Privacy Policy
Last updated: March 2026
This Privacy Policy describes how HTX S.r.l. (“HTX”, “we”, “us”) collects, uses, and protects your personal data when you visit our website ht-x.com or use our services, in compliance with Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) and Italian Legislative Decree 196/2003 as amended.
1. Data Controller #
HTX S.r.l. Via Flavia 23/1, 34148 Trieste (TS), Italy P.IVA: 01407090321 Share capital: EUR 72.000 i.v.
Contact:
- Email: hello@ht-x.com
- PEC: htx@pec.it
2. Types of data collected #
2.1 Website navigation data #
The website ht-x.com is hosted on GitHub Pages, a static hosting service. As a fully static site, HTX does not collect or have access to server logs related to website navigation. GitHub, Inc. may collect standard technical data (IP address, browser) according to its own privacy policy; HTX does not have access to such data.
We do not use Google Analytics, Facebook Pixel, or any third-party analytics or tracking tools. We do not collect website navigation data.
2.2 Contact data #
When you contact us via email at hello@ht-x.com, we collect the personal data you voluntarily provide, which may include:
- Name and surname
- Email address
- Company name
- Content of your message
2.3 Assessment data #
When you use our online assessment tool (available at /assessment/), we collect the information you voluntarily submit, which may include:
- Company name and industry
- Responses to assessment questions
- Contact details provided in the form
Assessment data is processed by our API at assessment.ht-x.com and stored on EU-based servers.
3. Legal basis for processing #
We process your personal data on the following legal bases (GDPR Art. 6):
| Data type | Legal basis | Reference |
|---|---|---|
| Contact data | Consent (your voluntary contact) | Art. 6(1)(a) |
| Assessment data | Consent (your voluntary submission) | Art. 6(1)(a) |
| Client service data | Contract performance | Art. 6(1)(b) |
| Assessment API logs | Legitimate interest | Art. 6(1)(f) |
Legitimate interest: The server hosting the assessment API (assessment.ht-x.com) records standard technical logs (IP address, timestamp, requests) for security and troubleshooting purposes. This processing is minimal and proportionate.
4. Data retention #
| Data type | Retention period |
|---|---|
| Assessment API logs | Per Hetzner Online GmbH retention policy |
| Contact data | Until the request is fulfilled, then deleted |
| Assessment data (responses, reports) | 24 months |
| Client data | Duration of contract + legal retention period |
After the retention periods expire, data is securely deleted or irreversibly anonymized.
5. Third parties and data processors #
We share your data only with the following service providers, strictly necessary for operating our services:
| Provider | Service | Location | Role |
|---|---|---|---|
| GitHub, Inc. | Website hosting (GitHub Pages) | Static files served globally via CDN | Hosting provider |
| Hetzner Online GmbH | Assessment API server | Germany (EU) | Infrastructure provider |
We do not share your data with marketing platforms, advertising networks, or data brokers.
6. International data transfers #
We do not actively transfer personal data outside the EU/EEA. Our website is hosted on GitHub Pages, which may serve static files from global CDN locations; however, since the site is fully static, no personal data is processed or stored at CDN level. Assessment data is processed and stored exclusively on EU servers (Hetzner, Germany).
7. Your rights #
Under GDPR Articles 15 to 22, you have the following rights regarding your personal data:
- Right of access (Art. 15) — obtain confirmation of whether your data is being processed and a copy of it
- Right to rectification (Art. 16) — request correction of inaccurate data
- Right to erasure (Art. 17) — request deletion of your data (“right to be forgotten”)
- Right to restriction (Art. 18) — request limitation of processing
- Right to data portability (Art. 20) — receive your data in a structured, machine-readable format
- Right to object (Art. 21) — object to processing based on legitimate interest
- Right to withdraw consent (Art. 7(3)) — withdraw consent at any time, without affecting the lawfulness of prior processing
8. How to exercise your rights #
You can exercise your rights at any time by contacting us at:
- Email: hello@ht-x.com
- PEC: htx@pec.it
We will respond to your request within 30 days, as required by GDPR Art. 12(3).
9. Right to lodge a complaint #
If you believe your rights have been violated, you have the right to lodge a complaint with the competent supervisory authority:
Garante per la protezione dei dati personali Piazza Venezia 11, 00187 Roma, Italy Website: www.garanteprivacy.it Email: garante@gpdp.it PEC: protocollo@pec.gpdp.it
10. Updates to this policy #
We may update this Privacy Policy to reflect changes in our practices or for regulatory reasons. Any changes will be posted on this page with an updated revision date. We encourage you to review this page periodically.