This notice explains how ALEPH DIGITAL INDUSTRY S.R.L. ("Aleph", "we") processes personal data in accordance with Regulation (EU) 2016/679 (the "GDPR") and the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended).
1. Data controller
ALEPH DIGITAL INDUSTRY S.R.L.
Registered office: Via Olivi 3, 31100 Treviso (TV), Italy
VAT IT04857100269 · Treviso Chamber of Commerce (REA) TV-404144
E-mail: support@aleph.solutions · Telephone: +39 0422 789611
Aleph has not appointed a Data Protection Officer, because it is not required to do so under Article 37 GDPR. Privacy requests can be sent to the e-mail address above.
2. Whom this notice covers
This notice applies to:
- visitors to www.aleph.solutions;
- people who contact us, request a demo, or subscribe to our newsletter;
- representatives and employees of our customers, prospective customers, partners and suppliers ("business contacts");
- users of our products and services, including customers who buy through the Siemens Xcelerator Marketplace.
Our products and services are intended for businesses. We do not knowingly collect data from children.
3. Personal data we process and where it comes from
| Category | Examples | Source |
|---|---|---|
| Contact and professional data | name, company, job title, business e-mail, telephone | you, your employer, our partners and agencies, public professional sources (such as LinkedIn and company websites) |
| Communication data | content of e-mails, messages, meeting notes, support requests | you |
| Contract and billing data | orders, subscriptions, invoices, VAT number, payment status | you, your employer, the Siemens Xcelerator Marketplace |
| Product account and usage data | user name, login events, audit-log entries, remote-support sessions | your use of our products |
| Technical website data | IP address, browser and device type, pages visited, time of access | your browser, through our website host |
| Marketing preferences | newsletter subscription, consent records, opt-outs | you |
We do not ask for, and do not want to receive, special categories of personal data (such as health data or political opinions) or data on criminal convictions.
Our products process machine and production data, such as counters, speeds and machine states. This data is not personal data. Where operating or supporting a product involves personal data of the customer's staff (for example user identifiers in audit logs), Aleph acts as processor on the customer's behalf, under a data processing agreement with the customer. In that case the customer's own privacy notice governs.
4. Purposes and legal bases
| Purpose | Legal basis (GDPR Article 6(1)) |
|---|---|
| Answering enquiries and demo requests | steps prior to a contract (b), or our legitimate interest in answering business enquiries (f) |
| Concluding and performing contracts, including Marketplace orders, licence delivery, support and invoicing | performance of a contract (b) |
| Accounting, tax and other legal obligations | legal obligation (c) |
| Business development: contacting business contacts about products relevant to their role | legitimate interest in promoting our business to professionals (f) |
| Newsletter and marketing e-mails | consent (a), or, for existing customers, our legitimate interest in promoting similar products (f), always with an opt-out |
| Operating and securing our website and products | legitimate interest in IT security and service reliability (f) |
| Establishing, exercising or defending legal claims | legitimate interest (f) |
Where we rely on legitimate interest, we have weighed it against your rights. You can object at any time (see section 9).
Where you are a business contact, you are not obliged to provide your data. Without the data needed for a contract or support request, however, we cannot conclude or perform it.
We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.
5. Recipients
We share personal data only as needed for the purposes above, with:
- service providers acting as our processors, under contracts that meet Article 28 GDPR. These cover e-mail, office software and cloud hosting, and our website and its forms. The current list is in the annex below.
- Siemens, as operator of the Siemens Xcelerator Marketplace, for orders placed there. Siemens acts as an independent controller under its own privacy notice.
- professional advisers, such as accountants, auditors and lawyers, under a duty of confidentiality;
- banks and payment service providers;
- public authorities, where the law requires it.
We do not sell personal data.
6. International transfers
Some service providers are located outside the European Economic Area, or may access data from there. Where this happens, we rely on one of the following:
- an adequacy decision of the European Commission, including the EU–US Data Privacy Framework for certified US companies;
- Standard Contractual Clauses approved by the European Commission, with supplementary measures where needed.
You can request information on the safeguards used by writing to us.
7. Retention
| Data | Retention |
|---|---|
| Contract, order and billing records | 10 years from the end of the financial year, as required by Italian law (Article 2220 Civil Code) |
| Support requests and product audit logs | for the duration of the contract, then up to 2 years |
| Business-development contacts with no active relationship | 24 months from the last interaction, unless you ask us to delete them earlier |
| Newsletter subscription | until you unsubscribe or withdraw consent |
| Technical website logs | up to 12 months |
Data needed to defend legal claims may be kept for the applicable limitation period.
8. Security
We protect personal data with technical and organisational measures appropriate to the risk. These include access control, encryption in transit, and the security controls of our hosting providers. No transmission over the internet is completely secure. If you believe your data has been compromised, write to support@aleph.solutions.
9. Your rights
Under Articles 15 to 22 GDPR you have the right to:
- access your personal data and receive a copy;
- have inaccurate data corrected;
- have your data erased, where the conditions of Article 17 apply;
- restrict processing;
- receive your data in a portable format, where processing is based on consent or contract and carried out by automated means;
- object at any time to processing based on legitimate interest, and to direct marketing;
- withdraw consent at any time, without affecting processing carried out before the withdrawal.
To exercise these rights, write to support@aleph.solutions. We answer within one month. We may ask you to confirm your identity.
You also have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it), or with the authority of the EU country where you live or work.
10. Cookies
Our website uses technically necessary cookies only, which do not require consent. If we introduce analytics or marketing cookies, we will ask for your consent first and update this notice.
11. Changes to this notice
We may update this notice. The version and effective date are shown at the top. Significant changes will be announced on this page.
Annex: service providers (processors)
| Provider | Service | Location of processing |
|---|---|---|
| Microsoft Ireland Operations Ltd | e-mail, office software, cloud hosting (Microsoft 365, Azure) | EU/EEA |
| Webflow, Inc. | website hosting and web forms | United States |