Privacy notice under Regulation (EU) 2016/679 (GDPR) and Italian Legislative Decree 196/2003, as amended by Legislative Decree 101/2018. Last updated: 31/07/2026.
1. Data Controller
H.0.ME. S.r.l. — Via Ferdinando Iannaccone 4, 83100 Avellino (AV), Italy. VAT no. 08308640724. Email: info@h0me.it. The Data Controller may be contacted for any matter relating to the processing of personal data at the address indicated above.
2. Categories of data processed
- Contact data provided voluntarily through the contact form (name, email, telephone, message, service of interest).
- Email provided to subscribe to the newsletter.
- Content of conversations with the H0Mer virtual assistant (text of the messages sent in the chat).
- Navigation data collected automatically by the systems (server logs, IP addresses, browser type), for security and operational purposes. Self-hosted Matomo also produces aggregate statistics on pages visited, source and technical device characteristics; it uses no cookies, User ID or profiling and masks two bytes of the IP address.
3. Purposes and legal bases
- Responding to requests sent through the contact form — legal basis: pre-contractual measures and legitimate interest (Art. 6.1.b/f GDPR).
- Sending the newsletter — legal basis: consent of the data subject (Art. 6.1.a GDPR), revocable at any time.
- Operation of the H0Mer virtual assistant — legal basis: legitimate interest in providing informational assistance (Art. 6.1.f).
- Security and proper functioning of the website — legal basis: legitimate interest (Art. 6.1.f).
- Aggregate website usage statistics through self-hosted Matomo, to measure and improve content and performance — legal basis: legitimate interest (Art. 6.1.f), subject to the right to object.
- Improvement of the virtual assistant and anonymous statistics — conversations undergo an automated quality review, are then irreversibly anonymised and kept in that form for statistical analysis and to improve the service's answers; legal basis: legitimate interest (Art. 6.1.f).
4. Processing methods
Data is processed by electronic means, in compliance with technical and organisational security measures adequate to protect its confidentiality and integrity. Access is restricted to authorised personnel.
5. Recipients and external processors
Data may be processed, as processors or independent controllers, by suppliers providing services necessary for the operation of the website, including:
- Hosting provider (Aruba S.p.A.) — servers located within the European Union.
- Artificial intelligence service providers used by the H0Mer assistant (e.g. Google, OpenRouter): the messages sent in the chat may be processed by their systems.
- Email service for the management of requests and the newsletter.
Data is neither disseminated nor transferred to third parties for their own marketing purposes.
6. Transfer of data outside the EU
Some AI service providers may be established outside the European Union (e.g. the United States). In such cases, the transfer takes place on the basis of adequate safeguards pursuant to Art. 44 et seq. GDPR (e.g. standard contractual clauses or adequacy decisions). We recommend not entering sensitive personal data in the chat.
7. Retention period
Data is retained for the time strictly necessary for the purposes for which it is collected: contact data for the time needed to handle the request and the consequent obligations; newsletter data until consent is withdrawn; logs for the periods required by law; raw Matomo data for no more than 396 days, after which they are deleted and only aggregate statistics remain. At the end of these periods, data is deleted or anonymised.
The content of conversations with the virtual assistant is kept in identifiable form for a maximum of 72 hours, the technical time needed for quality review; within that period it is irreversibly anonymised (removal of the IP address and of any reference to names, contact details, addresses and identifying details, with the text rewritten in general form) and the original text is deleted. Anonymised data do not allow the data subject to be identified and may be kept indefinitely for statistical purposes and to improve the service.
We also keep the geographic area of origin at region or country level, determined on our own server from an already truncated IP address that is never stored, without using any third-party geolocation service. Because of its level of detail, this information does not allow the data subject to be identified and is used for statistical purposes only.
8. Rights of the data subject
You have the right, at any time, to exercise the rights provided for in Art. 15-22 GDPR: access, rectification, erasure, restriction, objection to processing and data portability, as well as to withdraw the consent given. To exercise these rights, write to info@h0me.it.
9. Complaint to the Supervisory Authority
You have the right to lodge a complaint with the Garante per la protezione dei dati personali (the Italian Data Protection Authority) (Piazza Venezia 11, 00187 Rome — garanteprivacy.it) if you believe that the processing infringes the applicable legislation.
10. Cookies
For information on the use of cookies, please refer to the Cookie Policy.
11. Artificial intelligence (transparency — Reg. (EU) 2024/1689)
This site provides H0Mer, a conversational assistant based on generative artificial intelligence systems supplied by third parties (currently Google Gemini, with possible recourse to alternative models via OpenRouter). Pursuant to Article 50(1) of Regulation (EU) 2024/1689 (AI Act) we inform you that, when talking to H0Mer, you are interacting with an artificial intelligence system and not with a natural person: this information is also displayed inside the chat window, before the conversation begins. Replies are generated automatically, may contain inaccuracies and do not constitute professional advice, nor a contractual offer or a binding quotation: for technical and financial assessments please write to info@h0me.it. No automated decisions producing legal effects on individuals within the meaning of Article 22 GDPR are taken. Please do not enter sensitive or confidential personal data in the chat. Conversations are in any case subject to an automated quality review and are then irreversibly anonymised: see Art. 7 for retention periods.
12. Changes
The Data Controller reserves the right to update this notice; changes will be published on this page together with the relevant update date.