Privacy Policy Chatbot

INFORMATION ON ON THE PROCESSING OF PERSONAL DATA IN THE CONTEXT OF USING THE "GAIA" CHATBOT 

(ART. 13 EU REGULATION 2016/679)

Information on the Data Controller and the Data Protection Officer. The Data Controller is Fiera Bolzano SpA/AG, with its registered offices in Piazza Fiera 1, 39100 Bolzano (BZ). The Data Controller has also appointed a Data Protection Officer (or DPO), Effizient Srl, with offices at via Galvani 6/A, 39100 Bolzano (BZ). To exercise your rights as provided by law, you may contact the Data Controller at their offices by phoning 0471 516000 or by emailing them at dpo@fierabolzano.it, or the Data Protection Officer at their offices, by phoning 0471 053533 or by emailing them at dpo@fierabolzano.it.

General Information. This data protection policy provides information on how personal data is processed in relation to the use of the Client's chatbot on the website [www.fierabolzano.it] ("Website") and the use of the "GAIA" chatbot ("Chatbot"), in accordance with Regulation (EU) 2016/679 ("GDPR"). This policy supplements the Client's general data protection notice for website visitors. We recommend reading the general policy as well to obtain a complete overview of data processing activities.

The "GAIA" chatbot serves exclusively to offer users quick, barrier-free, and interactive access to various information on the website. Use for purposes other than those agreed upon is excluded.

Data Collected and Retention Periods

• Interaction Content: All messages sent or received via the chatbot are processed to enable the dialogue. We ask that you never enter personal data that could identify you or others. This includes contact details, addresses, tax codes, and similar information. The provision of personal data is not required by contract or law and is not necessary for the chatbot's functionality. You will not suffer any disadvantage if you do not provide such information. As recommended, please do not reveal such identifying information. We also ask that you never provide sensitive data, such as health-related data.
• System and Access Information: To provide and securely manage the "GAIA" chatbot, various technical information is collected automatically. This includes, among other things, a randomly generated pseudonymous client ID, browser data (e.g., version and language), date and time of the call, configured time zone, and information about the terminal device's operating system. The so-called referrer URL (the page from which the chatbot was accessed) and technical system log or protocol data are also collected.
• Voluntary Evaluation of Responses and the Chatbot: If you wish to rate the responses of our chatbot to improve it (for example, via "thumbs up/thumbs down"), this information is also collected and used for service improvement.
• Chat-Key: This is a identification number for the chat itself, used to prevent loss of history and to maintain an active session (for example, if you switch to another window). The retention period for this cookie is a maximum of 3 days.
• Chat-ClientID: Each user receives a randomly generated client ID. This is used to make chats traceable. Without additional information, it cannot be attributed to any specific person and is therefore considered pseudonymous data. The retention period for this cookie is 1 year.
• Chat-Privacy: This cookie is created as soon as you consent to the data protection policy within the chat. This allows us to verify that the policy has been confirmed. The retention period for this cookie is 7 days.

Purposes and Legal Basis for Processing. The use of the chatbot requires the user's consent pursuant to Art. 6, para. 1, let. a) GDPR. However, refusing consent does not prevent you from obtaining the desired information by browsing our Website.

The legal basis for setting cookies is Art. 6, para. 1, let. f) GDPR, for the pursuit of the Data Controller's legitimate interest in ensuring a useful and efficient user experience.

To ensure the quality of chatbot content, selected conversation fragments may be used. To avoid processing personal data, chats may be used for quality control, content updates, and reporting only after all identifying information has been removed. The legal basis for these purposes is Art. 6, para. 1, let. f) GDPR.

Communication of Data (Recipients). This chatbot uses the OpenAI ("ChatGPT") language model. The headquarters is located at: 3180 18th St, San Francisco, California 94110, USA. By default, processing takes place via the data center in Ireland at: The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland. Nevertheless, this provider does not receive any identifying information, personal data of users, or chat content. We use this provider out of technical necessity based on a legitimate interest to offer you a powerful and useful chatbot.

In principle, your data may be transmitted to the following categories of recipients: external legal or tax consultants, IT service providers, authorities, and other public bodies.

Transfer of data to third countries or international organizations. Your personal data is not transferred to third countries or international organizations outside the European Union. In consideration of the use of tools subject to US companies, any transfer to this non-EU country would take place on the basis of a specific adequacy decision.

Use by Childs. The use of this chatbot is not intended for minors. We do not intentionally collect or store data from minor visitors (except unintentionally). Persons under the age of 18 are therefore not authorized to use the chatbot.

Rights of the interested party and complaint to the  Data Protection Authorityr. You have the right to request access to your data at any time, as well as its modification, integration or deletion, limitation or opposition to its processing, where there are legitimate reasons, as well as its portability to another Data Controller. You may also lodge a complaint with the Data Protection Authority if you believe your data has been processed unlawfully.