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Privacy Policy - Digital assistant "Sportellino"

Last updated: 16 October 2026

This notice under Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) covers sportellino.it, the Sportellino digital assistant and communications with the association. The digital assistant provides information and guidance; it does not make decisions about permits, benefits, housing or other rights. Under the Terms and conditions, the service is for adults residing in the European Union.

1. Who handles your data

The controller is Associazione Buonsenso, a nonprofit association without legal personality under Italian law, with its registered office at Via Casilina 3, 00182 Rome, Italy, Italian tax code 96657510580. For information, personal support and privacy requests: info@sportellino.it. The registered office is not advertised as a public help desk: personal support is requested exclusively by email.

2. Access and data processed

You do not need to create a Sportellino account to start the web chat. This does not mean the conversation is anonymous. We process your messages, technical session identifiers and data needed for operation and security, such as IP address, device information and interaction dates and times. Information in your questions may identify you. If you use WhatsApp, your phone number and profile information made available by that channel may also be processed.

If you contact us by email or a form, we process your contact details, request and any attachments you choose to send. For the newsletter, we process your email address and the information needed to manage your subscription and choice.

Ask questions in general terms. Do not send identity documents, tax codes, health information, other sensitive information or other people’s data unless necessary. Merely reading or accepting this notice is not explicit consent to the processing of special categories of personal data. Any necessary processing of such data requires a specific legal basis under Article 9 GDPR and, where required, separate consent.

3. Purposes and legal bases

  • Digital assistant and requested assistance: processing questions, providing answers and managing contact requests; Article 6(1)(b) GDPR, to the extent necessary to provide the requested service.
  • Operation and security: maintaining the service, identifying errors and preventing abuse; the controller’s legitimate interest under Article 6(1)(f), with respect for users’ rights.
  • Newsletter and optional tools: consent where required, Article 6(1)(a). Newsletter subscription is optional and is not required to use the digital assistant. Withdraw it using the unsubscribe link or by emailing info@sportellino.it.
  • Legal obligations and protection of rights: Article 6(1)(c) and, where applicable, Article 6(1)(f).

Conversations with Sportellino are used exclusively to respond to users’ requests. Conversation content is not used to train, fine-tune or improve artificial intelligence models. AI processes messages to generate the requested answer; this is separate from model training. We cannot process a request without the technically necessary data. Newsletter subscription and optional consent remain separate.

4. Retention and deletion

Conversation content is kept for six months from collection and then deleted. Any longer retention is limited to data necessary for a specific legal obligation or for establishing, exercising or defending a legal claim, for the time actually needed. Chats are not subject to a general ten-year retention period.

You can request earlier deletion at info@sportellino.it. State which channel you used and provide the minimum information needed to locate the conversation. Deleting a conversation from your device does not necessarily delete it from the service’s systems.

Support correspondence is kept for the time needed to handle the request and follow-up. Newsletter data is kept until you unsubscribe or withdraw consent, except information needed to document and respect your choice. Technical data is kept as necessary for operation and security; data subject to legal retention obligations follows the applicable periods.

5. Providers, external channels and security

Data may be processed by authorised personnel and providers needed to deliver the service, including hosting, technical infrastructure, AI processing and communications providers. When acting on the association’s behalf, they are appointed as processors under Article 28 GDPR. Data may also be disclosed to authorities when required by law. We do not publish conversations or supply personal data for third-party marketing.

WhatsApp and other external services also apply their own privacy notices to their processing. See, for example, the WhatsApp Privacy Policy. Any transfers outside the European Economic Area must comply with Chapter V GDPR, using an adequacy decision or other applicable safeguards, such as standard contractual clauses. Ask info@sportellino.it for details of the providers involved and the safeguards.

We adopt technical and organisational measures proportionate to the risks and restrict access to authorised people. The web connection uses HTTPS. Do not send confidential information that is unnecessary for the service.

6. Cookies and website tools

The site may use technical cookies and, depending on your choices, measurement tools or third-party content. Purposes, providers, durations and preferences are described in the cookie policy available on the site and the consent settings panel. You can change your preferences in that panel. Consent to optional tools is not required to request information by email.

7. Your rights

Where the GDPR provides, you may request access, rectification, deletion, restriction and portability, object to processing based on legitimate interests, and withdraw consent without affecting earlier lawful processing. Contact info@sportellino.it or Associazione Buonsenso, Via Casilina 3, 00182 Rome, Italy. We ask only for information necessary to verify the request. Do not attach an identity document unless we request it with a reason.

We respond without undue delay and within one month. If necessary, this may be extended by two further months, with reasons and notice within the first month. You may complain to the Italian Garante per la protezione dei dati personali or the competent authority where you live or work. Updates to this notice are published here with their date.