1. Introduction

The protection of the personal data of its clients, employees and users represents a fundamental and non-negotiable value for Ass. Archivio Alighiero Boetti and all companies controlled by it pursuant to and for the purposes of Article 2359 of the Italian Civil Code (hereinafter, “Archivio Alighiero Boetti”).

Archivio Alighiero Boetti recognises the protection of personal data as an expression of respect for the dignity, freedoms and fundamental rights of individuals. It is committed to processing such data in accordance with the principles of lawfulness, fairness, transparency, security and accountability, adopting appropriate practices and measures to ensure that data is used in compliance with applicable legislation and the organisation’s ethical values.

This document (hereinafter, the “Privacy Policy”) has been prepared in accordance with EU Regulation 2016/679 (hereinafter also referred to as the “GDPR”) and applicable European and national legislation. Its purpose is to describe the principles and procedures governing the management of the websites and digital channels (hereinafter, the “Websites”) of the companies belonging to Archivio Alighiero Boetti, as further identified in Section 2 of this Privacy Policy, with regard to the processing of personal data relating to users and visitors who access them (hereinafter, the “Users”).

Please note that this Privacy Policy applies to the processing of personal data carried out through the Websites of Archivio Alighiero Boetti, but does not apply to processing activities carried out on other websites external to Archivio Alighiero Boetti that Users may visit while browsing by clicking on links and/or banners featured on the Websites. Furthermore, this Privacy Policy does not replace the privacy notices provided by the companies belonging to Archivio Alighiero Boetti, in their capacity as Data Controllers, pursuant to Articles 13 and 14 of the GDPR.

2. Data Controllers

Each of the companies belonging to Archivio Alighiero Boetti identified below acts as a data controller, as defined in Article 4(7) of the GDPR (hereinafter, individually, a “Controller” and collectively, the “Controllers”), in relation to the processing of personal data required for browsing their respective Websites.

To find out which companies belong to Archivio Alighiero Boetti and act as Controllers, together with their respective contact details, click here.

3. Data Protection Officer

In accordance with Article 37 of the GDPR, Archivio Alighiero Boetti has appointed a Data Protection Officer (hereinafter, the “DPO”). You may contact the DPO at any time regarding matters relating to the processing of personal data and/or to exercise your rights as a data subject, as set out in Section 10 of this Privacy Policy, by sending a written communication to info@archivioalighieroboetti.it.

4. Types of Personal Data Processed and Purposes of Processing When Browsing the Websites

It is important to note that, in the digital environment, personal data is primarily collected through cookies and other tracking technologies. The most common include browsing cookies, tracking pixels, behavioural profiling tools and device fingerprinting technologies. Although these tools can be used to personalise services and improve the User experience, their use requires transparency and awareness, in full compliance with applicable legislation and the fundamental rights of individuals.

On each Website, you will find a footer containing a detailed explanation of the cookies and tracking technologies installed on that Website and their respective functions. You may change your preferences regarding the use of cookies at any time, except for technical cookies that enable navigation of the Website and do not require specific consent.

Data Voluntarily Provided by Users

In addition to cookies and tracking technologies, it is important to point out that certain data is collected by the Controller because it is voluntarily provided by the User. Examples include information entered in contact forms or dedicated online forms, as well as requests to subscribe to newsletters or other services.

5. Data Processing Methods and Retention Periods

Archivio Alighiero Boetti considers the protection of personal data a fundamental principle of its operations and acts in full compliance with applicable legislation. All processing activities are carried out in accordance with the principles of fairness, lawfulness and transparency. Only information that is strictly necessary is collected, and its processing is entrusted to authorised and appropriately trained personnel, with the aim of safeguarding confidentiality.

Data may be processed manually or by electronic means. Appropriate technical and organisational measures are adopted to protect its security, integrity and availability and to prevent risks of loss, unlawful use or unauthorised disclosure. Inaccurate data is also corrected or deleted promptly, in accordance with the purposes for which it was collected.

Data is retained only for as long as strictly necessary, unless legal obligations require it to be retained for longer periods, in accordance with the principles established by the GDPR.

Access to the Websites of Archivio Alighiero Boetti is generally intended for adults, with exceptions for minors aged 14 and over, who are provided with simplified privacy information and specific safeguards. The personal data of minors is not used for advertising purposes. Where minors are under the age of 14, their personal data may only be provided with the authorisation of their parents or legal guardians. In any event, the Controller accepts no responsibility for any false statements made by minors.

Finally, where artificial intelligence tools, such as chatbots, are used, data processing is carried out in accordance with the relevant privacy notices, with the assurance that information provided by Users will not be used to train artificial intelligence systems.

6. Redirects to External Websites

The Websites may include tools that integrate with social networks, commonly known as social plug-ins. These tools, which can be identified by the official logos of the relevant platforms, allow certain social media features to be incorporated directly into the Website, such as a “Like” button or the ability to leave a comment.

Please note that when a User interacts with these plug-ins, the information generated is transmitted by the browser to the relevant platform and stored by that platform. To ensure full transparency, Users are encouraged to consult the privacy policy of each social network, which explains the purposes and methods of data collection, use and retention, as well as the rights that Users may exercise.

In this way, Archivio Alighiero Boetti reaffirms its commitment to providing clear information about how digital tools operate and to promoting the responsible use of technology, while respecting each User’s privacy and freedom of choice.

7. Links to and from Third-Party Websites

The Websites may contain links to pages managed by third parties. Please note that once a User chooses to access such external websites, the management of personal data and any authentication credentials falls exclusively under the responsibility of the respective third-party data controllers.

In accordance with the principles of fairness and transparency, Archivio Alighiero Boetti cannot be held responsible for the use of information collected by third parties. Users are therefore encouraged to make their own choices freely and to exercise due care in protecting their privacy.

8. Recipients of Personal Data

Personal data collected by Archivio Alighiero Boetti may be shared with specific recipients solely for the purposes stated and in compliance with confidentiality requirements. First, processing may be entrusted to authorised individuals acting under the direct responsibility of the Controller, who have received appropriate training and have been duly authorised to carry out such activities.

In addition, certain activities may be performed by third parties working with Archivio Alighiero Boetti to provide technical or support services, such as IT companies or maintenance providers. In certain circumstances, data may also be disclosed to entities or organisations that process it as independent data controllers, such as credit institutions, insurance companies, consultants or public authorities, always in accordance with the purposes specified in the relevant privacy notices.

These arrangements reaffirm Archivio Alighiero Boetti’s commitment to ensuring that all data disclosures are carried out transparently and responsibly, with due regard for the rights of data subjects.

9. Transfer of Personal Data

Personal data is processed primarily within the European Union, in compliance with the common data protection rules established by the GDPR. Where technical or operational requirements make it necessary to engage entities located outside the European Economic Area, the Controller ensures that the level of protection remains substantially equivalent to that afforded under European legislation.

All transfers to third countries are governed by the safeguards provided for under the GDPR, such as European Commission adequacy decisions, standard contractual clauses or binding corporate rules. This ensures that personal data is always processed with the same level of care and security, regardless of where the processing takes place.

10. Rights of Data Subjects

As provided for by the GDPR, you may exercise the following rights against the Controller at any time:

Right of access: You have the right to obtain confirmation from the Controller as to whether or not your personal data is being processed, or whether automated decision-making is taking place, and, where this is the case, to access and/or obtain a copy of such personal data (Article 15 GDPR).

Right to rectification: You may request the correction or completion of personal data concerning you that is inaccurate, partial and/or incomplete (Article 16 GDPR).

Right to erasure (the “right to be forgotten”): Under certain circumstances, you have the right to obtain the erasure of your personal data without undue delay (Article 17 GDPR).

Right to restriction of processing: Under certain circumstances, you may obtain the restriction of processing, for example, if you have objected to the processing, exercised your right to rectification and/or if the processing is unlawful. Where processing is restricted, your personal data may be processed, other than for storage purposes, only with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another natural or legal person, or for reasons of substantial public interest. In any event, we will inform you before the restriction is lifted (Article 18 GDPR).

Right to data portability: At any time, you may request and receive all personal data concerning you that is processed by the Controller in a structured, commonly used and machine-readable format, or request that it be transmitted to another data controller without hindrance (Article 20 GDPR).

Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you. In the event of an objection, the Controller will cease processing the data concerned unless it demonstrates compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims (Article 21 GDPR).

To exercise any of these rights, simply contact the Controller using the contact details below:

Write to the Privacy Office of Archivio Alighiero Boetti by sending an email to info@archivioalighieroboetti.it, for the attention of the Privacy Office of Archivio Alighiero Boetti.

11. Updates to the Privacy Policy

This Privacy Policy was last updated in April 2026. The entry into force of new sector-specific legislation, as well as the ongoing review and updating of the general terms and conditions governing the use of the Websites, may make it necessary to amend these procedures.

Accordingly, this Privacy Policy may be amended from time to time, and Users are encouraged to consult this page periodically. Any changes to the privacy notices provided at the time personal data is collected will be communicated by the relevant Data Controller to each affected data subject through the methods determined by the Controller.