Privacy Policy – XTalk (Xtremecloud srl)
This Privacy Policy is provided in accordance with Article 13 of EU Regulation 2016/679 (General Data Protection Regulation – GDPR) and describes how Xtremecloud srl processes personal data collected through its website, platform, mobile applications, and AI-based services.
I. Data Controller
The Data Controller is Xtremecloud srl, represented by Joshua Colombo, headquartered at Via Giovanni Prati, 14 – 38056 Levico Terme (TN), Italy.
📧 For any inquiries: info@xtalk.it
II. Types of Personal Data Collected
A. Data collected via registration or platform use
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Full name
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Email address
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Company / VAT number
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Tax ID
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Address
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Date of birth
B. Data collected via contact forms
Data entered in contact forms (e.g., name, email, subject, message) is processed exclusively for the purpose of responding to the submitted request. It will not be used for promotional purposes unless explicitly authorized.
C. Data collected automatically
Technical data may be collected while browsing the site:
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IP address
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Browser type
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Visited pages
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Access date and time
III. Use of Cookies
The website may use:
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Technical cookies: essential for site operation
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Analytical cookies (e.g., Google Analytics): only with consent, in anonymous form
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Third-party cookies: not in use
Users can manage or revoke consent via the cookie banner or browser settings.
See the Cookie Policy for more details.
IV. Purpose and Legal Basis of Processing
Personal data is processed to:
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Provide the services requested
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Create and manage accounts
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Respond to user inquiries
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Send service notifications
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Provide customer support
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Send promotional emails (only with explicit consent)
Legal basis: contract, consent, legal obligation.
V. Processing Method and Location
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Data is processed using automated tools with adequate technical and organizational safeguards.
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Stored on servers located within the European Union.
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Access is restricted to authorized personnel and third parties under data processing agreements.
VI. Data Sharing
Data may be shared with:
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Telecom operators (within the EU)
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Trusted cloud and infrastructure providers
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AI/transcription partners (e.g., OpenAI, Google)
No data is shared with third parties for advertising purposes.
VII. Data Retention
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Data is retained for the time necessary to fulfill its purposes.
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Personal data is deleted upon account closure.
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Anonymous data may be stored for service improvement.
VIII. Data Subject Rights
Under Articles 15–21 of the GDPR, you may:
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Access your personal data
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Correct or update your data
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Request erasure (“right to be forgotten”)
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Restrict or object to processing
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Request data portability
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Revoke your consent
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File a complaint with the supervisory authority
Requests can be sent to info@xtalk.it and will be processed within 36 hours.
IX. Data Processing via Mobile Apps (Android and iOS)
This section applies to users of the XTalk mobile app available on the Google Play Store and Apple App Store.
A. Data collected via the app
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Device identifiers (Android ID, IDFA)
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Usage data (logs, crash reports)
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Microphone access (for voice features)
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Contacts and call metadata (if authorized)
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Location data (optional)
B. App permissions
Android:
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Microphone, contacts (optional), phone state, storage, location (optional)
iOS:
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Microphone, contacts (optional), push notifications
XTalk does not use IDFA for advertising or profiling purposes.
C. Purpose of processing
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Manage calls, chat, voice assistant, and routing
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Integrate with calendar and contacts
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Improve service performance
X. AI Services and Conversational Intelligence
XTalk includes AI modules to deliver advanced conversational services.
A. Data processed by AI
B. Purpose
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Natural language understanding
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Personalized and contextual response generation
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Request routing
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Conversation summarization
C. AI providers
Depending on the configuration, XTalk may use:
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OpenAI
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Google Cloud AI
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Anthropic Claude
All providers operate under GDPR compliance and EU data protection safeguards (e.g., SCCs).
D. Safeguards
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Data is processed only temporarily
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Anonymization where applicable
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Access is restricted and monitored
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No AI profiling for advertising
E. User rights
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Users may request human intervention
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Right to opt-out of automated decision-making
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Full rights under GDPR apply
XI. Children’s Privacy
The app and services are not intended for children under 13. We do not knowingly collect personal data from minors.
XII. Policy Updates
This policy may be updated due to legal or functional changes. Users will be notified in the event of significant changes.
XIII. Contact
📧 For any request regarding your personal data:
info@xtalk.it
