Privacy Policy of Pagino
Effective Date: July 18, 2025
This policy describes how eDisplay srl, as Data Controller, collects, uses, and protects users' personal data ("User", "you", "your") through the software as a service "Pagino" (the "Service"), in compliance with Regulation (EU) 2016/679 (GDPR).
1. Data Controller
The Data Controller is:
eDisplay srl
Registered Office: Viale del Lavoro, 53 - 08023 Fonni (NU), Italy
VAT Number: 01172340919
Contact Email: info@edisplay.it
2. Types of Data Collected
We collect various types of personal data to provide and improve our Service.
a) Data voluntarily provided by the User
Registration Data: When you create an account, we collect: first name, last name, email address, phone number, website, and company name.
Billing Data: For managing credit purchases and tax obligations, we collect data necessary for invoicing, such as address, VAT number, and/or Tax ID.
Data entered for Content Generation (Prompts): We collect the texts and instructions (prompts) you enter into the platform to allow artificial intelligence models to generate email templates. You acknowledge that these prompts may contain personal data and assume responsibility for processing such data in accordance with applicable regulations.
b) Data collected automatically during Service use
Usage and Log Data: We collect information about how you interact with the Service, including IP addresses, error logs, and features used. This data helps us monitor security, resolve technical issues, and improve the platform.
Cookies and Similar Technologies: We use cookies to ensure the proper functioning of the Service and to analyze traffic. In particular:
- Technical Cookies: Essential for authentication, session management, and service provision.
- Analytical Cookies: We use the Matomo platform, configured to respect user privacy, to collect aggregated statistical data on website usage, in order to understand and improve the user experience.
3. Purposes and Legal Basis of Processing
We process your personal data for the following purposes and on the basis of the following legal conditions:
| Purpose of Processing | Data Processed | Legal Basis |
|---|---|---|
| Service Provision | Registration Data, Usage Data, Prompts | Performance of a contract (Art. 6.1.b GDPR) |
| Payment and Billing Management | Registration Data, Billing Data | Performance of a contract and Legal Obligation (Art. 6.1.b, 6.1.c GDPR) |
| Service Improvement and Security | Usage and Log Data | Legitimate Interest (Art. 6.1.f GDPR) |
| Service Communications | Email address | Performance of a contract (Art. 6.1.b GDPR) |
| Marketing and Newsletter | Email address | Specific consent (Art. 6.1.a GDPR) |
For marketing activities, you will be asked for explicit and separate consent, which you can revoke at any time.
4. Data Sharing and Third Parties (Data Processors)
We do not sell your personal data. We share data only with carefully selected third-party providers, acting as Data Processors on our behalf, solely for the purpose of providing the Service.
The main providers with whom we share data are:
Artificial Intelligence Model Providers: To generate email templates, the prompts you enter are sent via API to one or more of the following AI technology providers: Anthropic, OpenAI, Google, Grok, Replicate.com (managed via the OpenRouter aggregator).
IMPORTANT: We have configured the interaction with these providers so that the data sent via their APIs is not used to train or improve their artificial intelligence models.
Cloud Infrastructure and Hosting Providers: Our services are hosted on servers provided by DigitalOcean and PythonAnywhere. The servers are located within the European Union, ensuring an adequate level of data protection.
Payment Processor: For secure payment management, we use Stripe. We do not store your full credit card details on our servers. We invite you to consult Stripe's privacy policy.
5. Data Retention
We retain personal data for the time strictly necessary to achieve the purposes for which they were collected.
Account Data and Generated Templates: Your account data and the templates you create are retained as long as your account is active. In case of prolonged inactivity or account deletion, the data will be stored for a maximum period of 1 year to allow for possible reactivation, after which they will be anonymized or deleted.
Billing Data: Will be retained for the period required by tax and accounting regulations (generally 10 years).
Usage and Log Data: Are retained for a maximum period of 1 year for security and analysis purposes, after which they are deleted or anonymized.
6. Data Subject Rights
As a data subject, you have the right to:
- Access (Art. 15 GDPR): Request confirmation as to whether or not personal data concerning you are being processed and obtain access to your data.
- Rectification (Art. 16 GDPR): Obtain the correction of inaccurate personal data.
- Erasure ("Right to be forgotten", Art. 17 GDPR): Obtain the erasure of your data, in the cases provided by law.
- Restriction of processing (Art. 18 GDPR): Obtain the restriction of processing.
- Data portability (Art. 20 GDPR): Receive personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format.
- Objection (Art. 21 GDPR): Object at any time to the processing of your data for marketing purposes or based on legitimate interest.
- Withdraw consent: Withdraw consent for marketing purposes at any time, without affecting the lawfulness of processing based on consent given before its withdrawal.
To exercise your rights, you can send a request to the email address: info@edisplay.it
7. Right to Complain
If you believe that the processing of your personal data violates the provisions of the GDPR, you have the right to lodge a complaint with the competent supervisory authority (for Italy, the Garante per la Protezione dei Dati Personali) or to take appropriate legal action.
8. Changes to this Policy
We reserve the right to update this privacy policy. Any changes will be communicated via email or through a notice on the platform.