Agile, as identified at the beginning of this Privacy Notice, is the Data Controller with regard to all Personal Data processed through the Digital Tools.

You can contact Agile’s Data Protection Officer (“DPO”) at the following email address: dpo@agiletelecom.com  

• Name, Contact Details, and Other Personal Data

In various sections of our Digital Tools, particularly when requesting the activation of a Service or information about our Services, you may be asked to provide information such as your name, phone number, email address, the company you work for, etc.

Additionally, when you communicate with Agile via the email addresses available on the Digital Tools, Agile may collect any additional information you choose to share.

Depending on the type of service requested, it may also be necessary to collect certain specific identity information to comply with industry-specific regulations (e.g. “Alias” rules).

• Special Categories of Personal Data

Some sections of the Digital Tools (e.g. contact or spam reporting forms on the Website) include free-text fields where you may provide Agile with certain information, which could contain Personal Data.

As these are open fields, you may (intentionally or unintentionally) disclose special categories of Personal Data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data uniquely identifying a person, or data concerning health, sex life, or sexual orientation.

In accordance with any applicable contractual terms for the use of Agile’s services (which we invite you to review), Agile asks that you do not provide such data unless strictly necessary. These special categories of data may only be processed with your explicit consent and in accordance with applicable law. Agile therefore highlights the importance of explicitly consenting to the processing of such data, should you decide to share it.

• Data Voluntarily Provided by the Data Subject

As mentioned above, some sections of the Digital Tools allow you to enter text messages visible to Agile, which may include Personal Data of other individuals.

In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities.

To this end, you provide the broadest indemnity with respect to any objection, claim, or request for compensation for damages from data processing that Agile may receive from third parties whose Personal Data has been processed through your use of the Digital Tools in violation of applicable data protection laws.
In any case, if you provide or otherwise process third-party Personal Data while using the Digital Tools, you hereby warrant – assuming full responsibility – that this processing is based on the prior consent of such third parties or another valid legal basis legitimizing the processing of the relevant information.

• Personal Data Automatically Collected When We Send Emails or Communications

When we send emails or other communications, we use tracking systems – subject to your freely given consent – such as pixels or web beacons to detect whether a message is opened, which hyperlinks are clicked, from which IP address and with which type of browser the email is opened, and other similar details.

• Browsing Data

The IT systems and software procedures that enable the functioning of the Digital Tools may, during their normal operation, collect certain Personal Data, the transmission of which is implicit in the use of Internet communication protocols.

This information is not collected with the intent of being associated with identified individuals, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes IP addresses or domain names of the devices used by users who connect or interact with the Digital Tools, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the response file, the numerical code indicating the status of the server’s response (success, error, etc.), and other parameters related to the user’s operating system and computing environment.

These data are used solely to obtain anonymous statistical information on the use of the Digital Tools and to monitor their proper functioning, to identify anomalies and/or abuse, and are deleted immediately after processing.

Data may be used to ascertain responsibility in the event of cybercrimes against the site or third parties; except for this eventuality, web contact data is currently anonymised.

• Cookies

Definitions, Characteristics, and Applicable Law

Cookies are small text files that websites visited by the user send to the user’s computer or mobile device, where they are stored and then retransmitted to the same websites upon the next visit. Cookies allow a website to remember the user’s actions and preferences (such as login data, selected language, font size, display settings, etc.), so they don’t have to be re-entered when the user returns to the site or navigates from one page to another.

Cookies are used to perform computer authentications, session monitoring, and to store information about users’ activities on a website, and may also contain a unique identification code that tracks the user’s browsing within the site for statistical or advertising purposes. While browsing a website, the user may also receive cookies from third-party websites or web servers (so-called “third-party cookies”).

Some operations may not function properly without the use of cookies, which in certain cases are therefore technically necessary for the website’s functionality.
There are various types of cookies based on their characteristics and functions, and they can remain on the user’s computer for different periods of time:

• Session cookies, which are automatically deleted when the browser is closed;
• Persistent cookies, which remain on the user’s device until a preset expiration date.

According to applicable law, user consent is not always required for the use of cookies. In particular, “technical cookies” – used solely to carry out the transmission of a communication over an electronic communications network, or strictly necessary to provide a service explicitly requested by the user – generally do not require user consent.

In contrast, “profiling cookies”, which are used to create user profiles and send advertising messages aligned with the preferences shown during web browsing, generally require the user’s prior consent, depending on the applicable regulations.

Types of Cookies Used by the Digital Tools and Opt-Out Options

The Digital Tools use the following types of cookies, which can be de-selected (except for third-party cookies, for which you should refer to the respective third-party policies and opt-out mechanisms provided via links):

• Technical navigation or session cookies, which are strictly necessary for the operation of the Digital Tools or to allow you to use requested content and services;
• Analytical cookies, which help us understand how users interact with the Digital Tools. These cookies do not collect your identity or any Personal Data. The information is processed in aggregate and anonymised form;
• Functionality cookies, which are used to enable specific features (e.g., language preferences) and improve the service provided;
• Profiling cookies, which are used to deliver advertising aligned with your browsing preferences.

Agile also uses third-party cookies, meaning cookies from websites or web servers other than Agile’s, used for their own purposes – including profiling. These third parties, listed with links to their respective privacy policies, are typically independent data controllers for the data collected through their cookies, or they act as Agile’s data processors (i.e., process data on behalf of Agile).

The specific cookies used by Agile through the Digital Tools can be viewed via the following links, along with the related privacy policies:

• www.agiletelecom.com
• www.faxator.com
• www.qlara.ai

Cookie Settings

You can block or delete (in whole or in part) technical and functionality cookies using your browser settings. However, please note that disabling technical cookies may make it impossible to use the Digital Tools, access content, or benefit from related services. Disabling functionality cookies may prevent some services or features from being available or functioning properly, and you may be required to re-enter certain information or preferences each time you visit or use the Digital Tools.

Your cookie preferences will be stored in a dedicated cookie. However, in some cases, this may not function correctly. In such cases, we recommend manually deleting or disabling unwanted cookies using your browser settings.
Please note that preferences will need to be set separately on each device or browser you use to access the Digital Tools.

How to View and Modify Cookies Through Your Browser

You can authorize, block, or delete (in whole or in part) cookies using your browser settings. For more information on how to manage cookie preferences via your browser, please consult the instructions below:

• Internet Explorer
• Firefox
• Chrome
• Safari

If you use a different browser, search for “cookies” in the help section to find your browser’s cookie settings.

You can also manage third-party cookie preferences via platforms such as AdChoice or All About Cookies.

WARNING: Disabling technical and/or functionality cookies may prevent access to or proper operation of some parts or features of the Digital Tools, and you may be required to re-enter certain information or preferences manually with each visit.

Flash Cookie Management
To modify your Flash cookie settings, click on the following link:
Disable Flash Cookies

Third-Party Websites
Our Digital Tools may contain links to other websites with their own privacy policies, which may differ from Agile’s. Agile is not responsible for the privacy practices of such third-party websites.

Agile will use your Personal Data, collected through the Digital Tools, for the following purposes:

• Service Provision: to enable you to register and access reserved Services, assist you in case of lost or forgotten login credentials, send you Agile’s newsletter upon your subscription (which contains only informational and non-commercial content), respond to your information requests submitted via the Contact section, and more generally, to provide services through the Digital Tools and supply any information, quotes, etc., you may request through Agile’s communication channels (“Service Provision”);
• Marketing: to send you marketing communications, promotions, advertisements, market research, and surveys via email, SMS, phone, banners, regular mail, instant messaging, via an operator, and through Agile’s official social media pages, including marketing-related initiatives such as sweepstakes, games, and contests related to Agile’s or third-party products and/or services (“Marketing”);
• Soft Spam: to send you marketing emails regarding products and services similar to those you have already purchased (“Soft Spam”);
• Compliance: to comply with legal obligations that require Agile to collect and/or further process certain types of Personal Data (“Compliance”);
• Abuse/Fraud Prevention: to monitor how the Digital Tools are used, detect or prevent any misuse or fraudulent activity, and enable Agile to defend itself in legal proceedings (“Abuse/Fraud”).

The legal bases relied upon by Agile for processing your Personal Data, according to the purposes outlined in Section 3 above, are as follows:

• Service Provision: the processing for this purpose is necessary in order to provide the Services and, therefore, to perform pre-contractual or contractual obligations at your request. While it is not mandatory to provide your Personal Data to Agile for this purpose, failure to do so will prevent Agile from delivering the Services. The same applies to the newsletter service, which is activated based on your explicit request by providing an email address, and from which you may unsubscribe at any time by following the instructions set out in Section 8 of this Privacy Notice.
• Marketing: the processing for this purpose is based on your consent. You are not required to provide your consent to Agile for this purpose and may withdraw it at any time without any consequences (except that you will no longer receive marketing communications from Agile). You can withdraw your previously given consent by following the instructions in Section 8 of this Privacy Notice.
• Soft Spam: this processing is based on Agile’s legitimate interest in sending you email marketing communications about products or services similar to those you have already purchased. You may stop receiving these communications at any time, without any consequences (other than no longer receiving such communications), by clicking the unsubscribe link provided in each of these emails.
• Compliance: processing is necessary for Agile to fulfil its legal obligations. When you provide Personal Data to Agile, it must be processed in accordance with applicable laws, which may require retention and disclosure to authorities for accounting, tax, or other legal obligations.
• Abuse/Fraud: the information collected for this purpose will be used solely to prevent and/or detect fraudulent activities or misuse of the Digital Tools, and to enable Agile to protect itself in legal proceedings.

Your Personal Data may be shared with the following parties (the “Recipients”):

• Entities acting as data processors, such as:
  • i) individuals, companies, or professional firms providing assistance and consulting to Agile in accounting, administrative, legal, tax, financial, or debt collection matters related to the provision of Services;
  • ii) parties responsible for providing technical maintenance services (including maintenance of network equipment and electronic communications networks);
• Third parties necessary for the provision of Services, such as hosting providers;
• Persons authorized by Agile to process Personal Data strictly related to the delivery of Services, who are bound by confidentiality obligations or are subject to an appropriate statutory duty of confidentiality (e.g., Agile employees);
• Companies within our corporate group, for internal administrative purposes;
• Parties involved in extraordinary corporate transactions, such as mergers or acquisitions, including authorized personnel from the target or acquiring companies, their consultants, investors, shareholders, and third-party service providers. Such disclosure may be required for due diligence or to facilitate the transition of Services and is based on Agile’s legitimate interest in conducting business operations;
• Public authorities or other entities, where required to disclose your Personal Data for Compliance, Abuse or Fraud purposes, or in response to lawful orders issued by authorities.

Some of your Personal Data may be transferred to Recipients, both internal and external to Agile, located outside the European Economic Area (EEA). Agile ensures such transfers comply with applicable data protection laws, using appropriate safeguards such as adequacy decisions, Standard Contractual Clauses approved by the European Commission, or other lawful mechanisms.

For more information, contact: privacy@agiletelecom.com.

Personal Data processed for the Service Provision purpose will be retained by Agile for the time strictly necessary to fulfil that purpose (e.g., to respond to inquiries submitted via the Contact section). However, since such Personal Data is processed to provide the Services, Agile may retain it for a longer period, particularly if necessary to protect Agile’s interests against potential claims related to the Services.

Personal Data processed for Marketing purposes will be retained by Agile until you withdraw your consent. You will be asked to renew your consent periodically. Once consent is withdrawn, Agile will stop using your data for marketing, but may still retain it to the extent necessary to protect its interests against potential claims arising from such processing.

Personal Data processed for Soft Spam purposes will be retained by Agile until you object to such processing via the unsubscribe link included in each Soft Spam email.

Personal Data processed for Compliance purposes will be retained for the period required by specific legal obligations or applicable regulations.

Personal Data processed to prevent Abuse/Fraud will be retained only for the time strictly necessary for this purpose and, in any case, until Agile is required to retain it for the purposes of defending itself in court or complying with requests from competent authorities.

You have the right to request from Agile, at any time:

• Access to your Personal Data (or a copy), and further details on how it is processed;
• Rectification or update of your incomplete or outdated data;
• Erasure of your data from Agile’s systems;
• Restriction of data processing;
• Portability of your data in a structured, commonly used, machine-readable format.

You also have the right to:

• Object to processing (e.g., for Soft Spam);
• Withdraw consent given for Marketing at any time.

You can unsubscribe from marketing and Soft Spam emails via the link in each communication. The same applies to the Agile newsletter.
Consent to cookie-based profiling may be withdrawn at any time, following the guidance in Section 2.f.

You can also exercise your rights by contacting Agile at: privacy@agiletelecom.com.

In any case, you have the right to lodge a complaint with the competent Supervisory Authority (in Italy, the Garante per la Protezione dei Dati Personali) if you believe your data has been processed unlawfully.

This Privacy Policy is effective as of 19/06/2025. Agile reserves the right to amend or update its content, in whole or in part, including due to changes in applicable law. Agile will inform you of such changes as soon as they are implemented, and they will become binding upon publication on the Digital Tools.
You are encouraged to regularly review this section to stay up to date with the latest version of the Privacy Policy and understand how Agile collects and uses your data.