Privacy notice

Last updated: 21 August 2026 · Version 1.1

This notice explains what personal data we process through Iànua, why, on which legal bases, for how long, and which rights you may exercise. It is provided under Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).

Iànua is a virtual assistant: when you interact with an automated system, the automated nature of the interaction is disclosed at the start of the contact on active channels, with handover to a human operator when needed, in accordance with the AI Act (Regulation (EU) 2024/1689, Article 50).

1. Data controller

Iànua is a differen product; integration and service delivery at your organisation are handled by RSTRT. When you use Iànua to contact a customer organisation, that organisation is the data controller and differen/RSTRT act as processors under Article 28 GDPR. For data collected directly by this website and product management, the controller is differen srl, Via XX Settembre 33/10, 16121 Genoa, Italy — VAT/tax code 02705790992, REA GE-505513, fully paid-up share capital €21,430.00. Contact: privacy@differen.it. Where necessary, we will forward your request to the customer organisation acting as controller.

2. Data we process

Channel	Data
Phone / voice IVR	Calling number, request content, any declared recording or transcript, outcome and operator notes.
Email	Address, subject, message content and routing.
Chat / WhatsApp / Telegram and other messaging channels	Contact identifier, messages, submitted attachments and outcome.
Website	Information you provide voluntarily and aggregate browsing statistics that are anonymous where technically possible.

We do not request special-category data (Art. 9 GDPR). Please do not submit unnecessary special-category or sensitive data.

3. Purposes and legal bases

Handling requests, support, appointments and tickets: contractual or pre-contractual measures and legitimate interest (Art. 6(1)(b)/(f)).
Transparency, security and audit: legal obligations and legitimate interest (Art. 6(1)(c)/(f)).
Service improvement using aggregate statistics that are anonymous where technically possible: legitimate interest, without individual profiling.

4. Retention

Call recordings, when enabled and disclosed: up to 90 days, unless needed for disputes or legal obligations.
Transcripts, chat messages and contact logs: up to 12 months, then deleted or anonymised, unless retention is required for disputes or legal obligations.
Contractual and accounting data: for the relationship and statutory retention periods.

5. Recipients and processors

Data may be accessed by authorised personnel of the customer organisation and by differen/RSTRT as processors. Technical suppliers for hosting, voice, speech services and AI models act under contractual safeguards. We do not sell personal data.

6. Transfers outside the EEA

The main infrastructure is in the European Union. Where an AI supplier processes data outside the EEA, appropriate safeguards such as EU Standard Contractual Clauses or an adequacy decision apply, with data minimisation.

7. Use of artificial intelligence

Iànua uses AI systems to understand requests and formulate responses. You are informed when you interact with an automated system and human oversight is available. Decisions producing legal or similarly significant effects are not made solely by automated processing.

8. Your rights

You may exercise the rights in Articles 15–22 GDPR: access, rectification, erasure, restriction, objection, portability and withdrawal of consent where applicable. You may also lodge a complaint with the competent supervisory authority (in Italy, the Garante per la protezione dei dati personali, garanteprivacy.it). Contact privacy@differen.it.

This website does not use profiling or advertising cookies. When enabled, analytics are aggregate and anonymous where technically possible: they do not use identifying cookies or persistent identifiers and do not track you across websites, except for technical logs required for security and service delivery. For this reason no cookie consent banner is required. Strictly necessary technical cookies used for restricted areas do not require consent.

10. Accessibility

We want Iànua to be usable by everyone, including people with low vision and those navigating by keyboard or with a screen reader. The website follows WCAG 2.1 AA principles, including semantic structure, alternative text, adequate contrast, keyboard navigation, visible focus, skip links and reduced-motion preferences. Report barriers to info@differen.it.

11. Contacts

differen srl — Via XX Settembre 33/10, 16121 Genoa, Italy · Privacy: privacy@differen.it · General: info@differen.it.

This notice may be updated; the version in force is always published on this page.