Privacy Policy

Privacy notice pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”)

1. Data Controller

The Data Controller is:

EquiUp S.r.l.
Via Vittorio Emanuele III, 79
73016 San Cesario di Lecce (LE) – Italy
Email: info@equiup.it

EquiUp processes users' personal data in accordance with Regulation (EU) 2016/679 (“GDPR”), Italian Legislative Decree 196/2003, as amended by Legislative Decree 101/2018, and the applicable personal data protection legislation.

2. Personal Data Processed

When using the website, EquiUp services and related features, various categories of personal data may be collected and processed, including:

  • identification and contact data provided by the user;
  • data required to register and manage the account;
  • data relating to orders, purchases and requested services;
  • technical and browsing data;
  • data relating to interactions with EquiUp;
  • preferences, interests and information relating to products or services viewed or requested;
  • data and information voluntarily entered by the user in conversations with the chatbot and AI-based services;
  • technical, session or user identifiers associated with use of the chat.

Users are requested not to enter unnecessary personal data in the chat and, in particular, special categories of personal data such as information concerning health, racial or ethnic origin, religious or philosophical beliefs, political opinions, sex life or sexual orientation, unless strictly necessary and permitted by applicable law.

3. Purposes and Legal Bases of Processing

EquiUp may process personal data for the following purposes:

a) Management of the website, account and requested services

Data is processed to enable registration, account management, the purchase of products or services, customer support and performance of obligations arising from the contractual relationship.

The legal basis is the performance of a contract or pre-contractual measures requested by the data subject under Article 6(1)(b) GDPR and, where applicable, compliance with legal obligations.

b) Use of the chatbot and Artificial Intelligence services

EquiUp provides users with a chat service that may use Artificial Intelligence systems.

When the user uses the chat, the content of the messages entered is transmitted exclusively to the servers and IT systems used and controlled by EquiUp for the provision of the service.

Together with the message, a user and/or session identifier may be processed where necessary to manage the conversation, maintain its context and correctly associate messages with the session.

The information may be processed through software infrastructures managed by EquiUp, including the n8n automation platform, and through Artificial Intelligence models running on infrastructures under EquiUp's control.

The content of conversations, users' personal data and other information processed through the chatbot are not transmitted, shared or made available to external providers of Artificial Intelligence models or to third-party Artificial Intelligence services.

Data processed through the chatbot is used exclusively for the provision and proper functioning of the service, to provide information about EquiUp products and services, user support, suggestions and personalised responses, as well as for security, maintenance and service improvement purposes, in compliance with applicable personal data protection legislation.

4. Recording and Retention of Conversations

Conversations conducted through the chatbot may be recorded and retained by EquiUp.

Retention makes it possible, among other things, to:

  • retain the context of conversations;
  • improve the quality and effectiveness of answers;
  • provide user support;
  • analyse use of the service;
  • identify users' interests and preferences, subject to consent where required;
  • improve and train the Artificial Intelligence systems used by EquiUp, subject to consent where required.

Conversations will be retained for 24 months, unless a longer period is necessary to comply with legal obligations, protect EquiUp's rights or manage requests and disputes.

Once this period has elapsed, conversations and related personal data will be deleted or anonymised so that the data subject can no longer be identified, without prejudice to any further retention obligations imposed by law.

In the cases provided for by law, users may request deletion of their conversations and related personal data by contacting EquiUp at info@equiup.it.

5. Use of Conversations to Improve and Train Artificial Intelligence

Subject to the user's consent where required by applicable law, EquiUp may use chatbot conversations to:

  • analyse the quality of answers;
  • identify errors and improve service operation;
  • develop new features;
  • create datasets intended to improve AI systems;
  • train, adapt, fine-tune or optimise the Artificial Intelligence models used by EquiUp.

Where technically possible and compatible with the purposes pursued, EquiUp will apply data minimisation, pseudonymisation or anonymisation techniques.

Any use of conversations by external AI model providers to train their own models depends on the contractual terms and configurations of the service used by EquiUp. If such use is envisaged, the user will be specifically informed and the conditions and legal bases required by law will apply.

6. Profiling

Subject to the user's specific consent, EquiUp may analyse browsing and purchase data, expressed preferences and interactions through the website and chatbot in order to create or update a user profile.

For example, chatbot conversations may reveal interests relating to products, equestrian disciplines, purchasing needs, preferred product categories and other preferences expressed by the user.

This information may be associated with the user's profile and used to:

  • personalise the experience on the website and in the chat;
  • suggest products or services that are more relevant to the interests expressed;
  • personalise offers and promotions;
  • segment users according to interests and preferences;
  • carry out personalised marketing activities, subject to consent.

The legal basis for commercial profiling is the data subject's consent pursuant to Article 6(1)(a) GDPR.

Providing consent is optional, and withholding it does not prevent use of the website, purchases or the chatbot's basic features.

Users may withdraw their consent to profiling at any time.

7. Marketing

Subject to the user's express consent, EquiUp may use personal data to send informational, commercial and promotional communications concerning EquiUp products and services and, where expressly stated, third-party products or services.

Communications may be sent by email, telephone, SMS, messaging services or other means permitted by law.

The legal basis is the data subject's consent pursuant to Article 6(1)(a) GDPR.

Consent is optional and may be withdrawn at any time:

  • by writing to info@equiup.it;
  • through the unsubscribe link in commercial communications, where available;
  • through any relevant features in the personal account.

Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Data used for marketing purposes will be processed until consent is withdrawn or the right to object is exercised, and in any event for no longer than four years from collection, unless consent is renewed or another applicable legal basis exists.

8. Profiling and Marketing Through the Chatbot

Subject to consent, information obtained from chatbot conversations may be combined with other information lawfully held by EquiUp, such as account data, purchase history and preferences expressed by the user.

This processing may enable EquiUp to better understand the user's interests and suggest more relevant products, services, content and offers.

Consent to profiling and marketing is optional and may be withdrawn at any time without affecting the ability to make purchases or use the essential features of the service.

9. Recipients of Personal Data

To the extent necessary for their respective activities, personal data may be disclosed to:

  • EquiUp's authorised staff and collaborators;
  • IT, hosting and cloud service providers;
  • e-commerce platform providers;
  • payment and shipping service providers;
  • communication and marketing service providers;
  • automation system providers, including n8n or the parties managing its infrastructure;
  • providers of Artificial Intelligence models and services used to process requests;
  • consultants and professionals;
  • public, administrative or judicial authorities where required by law.

EquiUp does not publicly disclose users' personal data except where required by law.

10. Transfers Outside the European Economic Area

Some technology providers used by EquiUp, including any cloud or Artificial Intelligence service providers, may process personal data in countries outside the European Economic Area.

In such cases, EquiUp verifies that the requirements of Articles 44 et seq. GDPR are met and, where necessary, adopts the safeguards required by applicable law, such as adequacy decisions, standard contractual clauses or other instruments provided for by the GDPR.

11. Data Retention

Personal data is retained for as long as necessary to pursue the purposes for which it was collected and thereafter for any period required by law or necessary to protect EquiUp's rights.

In particular:

  • purchase and invoicing data is retained for the periods required by tax and civil law;
  • data used for marketing is retained for the periods stated in this notice;
  • data used for profiling is retained for 24 months;
  • chatbot conversations are retained for 24 months;
  • data used to train AI systems is retained for 24 months, or anonymised where possible.

12. Security

EquiUp adopts appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration or improper disclosure, taking into account the nature of the data processed, the technologies used and the risks associated with processing.

13. Data Subject Rights

Where applicable, the data subject may exercise the rights provided for by Articles 15–22 GDPR, including the right to:

  • obtain confirmation as to whether personal data concerning them is being processed;
  • access their personal data;
  • obtain rectification of inaccurate data;
  • obtain deletion of data in the cases provided for by law;
  • request restriction of processing;
  • object to processing;
  • request data portability;
  • withdraw previously given consent at any time.

In particular, the data subject may object at any time to the processing of personal data for direct marketing purposes, including profiling to the extent that it is related to such marketing.

Requests may be sent to info@equiup.it.

The data subject also has the right to lodge a complaint with the Italian Data Protection Authority in accordance with the procedures established by the Authority.

14. Automated Decisions

The Artificial Intelligence systems used by the chatbot may automatically process information provided by the user to generate answers, suggestions and recommendations.

Unless otherwise specifically disclosed to the user, EquiUp does not use the chatbot to make decisions based solely on automated processing that produce legal effects concerning the data subject or similarly significantly affect them within the meaning of Article 22 GDPR.

15. Children

EquiUp services and the chatbot are not intended to intentionally collect children's personal data where the consent of the holder of parental responsibility is required.

Users are requested not to enter personal information relating to children in conversations unless strictly necessary.

16. Changes to this Privacy Policy

EquiUp may periodically update this Privacy Policy to reflect changes in legislation, technology or the services provided.

The updated version will be published on the EquiUp website and will state the date of the latest update.

Last updated: September 2026.