Effective Date: [February 22, 2025]
The data controller processing personal data collected through this platform is ASC27 S.r.l. an Italian incorporated under the laws of the Republic of Italy whose registered address is Via Tirso, 14, Rome, Italy
All personal data collected and processed through this platform are processed with the General Data Protection Regulation (GDPR) and other applicable data protection laws within the European Union or in countries for which an adequacy decision has been issued or for which standard clauses approved by the European Commission are in force.
Queries and prompts entered by users for the purpose of improving the LLM are not associated with the identity of the user who submitted them. Consequently, no user data are injected into the model. However, to ensure the integrity and lawful use of the platform, the association between queries, prompts, and users is retained separately and securely. This last information may be used exclusively for the following purposes:
Users are strictly prohibited from entering any third-party personal data into the platform without obtaining the specific, informed, and documented authorisation of the data subjects concerned, including consent for the potential use of such data for model improvement purposes.
Personal data collected to enable the use of the platform and for billing purposes are processed in accordance with the relevant legal obligations, including tax and accounting regulations. Such data are retained for the periods prescribed by applicable laws.
Access to the platform is authenticated either through Google or, at the user’s choice, internally by the data controller.
When using Google authentication, users acknowledge that Google acts as an autonomous data controller and may collect additional information during the authentication process. The collection and processing of such data are subject to Google’s privacy policy and terms of service, and the data controller is not involved in or responsible for these processing activities.
The email confirming the registration through the local platform is sent by a smart SMTP service, which does not retain any personal information.
Personal data collected and processed for the protection of the company’s rights are retained for the duration of the applicable statute of limitations. Personal data used to improve the LLM are retained indefinitely to provide evidence of the data processing activities in case of regulatory investigations or legal proceedings.
Processing of personal data is based on one or more of the following legal grounds:
Consent is not required for the processing of personal data necessary to fulfill contractual or legal obligations or to initiate or defend against legal actions.
Additionally, the use of anonymised prompts and queries for improving the LLM does not require user consent, however the user can deny the authorization to this processing purpose.
Users have the following rights under the GDPR:
The data subject may exercise his or her rights by sending a registered letter with return receipt to the registered office of the data controller.
If the request is formally correct, the Data Controller shall respond to the data subject within thirty working days of receiving the request, unless the decision requires more time to be taken. In this case, the Data Controller shall inform the data subject of the need for a longer period of time and, if possible, quantify it.
Within the aforementioned deadline, the Data Controller shall communicate the decision and the related motivation to the data subject, informing him/her of the ways in which it is possible to contact the ordinary Judge or the national Data Protection Authority.
The LLM is not designed to provide exact or reliable information about individuals and should not be used for this purpose. In any case, the LLM is not intended to generate responses regarding specific individuals
Appropriate technical and organisational measures are implemented to ensure the confidentiality, integrity, and availability of personal data, as well as to prevent unauthorised access, disclosure, alteration, or destruction.
This Cookie Policy explains how Vitruvian ("we," "our," or "us") uses cookies and similar technologies to recognize you when you visit our website [vitruvian.asc27.com] ("Website"). It explains what these technologies are, why we use them, and your rights to control their use.
Cookies are small text files that are stored on your device (computer, tablet, or mobile) when you visit a website. They help websites function properly, improve user experience, and provide analytical data.
We use the following types of cookies:
We use cookies to:
Some cookies are placed by third-party services we use, such as analytics tools (e.g., Google Analytics) and advertising partners. These third parties may collect information about your online activities over time and across different websites.
You can manage or disable cookies through your browser settings. However, disabling essential cookies may impact the functionality of the Website.
For more information on managing cookies, visit:
The data subject has the right to lodge a complaint with the Data Protection Authority in accordance with Legislative Decree no. 196/03 and the information provided on the website of the Data Protection Authority: www.garanteprivacy.it.
Alternatively, the data subject may lodge a complaint with the competent court.