Cogitek S.r.l. (hereinafter also "COGITEK" or the "Company") is committed to protecting the personal data entrusted to it. Therefore, the management and security of such data are guaranteed with the utmost care, in accordance with the requirements of privacy legislation, in full compliance with the principles of lawfulness, correctness and transparency.

In accordance with the legal provisions in force regarding privacy (in particular EU Regulation 679/2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data), this notice explains who the Data Controller is, for what purposes COGITEK may use the data conferred, how it will manage it, to whom it may be communicated, where it may be transferred and what the data subject's rights are.


The data provided will be processed, as Data Controller, by COGITEK, with registered office in Via Fregene, 14 - 00183 Rome (RM) - ITALY.


The personal data collected both on paper and electronically and subject to processing are related to:

  • identification, administrative, accounting, fiscal and commercial data of interested parties (such as members of the corporate bodies, employees, personnel of third parties with whom the Customer has a business relationship);
  • credit card data;
  • User/password access to programmes (e.g. adwords, facebook, linkedin).

These data, which the Customer is legitimately in possession of, are provided by him in the execution and performance of pre-contractual/contractual relations with the Owner.

The data may be processed for the following purposes:

A. sending quotes to companies/individuals who are already Customers/potential Customers;
B. execution of services requested by Customers;
C. monitoring of receipts;
D. compliance with legal obligations (e.g. accounting and tax obligations);
E. exercise of the right of defence of the Data Controller;
F. sending of communications - commercial information (e.g. newsletters, invitations to events, ways of obtaining a gadget or a promotion) to Customers - suppliers/potential Customers - suppliers of COGITEK Customer companies, in the case of data acquired directly from the Company (e.g. through landing pages);
G. sending of communications - commercial information (e.g. newsletters, invitations to events, other commercial information) to Customers/potential Customers of COGITEK.


La Società effettuerà il trattamento dei dati di cui ai precedenti punti:

  • A., B. and C. because it is necessary for (i) the execution of pre-contractual activities for the development of a contractual proposal and (i) the execution of the services requested by the Customer;
  • D. because it is necessary to fulfil a legal obligation to which the Company is subject;
  • E. insofar as it is necessary for the pursuit of the Company's legitimate interest in protecting its rights in the event of legal disputes;
  • F. and G. on the basis of the Client's consent; the Client is always entitled to revoke his/her consent, by the means provided for in the following paragraphs.

The provision of data for the purposes:

  • A., B., C. and E. is necessary for the performance of contractual and/or pre-contractual activities by the Company;
  • D. is compulsory and any refusal by the data subject will make it impossible for the Company to pursue the purposes described in the previous paragraph;
  • F. and G. is optional, however, failure to provide such data will make it impossible for the Company to pursue the purposes indicated.

The extent and adequacy of the data provided will be assessed from time to time in order to determine the consequent decisions and to avoid the processing of data in excess of the purposes pursued.

The Company undertakes not to use the personal data provided for purposes other than and in addition to those described in this information notice, without first informing the person concerned and, where necessary, obtaining his/her consent.


The data processing is carried out by means of computer procedures or, in any case, telematic means or paper supports, with logics strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security of the same and always in compliance with the relevant legislation in force, in particular with EU Regulation 679/2016.

The data will also be:

  • processed by Company resources, adequately trained and committed to confidentiality, who act as authorised personnel for data processing;
  • stored with instruments suitable to guarantee its security, integrity and confidentiality, through the adoption of adequate security measures as provided for by the regulations.


With reference to the processing for the purposes of:

  • A., B., C., D. and E., the Company will process personal data for the time necessary to fulfil these purposes and, in any case, for a period not exceeding 10 years from the termination of the last contractual relationship with the Customer. The data may also be kept beyond this period in relation to the possible need to use them in court in case of disputes, or in any other case in which the legitimate interest of the Company prevails over the interests or fundamental rights and freedoms of the data subject;
  • F. and G., the data will be retained until the data subject revokes his/her consent by the means made available by the Company for this purpose.


The data collected will not be disclosed or disseminated outside the Company.

The data may be communicated, by virtue of the evolution of the relationship with the Customer to:

  • public entities, in order to fulfil legal obligations or to exercise the Company's rights (e.g. the right to defence in court);
  • subjects and private entities established within the Italian state appointed, through contractual agreements, to carry out services (technical support, computer and administrative/accounting) closely related to the purpose for which the data are provided by the person concerned.

The Company informs that, should the evolution of its organisation or agreements with new suppliers make it necessary to transfer the data outside the European Union, such transfer will take place in accordance with the applicable legal provisions (art. 45 paragraph 1 of the GDPR, Transfer on the basis of an adequacy decision, or art. 46, Transfer subject to adequate safeguards).


Please note that the EU Regulation 679/2016 (in particular, Chapter III thereof) recognises certain rights of the data subject, for the exercise of which the same may contact the Company, by writing to Cogitek S.r.l., Via Fregene, 14 - 00183 Rome (RM) - ITALY or proceeding by email to

In particular, these rights are set out in the GDPR at articles:

  • 13, Information to be provided where personal data is collected from the data subject. In particular, we highlight what is indicated in paragraph 2. point d) regarding the right to lodge a complaint with the Guarantor of the protection of personal data;
  • 15, Right of access of the data subject;
  • 16, Right of rectification;
  • 17, Right to erasure ("right to be forgotten");
  • 18, Right to restriction of processing;
  • 19, Obligation to notify in case of rectification or erasure of personal data or restriction of Processing;
  • 20, Right to data portability;
  • 21, Right to object;
  • 22, Automated decision-making process concerning natural persons, including profiling.

The Data Controller shall endeavour to take charge of the data subject's request with the utmost commitment to ensure the effective exercise of his/her rights.


Any further information regarding the processing of personal data and this information notice may be requested by writing to Cogitek S.r.l., Via Fregene, 14 - 00183 Rome (RM) - ITALY or by e-mail at


This information notice may be subject to changes and additions, also as a consequence of the updating of the applicable legislation on the protection of individuals with regard to the processing of personal data and the free movement of such data. The text of the most up-to-date information notice is available on the website

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