Privacy Policy

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

You can contact Agile's Data Protection Officer ("DPO") at the following address: dpo@agiletelecom.com

When you use the Digital Tools, you may communicate to us, or we may collect, certain of your Personal Data, which – depending on the case - may consist of an identifier such as your name, an identification number, an online identifier, or one or more elements characteristic of your physical identity, physiological, mental, economic, cultural or social identity, sufficient to identify or make you identifiable (hereinafter referred to simply as "Personal Data").

Your Personal Data may be collected either because you voluntarily provide it (e.g., when you request information from Agile through the Contact section on the website https://agiletelecom.com/contactus/, when you subscribe to our newsletter, when you request one of our Services: in the latter case, it may also be necessary to collect further information regarding your identity in order to comply with specific sector-specific provisions, where applicable) or simply by analyzing your behavior on the Digital Tools.

a. Name, Contact Details and Other Personal Data

In various sections of our Digital Tools, in particular the section relating to requesting activation of a Service or requesting information regarding our Services, you will be asked to enter information such as your name, telephone number, email address, the company you work for, etc.

Furthermore, when you communicate with Agile through the email addresses found on the Digital Tools, Agile may collect any further information that you decide to provide.

Agile may further process:

– the information provided in connection with requests for assistance and support submitted through the Digital Tools;

– data relating to transactions carried out through the Digital Tools, such as transaction identifiers, amount, currency, payment outcome, information relating to any refunds and other administrative data necessary for the management of the contractual relationship and of the requested service. Data relating to payment instruments (such as card number, security code or payment credentials) is generally processed directly by the payment service providers and is not acquired by Agile, unless otherwise indicated to the user.

Depending on the type of service requested, it may also be necessary to collect certain specific information regarding your identity in order to comply with specific sector-specific provisions (e.g., the "Alias" regime).

b. Special Categories of Personal Data

Certain sections of the Digital Tools (e.g., the Site's forms for requesting a call-back or reporting spam) include free-text fields in which you can provide Agile with certain information, which may contain Personal Data.

Since these fields are free-text, you might use them to communicate (whether voluntarily or not) certain sensitive 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 intended to uniquely identify a natural person, data concerning health or a person's sex life or sexual orientation.

In accordance with the contractual terms that may be applicable to the use of specific services offered by Agile, which we invite you to check, Agile asks you not to send such Personal Data unless strictly necessary. Indeed, such special categories of Personal Data may be processed only with your explicit consent and in compliance with the law in force from time to time. Agile therefore stresses the importance of giving your explicit consent to the processing of the special categories of Personal Data, should you decide to share such information.

c. Data Voluntarily Provided by the Data Subject

As already mentioned above, in certain sections of the Digital Tools you are permitted to enter text messages, visible to Agile, which may contain Personal Data of other persons.

In such cases, you act as an autonomous Controller, assuming all statutory obligations and liabilities. In this regard, you grant the broadest indemnity in relation to any dispute, claim, claim for damages arising from processing, etc. that may be brought against Agile by third parties whose Personal Data have been processed as a result of your use of the functions of the Digital Tools in violation of applicable personal data protection laws. In any event, should you provide or otherwise process third parties' Personal Data in your use of the Digital Tools, you hereby warrant – assuming any and all liability connected thereto – that such particular instance of processing is based on the consent of such third-party data subject or on another appropriate legal basis legitimizing the processing of the information in question.

d. Personal Data Automatically Collected When We Send Emails or Communications

When we send emails or communications, we use tracking systems, subject to the user's freely given prior consent, such as, for example, pixels or web beacons, to detect the opening of a message, clicks made on the hyperlinks contained within the email, the IP address from which, or the type of browser with which, the email is opened, and other similar details.

e. Browsing Data

The computer systems and software procedures used to operate the Digital Tools acquire, during their normal operation, certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected for the purpose of being associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, enable users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to or use the Digital Tools, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful outcome, error, etc.) and other parameters relating to the user's operating system and computing environment. This data is used solely to derive anonymous statistical information on the use of the Digital Tools and to monitor its correct functioning, to identify anomalies and/or abuse, and is deleted immediately after processing. The data may be used to establish liability in the event of hypothetical computer crimes to the detriment of the site or of third parties: save for this possibility, web contact data is currently anonymized.

f. Cookies

Definitions, characteristics and application of the legislation

Cookies are small text files that websites visited by the user send and store on the user's computer or mobile device, to be subsequently retransmitted to the same websites on the user's next visit. It is precisely thanks to cookies that a website remembers the user's actions and preferences (such as, for example, login details, the language selected, font sizes, other display settings, etc.) so that these do not need to be entered again when the user returns to visit the site or navigates from one page of it to another. Cookies are therefore used to perform computer authentication, session monitoring and storage of information regarding the activities of users accessing a website, and may also contain a unique identification code enabling the user's browsing within the website itself to be tracked for statistical or advertising purposes. In the course of browsing a website, the user may also receive on their computer cookies from websites or web servers other than the one being visited (so-called "third-party" cookies).

Certain operations could not be carried out without the use of cookies, which in certain cases are therefore technically necessary for the very functioning of the site.

There are various types of cookies, depending on their characteristics and functions, and these may remain on the user's computer for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user's device until a pre-set expiry date.

Under applicable law, the use of cookies does not always require the user's express consent. In particular, "technical cookies" do not usually require such consent, i.e., those used solely to carry out the transmission of a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user. In other words, these are cookies that are essential for the functioning of the site or necessary to carry out activities requested by the user.

For "profiling cookies", on the other hand, i.e., those aimed at creating profiles relating to the user and used for the purpose of sending advertising messages in line with the preferences expressed by the user in the course of browsing the network, the user's prior consent is usually required, to the extent this depends on applicable law.

Types of cookies used by the Digital Tools and the possibility of (de)selection

The Digital Tools use the following cookies, which can be de-selected, except for third-party cookies, for which you will need to refer directly to the relevant selection and de-selection methods for the respective cookies, indicated by means of a link:

– Technical navigation or session cookies, strictly necessary for the functioning of the Digital Tools or to enable you to make use of the requested content and services.

– Analytics cookies, which make it possible to understand how the Digital Tools are used. No information about your identity, nor any Personal Data, is collected by means of these cookies. The information is processed in aggregate and anonymous form.

– Functionality cookies, i.e., used to activate specific functionalities of the Digital Tools and a series of selected criteria (for example, the language) in order to improve the service provided.

– Profiling cookies, used for the purpose of sending advertising messages in line with the preferences you have expressed in the course of browsing the network.

Agile also uses third-party cookies, i.e., cookies from websites or web servers other than Agile's own, for purposes specific to such third parties, including profiling cookies. Please note that such third parties, listed below together with the relevant links to their privacy policies, are typically autonomous controllers of the data collected through the cookies they serve, or act as processors for Agile (i.e., they process Personal Data on Agile's behalf).

In detail, the cookies sent by Agile through the Digital Tools can be viewed by clicking on the link provided here, together with the relevant privacy policy:

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 through the specific functions of your Browser. However, please note that not authorizing technical cookies may result in it being impossible to use the Digital Tools, view their content and make use of the related services. Disabling functionality cookies may result in certain services or specific functions of the Digital Tools not being available or not functioning correctly, and you may be required to modify or manually enter certain information or preferences each time you visit or use the Digital Tools.

The choices made with regard to cookies on the Digital Tools will in turn be recorded in a dedicated cookie. This cookie may, however, in certain circumstances not function correctly: in such cases, we recommend that you delete any unwanted cookies and disable their use also through your Browser's functions.

Your cookie preferences will need to be reset if you use different devices or Browsers to access the Digital Tools.

How to view and change cookies through the Browser

You can authorize, block or delete (in whole or in part) cookies through the specific functions of your Browser. For further information on how to set your cookie preferences through the Browser, you may consult the relevant instructions:

– Internet Explorer

– Firefox

– Chrome

– Safari

If you do not use any of the browsers listed above, select "cookie" in the relevant section of the help guide to find out where your cookie folder is located.

You can also manage your choices regarding third-party cookies using online platforms such as AdChoice or All about cookies.

WARNING: by disabling technical and/or functionality cookies, the Digital Tools may become unavailable for consultation, or certain services or specific functions of the Digital Tools may be unavailable or may not function correctly, and you may be required to modify or manually enter certain information or preferences each time you visit or use the Digital Tools.

Deletion of Flash cookies

Click on the link below to change your Flash cookie settings.

Disabling Flash cookies

Third-party websites

Our Digital Tools may contain links to other websites that have their own privacy policy. Such privacy policies may differ from the one adopted by Agile, which is therefore not responsible for third-party websites.

g. Data Relating to the Use of the Digital Tools

Agile reserves the right to collect information relating to users' use of the Digital Tools, such as data relating to browsing methods, interaction with specific functionalities, usage preferences, browsing paths and other indicators useful for understanding the functioning and usability of the Digital Tools.

Such information may also be collected by means of user experience analysis tools (such as, by way of example, heatmaps, appropriately configured session replay, aggregate analysis tools or similar measurement systems), by adopting appropriate technical and organizational measures to limit the collection of information exceeding that necessary for the purposes pursued and in compliance with the principle of data minimization.

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

– to provide the Services, such as: enabling you to register in order to access the Services with restricted access and assisting you in the event that you should lose or forget your login/registration password details; sending you Agile's newsletter that you have requested as a Service by subscribing thereto and which contains only informational, non-commercial material; responding to your requests for information sent through the Contact section and – more generally – offering the services through the Digital Tools, as well as managing payments, providing you with any information, quote, etc. that you may request through any of Agile's channels, including the handling of requests for assistance, information and technical support, including by means of automated tools, chatbots or AI, as well as the possibility of retaining the related interactions to the extent necessary for the management of such requests and for the improvement of support processes, and the sending of communications relating to the activation, management, use, security, updating, maintenance and proper provision of the Services and of the Digital Tools ("Service Provision");

– to send you marketing, promotional and advertising communications, market research, by email (which may include tracking pixels or similar technologies), SMS, telephone, banners, paper mail, instant messaging, through an operator, through Agile's official social media pages, as well as for marketing activities in the broad sense, including prize contests, events, games and competitions, relating to products and/or services attributable to Agile or to third parties ("Marketing");

– to send you marketing communications by email regarding products and services similar to those you have purchased ("Soft Spam");

– to enable us to improve the functioning of our Services, to analyze usage patterns, performance, and interactions with the Digital Tools in order to improve your User Experience and accessibility, and to carry out debugging activities, consisting of detecting and correcting one or more errors (bugs) found in our systems ("Improvement and Debugging");

– to ask you to participate in surveys, questionnaires, satisfaction assessments and feedback-collection activities relating to the Services and the Digital Tools, in order to improve their quality, functionality and usability ("Survey");

– to identify persons with characteristics similar to users who already use our Services. For this purpose, we share with social media platforms such as Meta and/or TikTok the Personal Data of registered users, previously hashed, so as to enable the display of advertisements relevant to persons who might be interested in our Services ("Audience Expansion");

– to analyze certain information relating to your relationship with Agile, your preferences, your interactions with the communications received and the ways in which you use the Digital Tools, in order to create commercial segments or profiles and make the communications, offers and promotional initiatives directed at you more relevant ("Personalization");

– to fulfil statutory obligations requiring Agile to collect and/or further process certain types of Personal Data ("Compliance");

– to monitor the ways in which the Digital Tools are used, to prevent or detect any abuse in the use of the Digital Tools, or any fraudulent activity, and thus to enable Agile to defend itself in legal proceedings ("Abuse/Fraud").

The legal bases used by Agile to process your Data, according to the purposes indicated in Paragraph 3 above, are the following:

– Service Provision: the processing for this purpose is necessary in order to provide you with the Services and, therefore, for the performance of pre-contractual or contractual measures requested by you. It is not mandatory to provide Agile with your Personal Data for this purpose, but failure to do so will make it impossible to provide you with any Service. The same applies to the newsletter Service, which arises from your specific request through the entry of an email address and which you may withdraw at any time by following the instructions set out in Paragraph 8 of this Notice.

– Marketing: the processing for this purpose is based on your consent. It is not mandatory to give your consent to Agile for this purpose and you are free to withdraw it at any time without any consequence (other than the fact that you will no longer receive marketing communications from Agile). You may withdraw your previously given consent by following the instructions set out in Paragraph 8 of this Notice.

– Soft Spam: the processing for this purpose is based on Agile's legitimate interest in sending you marketing communications by email regarding products and services similar to those you have already purchased. You may stop receiving these communications, without any consequence to you (other than the fact that you will no longer receive further communications of this kind from Agile), by using the link found at the bottom of each of these emails;

– Improvement and Debugging: the processing for this purpose is based on our legitimate interest in improving our Services and in carrying out debugging and caching activities;

– Survey: the processing for this purpose is based on Agile's legitimate interest in involving you in surveys, questionnaires, satisfaction assessments and feedback-collection activities relating to the Services and the Digital Tools, with the objective of pursuing the constant improvement of the services offered;

– Audience Expansion: the processing for this purpose is based on our legitimate interest in expanding our customer base by creating advertising audiences similar to users who currently interact with our Services and by publishing advertisements through social media platforms;

– Personalization: the processing for this purpose is based on Agile's legitimate interest in improving the relevance of the communications and content offered. You have the right to object at any time to the processing for Personalization purposes, without any consequence, by following the instructions set out in Paragraph 8 of this Notice;

– Compliance: the processing for this purpose is necessary for Agile in order to fulfil any statutory obligations. When you provide Personal Data to Agile, it must be processed in accordance with applicable law, which may entail its retention and disclosure to the Authorities for accounting, tax or other obligations.

– Abuse/Fraud: the information collected for this purpose will be used solely to prevent and/or detect any fraudulent activity or abuse in the use of the Digital Tools and thus enables Agile to defend itself in legal proceedings.

Your Personal Data may be shared with the parties indicated below (the "Recipients"):

– parties typically acting as processors, namely: i) persons, companies or professional firms providing assistance and advisory services to Agile in accounting, administrative, legal, tax and credit-recovery matters in connection with the provision of the Services; ii) parties appointed to carry out technical maintenance activities (including the maintenance of network equipment and electronic communications networks);

– parties with whom it is necessary to interact for the provision of the Services (for example, hosting providers) or providers of payment services, banking institutions, financial operators and parties involved in the management of economic transactions, to the extent necessary for the execution of the payment requested by the user;

– persons authorized by Agile to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who have undertaken to maintain confidentiality or are subject to an adequate legal confidentiality obligation (e.g., Agile's employees);

– companies of our Group for internal administrative purposes;

– in the event of extraordinary corporate transactions, corporate or intra-group reorganizations, contributions-in-kind, demergers, mergers, acquisitions, transfers of a business or business unit, assignments or transfers of the Agreement, of the Services or of the related assets, persons authorized by the companies involved in the transaction, companies of the Group that may be designated to take over the provision of the Services, their advisors, investors, shareholders and third-party service providers. Such disclosure may be necessary for purposes of due diligence, valuation, execution of the transaction, transfer or continuity of the Services, and is based on the legitimate interest in carrying out corporate business and reorganization activities;

– parties, bodies or authorities to whom it is mandatory to disclose your Personal Data for Compliance, Abuse or Fraud purposes, or pursuant to orders of the authorities;

Some of your Personal Data is shared with Recipients, whether internal or external to Agile, who may be located outside the European Economic Area. Agile ensures that the processing of your Personal Data by such Recipients takes place in compliance with applicable law. Indeed, transfers are carried out by means of appropriate safeguards, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other safeguards considered appropriate. Further information is available by writing to the following address: privacy@agiletelecom.com.

Personal Data processed for the purpose of Service Provision will be retained by Agile for the time strictly necessary for the aforesaid purpose (e.g., to respond to requests for information sent to us through the Contact section). In any event, since such Personal Data is processed in order to provide you with the Services, Agile may retain it for a longer period, in particular to the extent that this may be necessary in order to protect Agile's interests against possible claims relating to the Services.

Personal Data processed for the purpose of Marketing will be retained by Agile until you withdraw your consent; you will in any event be asked to renew your consent periodically. Once consent has been withdrawn, Agile will no longer use your Personal Data for that purpose, but may nonetheless retain it, in particular to the extent that this may be necessary in order to protect Agile's interests against possible claims based on such processing.

Personal Data processed for the purpose of Soft Spam will be retained by Agile until you object to such processing by means of the link found at the bottom of each Soft Spam email.

Personal Data processed for the purposes of Survey and Improvement of the User Experience will be retained by Agile until you object to such processing by means of the methods further indicated in Section 8 of this Privacy Policy.

Personal Data processed for the purpose of Audience Expansion will be retained for the time strictly necessary for the creation, updating and management of the customized or similar audiences on the advertising platforms used and, in any event, until you object to such processing by means of the methods further indicated in Section 8 of this Privacy Policy.

Personal Data processed for the purpose of Personalization will be retained by Agile for the time strictly necessary to pursue such purpose, and in any event until you object to such processing by means of the methods further indicated in Section 8 of this Privacy Policy.

Personal Data processed for the purpose of Compliance will be retained by Agile for the period provided for by specific statutory obligations or by applicable law.

Personal Data processed in order to prevent Abuse/Fraud will be retained by Agile for the time strictly necessary for the aforesaid purpose and thus until such time as Agile is required to retain it in order to defend itself in legal proceedings or to disclose such data to the competent Authorities.

You have the right to ask Agile, at any time, for:

– access to your Personal Data (or a copy of such Personal Data), as well as further information on the processing carried out thereon;

– the rectification or updating of your Personal Data processed by Agile, where incomplete or not up to date;

– the erasure of your Personal Data from Agile's databases;

– the restriction of the processing of your Personal Data by Agile;

– to obtain, in a structured, commonly used and machine-readable format, the Personal Data concerning you;

as well as, you may:

– object to the processing of your Personal Data by Agile (e.g., Soft Spam, Survey, Improvement of the User Experience, Audience Expansion and Personalization);

– withdraw your consent for the Marketing purpose.

You may withdraw your consent to Marketing sent by email and stop receiving Soft Spam by using the dedicated link found at the bottom of every email received. The same method may be used to stop receiving Agile's newsletter, where you had requested it as a Service.

Consent to profiling through cookies may be withdrawn at any time by following the instructions set out in paragraph 2.f of this Notice.

In addition to the foregoing, you may also exercise your rights by writing to Agile at the following address: privacy@agiletelecom.com.

In any event, you always have the right to lodge a complaint with the competent Supervisory Authority (Garante per la Protezione dei Dati Personali) should you believe that the processing of your Personal Data is contrary to the law in force.

This privacy policy is in force as of 10/07/2026. Agile reserves the right to modify or simply update its content, in whole or in part, including as a result of changes in applicable law. Agile will inform you of such changes as soon as they are introduced, and they will become binding as soon as they are published on the Digital Tools. Agile therefore invites you to visit this section regularly in order to be aware of the most recent and up-to-date version of the privacy policy, so as to remain constantly informed about the data collected and the use that Agile makes of it.