PRIVACY POLICY (“CHATBOT”)

DATA CONTROLLER

Regensburger Allee 9, 39042 Bressanone
+39 0472 27 52 22
info@brixen-suedtirol.com 

PRIVACY INFORMATION

This Privacy Policy explains how personal data is processed in connection with the use of the chatbot provided by the Consortium Brixen South Tyrol – Dolomites Italy on www.brixen-suedtirol.com (“Website”) and the use of the chatbot “Brixi” (“Chatbot”), in accordance with Regulation (EU) 2016/679 (“GDPR”).

It supplements the general privacy policy applicable to visitors of the Website. We also recommend reading the general privacy policy in order to obtain a complete overview of all data processing activities.

The chatbot “Brixi” is intended exclusively to provide users with quick, accessible, and interactive access to various information available on the Website. Any use for purposes other than those agreed upon is excluded.

The use of our chatbot requires acceptance of this Privacy Policy.

1) Data Collected and Processing within the Chatbot

1a) Interaction Content

All messages sent or received through the chatbot are processed in order to enable the dialogue. We kindly ask you never to enter personal data that could identify you or another person. This also includes contact details, addresses, tax identification numbers, and similar information. The provision of personal data is neither contractually nor legally required and is not necessary for the functionality of the chatbot. You will not suffer any disadvantages if you choose not to provide such information. As recommended, we ask you not to disclose any identifying information.

1b) Special Categories of Personal Data

As already described under “Interaction Content”, we also kindly ask you never to provide sensitive data such as health-related information.

1c) System and Access Information

In order to provide and securely operate the chatbot “Brixi”, various technical information is automatically collected. This includes, among others, a randomly generated pseudonymous client ID, browser data (e.g. version and language), date and time of access, configured time zone, and information about the operating system of the device used. In addition, the so-called referrer URL (i.e. the page from which the chatbot was accessed) as well as technical log and protocol data are collected.

1d) Voluntary Rating of Responses and Chatbot Evaluation

If you choose to rate the chatbot responses and thereby help improve the chatbot, for example through thumbs up/thumbs down feedback, this information will also be collected and used for chatbot improvement purposes.

1e) Processing Methods and Cookies

This chatbot uses the following cookies:

• Chat-Key: A number identifying the chat session itself in order to preserve the chat history (e.g. when switching browser windows).
  Storage duration: 3 days
• Chat-ClientID: Randomly generated client ID per user to make chats traceable. Without additional information, it cannot be linked to a specific individual (pseudonymous data).
  Storage duration: 1 year
• Chat-Privacy: Created once the privacy policy has been accepted within the chat.
  Storage duration: 7 days

Legal basis: Art. 6(1)(f) GDPR (legitimate interests in ensuring a useful and efficient user experience).

2) Purposes of Processing and Data Sharing

2a) Data Recipients, Data Processors and Data Transfers

This chatbot uses the language model provided by OpenAI (“ChatGPT”).
Headquarters: 3180 18th St, San Francisco, California 94110, USA. By default, processing takes place through the data center in Ireland:
The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland.

This provider does not receive any information or personal data relating to users or chat content.

Legal basis: legitimate interest pursuant to Art. 6(1)(f) GDPR.

2b) Operational Security, Stability and Maintenance

As part of ongoing operations, we automatically collect technical and network-related data for troubleshooting, technical support, system testing, security monitoring, and performance monitoring purposes. The collected data is generally evaluated only in aggregated or anonymized form. Legal basis: Art. 6(1)(f) GDPR.

2c) Quality Assurance, Content Updates and Reporting

To ensure content quality, selected excerpts of conversations may be used exclusively after the removal of all identifying information. Legal basis: Art. 6(1)(f) GDPR. Should personal data nevertheless be provided, this shall be considered consent pursuant to Art. 6(1)(a) and/or Art. 9(2)(a) GDPR.

2d) Compliance with Legal Obligations

For the protection of our rights and to comply with legal obligations, personal data may be disclosed to public authorities. Legal basis: Art. 6(1)(c) GDPR. External suppliers (e.g. IT service providers) may, where necessary, gain access to personal data and have been appointed as data processors in accordance with Art. 28 GDPR.

3) Rights of Data Subjects

As a user of the chatbot “Brixi”, you are entitled to the rights set out in Articles 15 to 21 GDPR, provided that personal data has been supplied and chat content could be attributable to you.

• Right to withdraw consent – You may withdraw your consent at any time.
• Right of access – You may request information about the processing of your personal data (Art. 15 GDPR).
• Right to rectification – You may request correction or updating of inaccurate data (Art. 16 GDPR).
• Right to erasure – You may request the deletion of your data unless legal obligations prevent this (Art. 17 GDPR).
• Right to restriction – You may request restriction of processing (Art. 18 GDPR).
• Right to data portability – You may receive your data in a machine-readable format or request its transfer to another controller (Art. 20 GDPR).
• Right to object – You may object to processing activities based on legitimate interests (Art. 21 GDPR).

You also have the right to lodge a complaint with a data protection authority. In Italy: “Garante per la protezione dei dati personali”.

4) Use by Minors

The use of this chatbot is not intended for minors. Persons under 18 years of age are not permitted to use the chatbot.

5) Changes to this Privacy Policy and Questions/Clarifications

This privacy information notice may be updated at any time. For any questions, please contact us using the contact details provided above.