Statement of Online Privacy Practices


Italian version

Updated 31.05.2019

Affidaty designed and created T.R.I.N.C.I., an operating system offering a range of applications that, blending the special characteristics of both private and public systems, allows it to work as both a private and/or private blockchain, whilst keeping its security features and structural integrity constant. T.R.I.N.C.I. is the fastest and most modular certified-data-transfer system that uses a decentralised and distributed environment. It does so without compromising the stability or the speed of the information transferred. This type of technology has paved the way to write interconnected blockchain devices that communicate with one another, creating a network of verifications on all types of relationships. It spreads the wealth throughout the network thanks to a Smart Contract.

Your privacy is of paramount importance to Affidaty S.p.A. It is crucial that we ensure the privacy of your data. In this statement of Online Privacy Practices you will find the data-collection procedures utilised by Affidaty S.p.A. websites and those of its affiliates, along with the types of data collected from those using our websites, and finally the ways in which the information is used, shared, and processed offline. Descriptions are also provided on how cookies, web beacons, and other technology are used by Affidaty S.p.A. software products and services. Any references to Affidaty S.p.A. websites, products, and services in the privacy protection rules likewise refer to apps, programmes, and devices.

This Affidaty S.p.A. Statement of Online Privacy Practices is mean to supplement those privacy protection rules. This Statement of Privacy Practices shall apply to all Affidaty S.p.A. websites that include a link to such rules, but not to any Affidaty S.p.A. websites that have their own privacy-protection rules. Some portions of this Statement of Privacy Practices may not apply where the information is processed simply on the customer’s behalf, such as to provide web-hosting services.

Affidaty S.p.A. may supplement this Statement with additional information on a specific interaction with a user, such as through a transaction document, or a specific privacy rule applicable to a user ordering or utilising an online service.

Affidaty S.p.A.’s privacy practices involving information collected through as described in the Statement of Privacy Practices, comply with EU Regulation no. 679/2016, also known as the GDPR.

The Data Protection Officer (DPO) is Avv. Alessandro Badii, who can be contacted at the following addresses: Tel: 068414562 – Email: – Pec:

For questions or concerns on privacy practices and procedures, please contact the Affidaty S.p.A. team by submitting this form .

1. Introduction

This Privacy Notice complies with EU Regulation no. 2016/679 regarding personal data protection. The full text is available at: .

Please note that Affidaty S.p.A. recognises and is committed to protecting the control vested in all users over their own personal data. Consequently, these data are stored inside highly secure IT systems, the only goal for which is to accurately identify our users, and to permit them to utilise our services with total transparency and security. In so doing, Affidaty S.p.A. can also be kept free of users with ulterior motives.

Affidaty S.p.A. processes personal data based on the willingness of our users to share it, and moreover based on their consent to processing. Affidaty S.p.A. respects and safeguards those rights established in EU Regulation no. 2016/679.

The legal basis for this processing is the user’s express consent, when they are willing to share some of their personal data with Affidaty S.p.A. in order to get the most out of the Affidaty S.p.A. ecosystem. This holds especially true for the contracting services, and the payment system used to ensure proper billing and accounting for all services purchased.

Affidaty S.p.A.’s core values are loyalty, ethics, transparency, and good faith. These values inform each and every decision we make, including the way we collect and protect your personal information. Therefore, the processing of our users’ personal data, and the posting of the same (with the data subject’s consent) within the platform, are predicated on these tenets.

Data is generally processed to permit users to utilise their own data within the Affidaty S.p.A. ecosystem. User-supplied data will be used, within Affidaty S.p.A., solely by Affidaty S.p.A. as the data controller to verify the user’s identity within the Affidaty S.p.A. system. The system then acts as a passive processor for the purpose of storing and protecting the data.

Since Affidaty S.p.A. does not transfer any of the data (without the user’s express consent) to any third party, all data processing on user-supplied data takes place in-house.

The “data controller” as defined under European law is Affidaty S.p.A., by and through its designated legal representative, with registered office at Viale Giovanni Milton no. 53, 50129 Florence (FI). Should you have any questions or concerns about your personal data, you may contact the data controller using this form .

Affidaty S.p.A. has no intention of transferring any collected personal data outside the EU. On the other hand, should such a transfer become necessary, Affidaty S.p.A. will notify the affected users in advance, secure their consent, and act in full compliance with Article 46 et seq. of EU Regulation no. 2016/679.

The data-storage period cannot be stated with specificity; however, the main criterion on which it is based is the user’s willingness and consent to permit Affidaty S.p.A. to retain their data. Every two years, Affidaty S.p.A. will solicit confirmation from its users to allow continued processing of their data.

It is incumbent upon us to note that users enjoy a set of rights (established by EU Regulation no. 2016/679) which may be asserted against Affidaty S.p.A.

Specifically, the aforementioned Regulation introduced the right of the data subject to request, from the data controller, access to his or her personal data (Art. 15 of the Regulation) as well as the correction, deletion, or limitation on any processing on the same (the “right to be forgotten”, Art. 17 of the Regulation), as well as the right to object to processing on the same. Additionally, Affidaty S.p.A. ensures the following:

  • the right to data portability on user-supplied data (Art. 20 of the Regulation): the data subject has the right to receive their personal data from a data controller in a structured, commonly used, machine-readable format, and the right to transfer the data to another controller without delay by the data controller to whom they were supplied;
  • the right to revoke consent at any time, without thereby prejudicing the lawfulness of any processing predicated on consent during the period prior to revocation (Art. 7 of the Regulation);
  • the right to lodge a complaint with the data controller, or with the authorities, specifically, the Data Protection Authority (

The timeframe in which to respond to any data subject following the exercise of any right established under EU Regulation no. 2016/679 is one (1) month, which may be extended to three (3) months in instances of complex requests.

Again, please note that should Affidaty S.p.A. intend to use user personal data for reasons other than those set forth herein, Affidaty S.p.A. shall advise the users in advance, and ask for their specific consent.

You may elect to supply us with your personal information in different ways. For example, you may send us your name and contact information for the purpose of order submission, fulfilment, and modification, for subscriptions, to sign up for a service, or for business-related purposes (if you are our vendor or business partner). You may also send us information on your credit card to make purchases, or to provide information on your educational background and professional experience, should you intend to apply for a position with Affidaty S.p.A.. If you do not wish for your information to be used to contact you in the future, Affidaty S.p.A. will abide by your decision.

2. Registration

If you wish to receive information, download publications, participate in an event (be it in person or online) or request a trial period, we may ask that you provide us with your name and contact information, as well as other information relating to the request as submitted. Affidaty S.p.A. will use such information within the scope of that request, and for correspondence purposes, if needed. In the vast majority of cases, this information can likewise identify the user whilst they are visiting our sites. The information will be retained for any future interactions with the user.

Additionally, Affidaty S.p.A. may ask you to register a Synkrony Alias. In that case, you must provide your name, email address, country of residence, and other information as needed for the specific type of registration. The Synkrony Alias acts as your unique identifier when you visit our websites, submit a request, or when you place an order for, or use a product or service. Most orders for services and products require the user to register for a Synkrony Alias. Signing up for a Synkrony Alias may also allow for both customisation and control of your privacy settings. Some Affidaty S.p.A. products and services may require a special registration for the purpose of supplying those specific products and services. In those cases, the registration details supplied by the user for a product or service shall be used solely for purposes relating to the supply of such product or service.

3. Site Visits and T.R.I.N.C.I. Blockchain Services

Using a variety of technologies, Affidaty S.p.A. also collects information on website use by users, and the use of T.R.I.N.C.I. services. For example, if a user visits our websites, or accesses T.R.I.N.C.I. blockchain services, Affidaty S.p.A. may record certain information sent to us by the browser, such as an IP address (including information from the IP address, such as geographic location), browser type, version, and language, time and duration of access, and the reference website addresses; additionally, information may be collected on the pages viewed within our websites, the time spent on each page, and other actions occurring during your visit to our site. When you visit our website without a Synkrony Alias, or without registering, personal information is still collected to allow the website to function properly.

Additionally, some software products and T.R.I.N.C.I. blockchain services incorporate technology that allows Affidaty S.p.A. to collect certain items of information on the use of products and services. Affidaty S.p.A. may also use certain technologies for purposes of email transmission confirmation, and to determine whether a link contained in an email was followed. For more information on the technology we use, please read the section 22.Cookies, Web Beacons and other technology.

4. Marketing Information

Most information that we collect on a user comes from direct interaction.

Occasionally, and if permitted, Affidaty S.p.A. may collect information from other sources, such as from product vendors. In those cases, Affidaty S.p.A. asks the vendor to state whether the information has been collected in such a way to allow them to be lawfully used by Affidaty S.p.A. as well.

When a person registers for an event, Affidaty S.p.A. may collect additional information (whether on- or offline) relating to the event itself. Over the course of the event, Affidaty S.p.A. may collect information on session participation and survey results. The events may be videotaped, and group photographs may be taken. We reserve the right to use any photos taken for promotional purposes. Affidaty S.p.A. may use commercial-contact information supplied by the user (e.g. from a business card) to communicate with that person.

Affidaty S.p.A. may directly or indirectly supplement any personal information collected for purposes of accuracy or to improve customer interactions.

5. Use of Personal Information

The following paragraphs provide a detailed explanation of how personal data are used by Affidaty S.p.A..

6. Completing Transaction Requests

If a user submits a request to Affidaty S.p.A. (such as for a product or service, for specific marketing materials, or requests a reply), Affidaty S.p.A. will use the information provided to process the request. Consequently, Affidaty S.p.A. may share that information with any third party implicated in the request, such as an Affidaty S.p.A. business partner, financial institution, shipping company, postal service, or a public authority such as the customs office. Affidaty S.p.A. may ask customers to complete a customer-satisfaction feedback form or market-research survey.

7. Customisation of the Website Experience

Affidaty S.p.A. may use any collected personal information to offer a personalised experience when you visit our websites or use our services, for example by providing tailored content or streamlining your navigation on the site. We may also use that information to improve our websites.

8. Support

Affidaty S.p.A. may use the personal information to provide support for Affidaty S.p.A. products and services, such as by sending information on updates or product corrections. We may combine user information with information sourced from other interactions in order to make critical suggestions on product support.

Affidaty S.p.A. also offers “Live Chat” support on its websites to assist customers whilst they navigate the site, or forums in which users can raise issues and offer solutions. Affidaty S.p.A. will adhere to the provisions of the Statement of Privacy Practices when using any personal information supplied via chat or within the forum.

For purposes of technical support, Affidaty S.p.A. may happen to have access to information provided by the customer, or to data present in the system. These data may contain personal information on company employees, customers, partners, or suppliers. This Statement of Privacy Practices shall not apply to this kind of personal-data access or management; the terms and conditions for processing and managing that kind of data are set forth in the Terms of Use, and in other agreements with Affidaty S.p.A.

9. T.R.I.N.C.I. Blockchain Services

Affidaty S.p.A. may utilise information gathered during the use of any T.R.I.N.C.I. blockchain services to be able to: cull statistical data on the utilisation and efficacy of our software products and T.R.I.N.C.I. blockchain services; to improve and customise your experience with, and use of, our products and services; to customise our interactions with the user; to advise customers regarding the general use of their products and services, as well as to improve and develop our products and services.

10. Marketing

Personal information supplied to Affidaty S.p.A., as well as indirectly collected personal information, may be used by Affidaty S.p.A. for marketing purposes, for example to keep the user informed of events, products, services, and solutions sold by Affidaty S.p.A., and which might supplement an existing portfolio of products. Before doing so, Affidaty S.p.A. will contact the customer to obtain consent. You may opt out of Affidaty S.p.A. marketing mailings at any time by following the “unsubscribe” instructions appearing in all emails. You also have the option to update your subscriptions, or to contact us directly.

Some of our offers and events may be co-branded, or produced by Affidaty S.p.A. and third parties such as business partners or solution providers who use, resell, or supplement Affidaty S.p.A. products and/or services. Co-branded offers and events are clearly marked as such. Registering for these offers or events means the collection and sharing of user personal information with other companies. We invite the user to review these companies’ privacy policies to learn how they manage personal information.

If you choose to “send this page via email” you must enter the name and email address for the recipient; Affidaty S.p.A. will then automatically send an email with the requested page, but will not use the information for other purposes.

11. Hiring

Should you wish to respond to any job announcement on Affidaty S.p.A.’s website or another site, you have the option of submitting a resume. Affidaty S.p.A. will utilise this information internally to answer your questions and to review your job application.

12. Monitoring and Recording Phone Calls, Chats, and other Interactions

Some online transactions may require that we contact, or that we be contacted, by customers. Some transactions also involve online chats. Affidaty S.p.A. reserves the right, with your consent, to monitor, and in some cases record, these interactions to ensure staff training and quality standards, or to retain proof of specific transactions or interactions.

13. Use of Information in Social Computing

Affidaty S.p.A. provides tools for social computing on some of its websites to allow for online sharing and collaboration amongst registered users. These tools include forums, wikis, blogs, and other social-media platforms. To download and use these applications, or to sign up and use these social-computing tools, you must provide certain items of personal information. Registration information are subject to, and protected under, the Statement of Privacy Practices, with the exception of any profile information which is automatically supplied to other participants. These applications and tools may include additional privacy policies with specific information on data collection and management procedures.

Any other posted content, be it images, information, opinions, or other personal information you voluntarily make available to other participants on these platforms or applications shall not fall within the scope of the Statement of Privacy Practices. This content is subject to the terms of use for these platforms or applications, and to the Statement of Privacy Practices with respect to their use, and to the process or request for support to remove content from such tools. Please review those terms of use to better understand the division of rights and responsibilities between Affidaty S.p.A. and other parties with respect to such content. Additionally, content posted on social-computing platforms may be disseminated to Affidaty S.p.A. sites or to any external site.

14. Safeguarding of Affidaty S.p.A. and Third Party Rights and Property

Affidaty S.p.A. may use or share personal information to protect the rights and property of Affidaty S.p.A., its business partners, suppliers, customers, or third party companies if Affidaty S.p.A. believes such rights or ownership interests are being infringed upon. Furthermore, Affidaty S.p.A. reserves the right to produce personal information, in accordance with applicable law, if needed to protect its own rights or those of any third party, or to take part in any court proceeding, or respond to any court order implicating the Affidaty S.p.A. websites.

15. Information for our Business Partners

If you represent an Affidaty S.p.A. business partner, you have the option of visiting Affidaty S.p.A. websites developed specifically for Affidaty S.p.A. business partners. Affidaty S.p.A. may use the information provided in these sites (with your consent, if required) to cultivate and manage customer relations, and with the business partners who represent them, as well as with Affidaty S.p.A.’s business partners in general. For example, information you have supplied may be used to send you information on Affidaty S.p.A. business partner programmes or to share specific information with other business partners (as permitted under any pending duty of non-disclosure or confidentiality) and with Affidaty S.p.A. customers or prospective customers. With consent, and for a given programme or transaction, Affidaty S.p.A. may contact you for feedback on customer satisfaction or for purposes of market research.

16. Information for Vendors

If you represent an Affidaty S.p.A. vendor, you have the option of visiting those Affidaty S.p.A. websites developed specifically for our vendors. Affidaty S.p.A. may use the information provided on these sites to open or consummate a transaction. For example, Affidaty S.p.A. may share such information with any third party involved in the request, such as an Affidaty S.p.A. business partner, customer, financial institution, courier, postal service, or public authority. Personal information may likewise be used, with consent, to manage and cultivate our relationship with you, the vendor you represent, and other Affidaty S.p.A. vendors in general.

17. Minors

Unless otherwise stated, our websites, products, and services are not intended for use by anyone under sixteen (16) years of age.

However, Affidaty S.p.A. permits access by minors under sixteen (16) years old to IT systems featuring educational content. These systems require the entering of an identifier (the Synkrony Alias) prior to accessing the same, as well as to review any results obtained by using the site. In these cases, the data shall be processed anonymously, ensuring user privacy thanks to an alphanumeric password. In certain cases where the educational content is associated with the awarding of scholarships, specialised courses, the earning of degrees, certificates and/or participation certificates, express consent of the minor’s parent or legal guardian may be required in order to authorise the disclosure of a mobile phone number for purposes of identifying the winner (Art. 8, GDPR, and Legislative Decree no. 101 of 10/8/2018). Collected data shall, regardless, be processed according to the principle of anonymity, and will be removed if the Synkrony Alias is deleted. Should any services rendered be used by third parties as part of a license-as-a-service, Affidaty S.p.A. shall remain liable for any data processing through the end of the licensing period. Affidaty S.p.A. shall apply the terms and conditions of the licensing agreement in accordance with EU Regulation no. 679/2016 (the GDPR), reserving the option to supplement certain specific content in case of any special requests placed by the customer. Affidaty S.p.A. shall, without exception, remove any reference to things or persons at the end of each learning session, and retain solely the statistics gleaned from use of the educational systems. In some cases, if contemplated under the licensing agreement, Affidaty S.p.A. may share statistics culled from interactions with educational content with the licensee who took the tests, for the purpose of awarding scholarships, specialised courses, awarding degrees, certificates, and/or participation certificates.

18. Data Storage

Affidaty S.p.A. will process your personal information for as long as the purposes for which the information was processed are being pursued, or for any other valid reason (such as for defending a lawsuit, or to discharge duties under a pending contract). Registration information will be maintained whilst the account or Synkrony Alias is active, or for the time period necessary to provide services. If you wish to request service deactivation or to have us delete your registration information, please contact us using this form .

If the user has executed an Affidaty Blockchain service agreement with Affidaty S.p.A., registration information may be kept to respond to any customer requests.

19. Cookies, Web Beacons and other Technology

As described above, Affidaty S.p.A. collects information from site visits and from the use of T.R.I.N.C.I. blockchain services, as well as from the use of our software products, to obtain statistical information on the use and efficiency thereof, to personalise the user’s experience and interactions, and to improve our products and services. These activities are made possible through the support of a variety of technologies, including scripts, tags, Local Shared Objects (Flash cookies), beacons, Local Storage (HTML5), and “cookies”.

20. What are Cookies and how are they Used?

A cookie is a data file that a website sends to a browser, which is then stored on a computer as an identifying tag. Although generally used to evaluate website usage (number of site visitors, time spent on the site), efficiency (what are the top items of interest), and to streamline use and navigation, and therefore are not associated with personal information, cookies are sometimes used to personalise a returning visitor’s experience on a website, associating the cookies with user preferences or personal information. Over time, these data supply useful information for purposes of improving user experience.

Cookies are generally classified as either “session cookies” or “persistent cookies”. Session cookies allow a person to navigate a website efficiency by keeping track of the page-to-page progression in order to avoid requesting information supplied during the current visit, or information needed to complete a transaction. Session cookies are stored in the browser’s temporary memory, and eliminated once the browser window is closed. On the other hand, persistent cookies memorise user preferences for the current or for subsequent visits. Persistent cookies are stored on the hard disk and are available when you relaunch your browser. For example, Affidaty S.p.A. uses persistent cookies to record the user’s home country and preferred language.

21. Can I Adjust the Privacy Settings for Cookies?

Whilst you navigate our websites or use our online services, you can set your preferences for cookies and other similar technology through your browser, or through Affidaty S.p.A. settings. If Affidaty S.p.A. has an active cookie-management programme, it will pop up when you first visit our site, at which point you can choose (and modify at any point thereafter) what types of cookies you want our websites or our T.R.I.N.C.I. blockchain services to use. You can enable mandatory cookies, mandatory and functional cookies, or mandatory, functional, and customisation cookies, as you wish. Below you will find additional information on the types of cookies we use. Setting cookie preference will not delete any cookies previously placed on the device you are using. You can, however, eliminate those cookies through your browser settings.

Although currently Affidaty S.p.A. website, the T.R.I.N.C.I. blockchain services, and the online services do not recognise automated monitoring by a browser (such as a “do not track” instruction), it is possible to express your general privacy preferences with respect to the use of a number of cookies and similar technologies through the web browser. For further information on cookie enabling and disabling, please review the designated section of your browser. In most cases, you can set your browser to warn you before receiving cookies, and thus have the option to decide whether to accept them. You can also disable cookies entirely. In our software, cookies can be disabled directly within the product. Since cookies allow people to get the full use of website, software product, and T.R.I.N.C.I. blockchain-service functions, we advise against disabling them. If you block all cookies, disable them, or reject them, some pages may not load correctly, or you may not be able to (to cite a few examples) add items to your cart, go to checkout, or use the website or T.R.I.N.C.I. blockchain services which require them to be enabled.

22. Web Beacons and Other Technology

Some Affidaty S.p.A. websites, software products, and T.R.I.N.C.I. Blockchain services also use web beacons or other technology to better personalise the sites and to provide better customer service. These technologies are used on different pages within Affidaty S.p.A. websites. When a visitor accesses these pages, a notice (which does not identify the specific visit) is thereby generated, which may then be processed by Affidaty S.p.A. or our suppliers. These web beacons are generally used alongside cookies. If you do not wish for cookie information to be associated with your visits to these pages, or to product use, you may disable the cookies in your browser settings, or directly within the product. If you disable cookies, web beacons, and other technology, visits to these pages will be logged, but the information memorised in the cookies will not be stored.

For more information on the technology used by our software products and the T.R.I.N.C.I. blockchain services, including deactivation procedures, please review the user’s manual for the specific software, or for the T.R.I.N.C.I. blockchain services used. For information on the use of cookies and other technology by Affidaty S.p.A. customers, on the implementation of Affidaty S.p.A. software, and on T.R.I.N.C.I. blockchain services, please use this form .

Affidaty S.p.A. uses Local Shared Objects, such as Flash cookies, Local Storage and HTML5, to store preferences and information on content. Affidaty S.p.A.’s outsourcers for certain Affidaty S.p.A. site functions, or those with whom Affidaty S.p.A. advertises online based on browser activity may use Flash Cookies and Local Storage and HTML5 to collect and store information.

Some browsers offer internal management systems to remove HTML5.

Affidaty S.p.A. may decide to include web beacons in its marketing emails or newsletters to see whether the messages were opened, and whether the reader clicked on a link. Some Affidaty S.p.A. business partners place their web beacons and cookies on our site. Furthermore, the buttons of some third-party social networking sites may record certain items of information, such as an IP address, browser type, language settings, time of access, referring websites, and if a user is registered, collected information may be sent to the associated social-media profile. Affidaty S.p.A. has no control over the tracking technology used by third-party companies.

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23. Google Analytics

Google Analytics is a web-analysis service provided by Google Inc.. It uses monitoring cookies to collect data for the purpose of analysing site use by users, to fill out reports on site activity and user behaviour, to verify how often the users visit the site, how they are tracked, and what pages are most frequently visited. These monitoring cookies are third-party cookies, in that they are never installed by Affidaty S.p.A. directly, but rather by third parties. More specifically, Google Analytics collects the original cookies, the data on the device/browser, the IP address, and site activities. This type of data does not permit the user to be personally identified, and the data are not cross-referenced with other information on the same person.

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 When the user accesses a site, a banner appears to notify the user that the site uses Google Analytics and third-party cookies, and that by closing the banner, the user is consenting to the use of cookies. When the user expresses his or her consent, Affidaty S.p.A. tracks the same by placing a technical cookie.
The user is free to disable analytical cookies, and to block Google Analytics from collecting their navigation data. To do so, the user needs to download a browser plug-in to disable Google Analytics (

24. Online Advertising

Affidaty S.p.A. does not post third-party advertisements on its websites, but Affidaty S.p.A. does advertise its products and services on other websites.

25. Links to Non-Affidaty S.p.A. Websites and to Third-Party Applications

To allow for interactions with other websites on which the user has an account (such as Facebook or another social-media site) or to take part in community discussions on these sites, Affidaty S.p.A. provides a link, or incorporates third-party applications which allow a user to access, post, or comment within those social-media networks directly from our websites.

Affidaty S.p.A. may also provide links to non-Affidaty S.p.A. websites. The use of these links and third-party applications is subject to the privacy policies of the third-party companies. We therefore invite you to review those policies carefully before clicking on any third-party link or application. Affidaty S.p.A. shall not be liable for the privacy policies or content of any third-party website.

26. Notice of Updates

Should this Statement of Privacy Practices be updated, we will post a notice to our website, or provide any other notice required by applicable law.

27. Access and Privacy Questions

If you have any questions or concerns regarding this Statement of Privacy Practices, or the management of your personal information by Affidaty S.p.A., you can write to us using this form .

You may also write to us at:

Affidaty S.p.A.

Viale Giovanni Milton, 53
50129 Florence (FI)

In some cases, you will have the option to view or modify your personal information online. If your information is not accessible online, and you wish to receive a copy of the information supplied to Affidaty S.p.A. or report any error to be corrected, contact us.

If you wish to opt out of Affidaty S.p.A. marketing emails, please write to us using this form or update your email preferences / unsubscribe using the link within the marketing email.