Outside the EU

Cloudflare and Microsoft Clarity, headquartered in the United States, may involve the transfer of data to countries outside the European Economic Area. Such transfers are carried out on the basis of adequate safeguards pursuant to Articles 46-49 of the GDPR, including the European Commission's Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework (European Commission Adequacy Decision of July 10, 2023).

8. Changes to This Policy

The Data Controller reserves the right to amend this privacy policy at any time, publishing the updated version on this page. Please check this page periodically. If you do not accept the changes made, you may request the deletion of your personal data by contacting the Data Controller.