Italia Quality distinguishes communications necessary to provide the service from promotional communications. Newsletter subscription is optional and does not condition ordinary access to the platform.
1. Types of communication
The platform may send service communications necessary for account management, security, email verification, password reset, moderation, complaints, essential service changes or other messages connected with the relationship. Newsletters, commercial initiatives and promotional content are managed separately.
2. Voluntary subscription
For individual users, promotional newsletters by email are generally based on prior, freely given, specific, informed and demonstrable consent. The newsletter box is not pre-ticked and refusal does not limit essential profile functions.
3. Soft spam
An existing customer email address may be used for promotion of the sender’s own similar products or services only where all conditions of Article 130(4) of the Italian Privacy Code are actually met. A simple and free opt-out must always be offered.
4. Evidence of the choice
Italia Quality may record subscription status, date, applicable policy/information version, language and a proportionate technical identifier to demonstrate the choice and manage disputes.
5. Unsubscribe and withdrawal
Every promotional communication must provide an easy and free method to withdraw consent or object. Withdrawal operates for the future and does not affect the lawfulness of processing carried out before withdrawal.
6. Service communications
Unsubscribing from the newsletter does not prevent messages strictly necessary for account management, security, moderation, legal obligations or user requests.
7. Frequency and content
UESE limits frequency and content according to relevance and proportionality. Misleading subjects or senders are prohibited, and each message must make the party on whose behalf it is sent identifiable.
8. Email tracking
Pixels, tracked links or other technologies enabling non-essential individual measurement require prior privacy/ePrivacy assessment. Where consent is required, those tools must not operate without a valid choice.
9. Providers
Delivery may use technical mail providers or contracted platforms. Such parties are selected and contracted under GDPR requirements when processing data on UESE’s behalf.
10. Publicly available addresses
Publication of an email address on a website, social network or public list does not by itself authorise marketing use. Commercial outreach must respect original purpose, data-subject expectations and specific electronic-communications rules.
11. Key legal references
- Directive 2002/58/EC – Article 13
- Italian Legislative Decree 196/2003 – Article 130
- Italian DPA – Guidelines on promotional activity and spam