Privacy Policy — AI Readiness Assessment

Privacy Policy for Personal Data Processing

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AI Readiness Assessment — Online Questionnaire

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)

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1. Data Controller

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HT-X S.r.l. Registered office: Trieste, Italy Email: hello@ht-x.com Website: https://ht-x.com

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2. Data Collected

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Through the AI Readiness Assessment questionnaire, we collect the following categories of data:

• Company identification data: company name, industry, company size
• Professional data: respondent’s role, description of work activities
• Operational needs data: problems, inefficiencies, past attempts, data management constraints
• Contact data (optional): email address, availability to be contacted

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3. Purposes and Legal Basis

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The collected data is processed for the following purposes:

a) Generation of the personalized AI Readiness report Analysis of responses to produce a PDF report with your company’s positioning regarding AI adoption. Legal basis: consent of the data subject (Art. 6(1)(a) GDPR).

b) Statistical and research purposes Aggregated and anonymized analysis of responses to produce statistics on the level of AI adoption in businesses, industry benchmarks, and research reports. Data used for statistical purposes does not allow identification of the data subject. Legal basis: consent of the data subject (Art. 6(1)(a) GDPR).

c) Commercial purposes The data may be used by HT-X S.r.l. to contact the data subject in order to propose consulting services, AI solutions, and activities related to the needs identified in the questionnaire. This purpose applies exclusively where the data subject voluntarily provides an email address or requests to be contacted. Legal basis: consent of the data subject (Art. 6(1)(a) GDPR).

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4. Use of Generative AI Tools

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The analysis of responses and the generation of the report may involve the use of generative artificial intelligence tools. In any case:

• Data is processed exclusively on infrastructure located within the European Union
• No data transfers to third countries are carried out
• The AI models used operate in secure mode and data is not used for training third-party models

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5. Data Retention

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• Questionnaire data: retained for a maximum of 24 months from completion
• Aggregated statistical data: retained indefinitely in anonymized form
• Contact data for commercial purposes: retained for a maximum of 12 months, unless consent is renewed

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6. Data Sharing and Disclosure

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Personal data is not shared with third parties. It may be processed by:

• IT service providers acting as data processors, exclusively within the EU
• Authorized personnel of HT-X S.r.l.

Aggregated and anonymized data may be published in reports, presentations, or articles for informational purposes.

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7. Data Subject Rights

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As a data subject, you have the right to:

• Access your personal data (Art. 15 GDPR)
• Rectification of inaccurate data (Art. 16 GDPR)
• Erasure of data (“right to be forgotten”, Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Object to processing (Art. 21 GDPR)
• Withdraw consent at any time, without affecting the lawfulness of processing based on consent given before withdrawal

To exercise your rights, write to: hello@ht-x.com

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8. Complaints

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You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) (www.garanteprivacy.it).

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9. Nature of Data Provision

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Completing the questionnaire is voluntary. Refusal to provide data makes it impossible to generate the AI Readiness report. Providing an email address is optional and does not affect report generation.

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Last updated: March 2026