Privacy Policy
Last updated: 04/03/2026. Agile Telecom is committed to protecting your privacy and ensuring transparent data processing.
Agile Telecom S.p.A., with registered office at Via Baldassarre Peruzzi 26, 41012 Carpi (MO), Italy ("Agile"), is strongly committed to protecting the online privacy of users of its websites www.agiletelecom.com, www.faxator.com, and www.qlara.ai (hereinafter collectively referred to, unless otherwise specified, as the "Website" and – together with the services provided by Agile through dedicated software and/or platforms – the "Digital Tools").
This document (the "Privacy Notice") has been drafted to help you understand how your Personal Data, as defined below, will be processed when using the Digital Tools.
The purpose of this Privacy Notice is to provide you with the necessary information so that you can give explicit and informed consent to the processing of your data through the Digital Tools, should you choose to do so.
In general, any information or Personal Data that you provide to Agile through the Digital Tools, or that is otherwise collected through the Digital Tools as part of the use of Agile's services (the "Services"), as further detailed in Section 3 below, will be processed in accordance with internationally recognized principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, and confidentiality.
Agile, as identified at the beginning of this Privacy Notice, is the Data Controller with regard to all Personal Data processed through the Digital Tools.
You can contact Agile's Data Protection Officer ("DPO") at the following email address: dpo@agiletelecom.com
When you use the Digital Tools, you may provide – or we may collect – certain Personal Data about you which, depending on the circumstances, may consist of identifiers such as your name, an identification number, an online identifier, or one or more elements specific to your physical, physiological, mental, economic, cultural, or social identity, capable of identifying or making you identifiable (hereinafter, "Personal Data").
Your Personal Data may be collected either because you voluntarily provide it (e.g. when you request information from Agile through the contact section, subscribe to our newsletter, register an account within the Digital Tools, or request one of our Services) or through analysis of your behaviour while using the Digital Tools.
a. Name, Contact Details, and Other Personal Data
In various sections of our Digital Tools, particularly when requesting the activation of a Service or information about our Services, you may be asked to provide information such as your name, phone number, email address, the company you work for, etc.
Additionally, when you communicate with Agile via the email addresses available on the Digital Tools, Agile may collect any additional information you choose to share.
Depending on the type of service requested, it may also be necessary to collect certain specific identity information to comply with industry-specific regulations (e.g. "Alias" rules).
If you have registered for Digital Tools following a referral from one of our commercial partners, some data related to the purchase, subscription, and renewal of subscriptions to our Services will be indexed.
b. Special Categories of Personal Data
Some sections of the Digital Tools (e.g. contact or spam reporting forms) include free-text fields where you may provide Agile with certain information, which could contain Personal Data.
As these are open fields, you may (intentionally or unintentionally) disclose special categories of Personal Data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data uniquely identifying a person, or data concerning health, sex life, or sexual orientation. Agile asks that you do not provide such data unless strictly necessary. These special categories of data may only be processed with your explicit consent and in accordance with applicable law.
c. Data Voluntarily Provided by the Data Subject
Some sections of the Digital Tools allow you to enter text messages visible to Agile, which may include Personal Data of other individuals. In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities.
If you provide or otherwise process third-party Personal Data while using the Digital Tools, you hereby warrant – assuming full responsibility – that this processing is based on the prior consent of such third parties or another valid legal basis legitimizing the processing.
d. Personal Data Automatically Collected When We Send Emails
When we send emails or other communications, we use tracking systems – subject to your freely given consent – such as pixels or web beacons to detect whether a message is opened, which hyperlinks are clicked, from which IP address and with which type of browser the email is opened, and other similar details.
e. Browsing Data
The IT systems and software procedures that enable the functioning of the Digital Tools may, during their normal operation, collect certain Personal Data, the transmission of which is implicit in the use of Internet communication protocols.
This category of data includes IP addresses or domain names of the devices used, URI addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the response file, the numerical code indicating the status of the server's response, and other parameters related to the user's operating system.
These data are used solely to obtain anonymous statistical information on the use of the Digital Tools and to monitor their proper functioning, to identify anomalies and/or abuse, and are deleted immediately after processing. Data may be used to ascertain responsibility in the event of cybercrimes; except for this eventuality, web contact data is currently anonymised.
f. Cookies
Definitions, Characteristics, and Applicable Law
Cookies are small text files that websites visited by the user send to the user's computer or mobile device, where they are stored and then retransmitted to the same websites upon the next visit. Cookies allow a website to remember the user's actions and preferences (such as login data, selected language, font size, display settings, etc.).
Cookies are used to perform computer authentications, session monitoring, and to store information about users' activities on a website, and may also contain a unique identification code for statistical or advertising purposes.
There are various types of cookies based on their characteristics and functions: session cookies, which are automatically deleted when the browser is closed; and persistent cookies, which remain on the user's device until a preset expiration date.
"Technical cookies" – used solely to carry out communications or strictly necessary to provide a service explicitly requested by the user – generally do not require user consent. "Profiling cookies", used to create user profiles and send targeted advertising, generally require the user's prior consent.
Types of Cookies Used
The Digital Tools use the following types of cookies:
- Technical navigation or session cookies – strictly necessary for the operation of the Digital Tools or to allow you to use requested content and services;
- Analytical cookies – help us understand how users interact with the Digital Tools. These do not collect your identity. Information is processed in aggregate and anonymised form;
- Functionality cookies – used to enable specific features (e.g., language preferences) and improve the service provided;
- Profiling cookies – used to deliver advertising aligned with your browsing preferences.
Agile also uses third-party cookies, meaning cookies from websites or web servers other than Agile's, used for their own purposes – including profiling.
Cookie Settings
You can block or delete (in whole or in part) technical and functionality cookies using your browser settings. However, disabling technical cookies may make it impossible to use the Digital Tools. Disabling functionality cookies may prevent some services or features from being available or functioning properly.
Your preferences will need to be set separately on each device or browser you use to access the Digital Tools.
How to View and Modify Cookies Through Your Browser
You can also manage third-party cookie preferences via AdChoice or All About Cookies.
WARNING: Disabling technical and/or functionality cookies may prevent access to or proper operation of some parts or features of the Digital Tools.
Agile will use your Personal Data, collected through the Digital Tools, for the following purposes:
- Service Provision: to enable you to register and access reserved Services, assist you with login credentials, send you Agile's newsletter, respond to your information requests, and more generally provide services through the Digital Tools.
- Marketing: to send you marketing communications, promotions, advertisements, market research, and surveys via email, SMS, phone, banners, regular mail, instant messaging, and social media pages.
- Soft Spam: to send you marketing emails regarding products and services similar to those you have already purchased.
- Compliance: to comply with legal obligations that require Agile to collect and/or further process certain types of Personal Data.
- Abuse/Fraud Prevention: to monitor how the Digital Tools are used, detect or prevent misuse or fraudulent activity, and enable Agile to defend itself in legal proceedings.
- Service Provision: processing is necessary to perform pre-contractual or contractual obligations at your request. While not mandatory, failure to provide your data will prevent Agile from delivering the Services.
- Marketing: processing is based on your consent. You may withdraw it at any time without consequences (except no longer receiving marketing communications).
- Soft Spam: processing is based on Agile's legitimate interest. You may stop receiving these communications at any time via the unsubscribe link.
- Compliance: processing is necessary to fulfil legal obligations.
- Abuse/Fraud: information is used solely to prevent/detect fraudulent activities and enable legal defence.
Your Personal Data may be shared with:
- Entities acting as data processors (consultants, technical maintenance providers);
- Third parties necessary for Service provision (e.g., hosting providers);
- Persons authorized by Agile bound by confidentiality obligations (e.g., employees);
- Companies within our corporate group for internal administrative purposes;
- Commercial partners for correct contract execution;
- Parties involved in extraordinary corporate transactions (mergers, acquisitions);
- Public authorities where required by law.
Some Personal Data may be transferred to Recipients outside the European Economic Area. Agile ensures compliance using appropriate safeguards such as adequacy decisions, Standard Contractual Clauses, or other lawful mechanisms. For more information, contact: privacy@agiletelecom.com.
- Service Provision: retained for the time strictly necessary to fulfil the purpose, potentially longer to protect Agile's interests against claims.
- Marketing: retained until you withdraw consent. You will be asked to renew periodically.
- Soft Spam: retained until you object via the unsubscribe link.
- Compliance: retained for the period required by applicable regulations.
- Abuse/Fraud: retained only for the time strictly necessary for prevention/detection and legal defence.
You have the right to request from Agile, at any time:
- Access to your Personal Data (or a copy), and further details on how it is processed;
- Rectification or update of your incomplete or outdated data;
- Erasure of your data from Agile's systems;
- Restriction of data processing;
- Portability of your data in a structured, commonly used, machine-readable format.
You also have the right to:
- Object to processing (e.g., for Soft Spam);
- Withdraw consent given for Marketing at any time.
You can unsubscribe from marketing and Soft Spam emails via the link in each communication.
Exercise your rights by contacting Agile at: privacy@agiletelecom.com
You have the right to lodge a complaint with the competent Supervisory Authority (in Italy, the Garante per la Protezione dei Dati Personali) if you believe your data has been processed unlawfully.
This Privacy Policy is effective as of 04/03/2026. Agile reserves the right to amend or update its content, in whole or in part, including due to changes in applicable law. Agile will inform you of such changes as soon as they are implemented, and they will become binding upon publication on the Digital Tools.
You are encouraged to regularly review this section to stay up to date with the latest version of the Privacy Policy.
Our platform "Lora" enables users to connect their social media accounts (including YouTube, Meta/Facebook, Instagram, LinkedIn, TikTok, and others) to publish, schedule, and manage content across multiple channels. When you connect a third-party account, we access data through that platform's API services in accordance with the permissions you grant.
a. YouTube API Services
When you connect your YouTube account through our platform, our application accesses the YouTube API Services. By using this feature, you agree to be bound by the YouTube Terms of Service and the Google Privacy Policy.
b. Data Collected Through Third-Party APIs
When you connect your social media accounts, we may collect and process the following data, depending on the platform and the permissions you authorize:
- Account profile information (name, profile picture, channel/page identifiers);
- Video and content metadata (titles, descriptions, thumbnails, publication status);
- Engagement data (ratings, comments, captions);
- Analytics and performance metrics related to your content.
For YouTube specifically, the scopes authorized may include: viewing your YouTube account, managing your YouTube account, seeing, editing, and permanently deleting your YouTube videos, ratings, comments and captions, and managing your YouTube videos.
c. Purpose of Processing
Data obtained through third-party platform APIs is collected and processed solely to enable you to:
- Publish, schedule, and manage content on your connected social media channels;
- View and monitor the performance of your published content;
- Generate personalized content recommendations for your social channels.
We do not use data obtained through the YouTube API Services or other third-party platform APIs for any purpose other than providing and improving the Lora platform services described above. We do not use this data to train artificial intelligence or machine learning models.
c-bis. Legal Basis
The processing of data obtained through YouTube API Services and other third-party platform APIs is based on the performance of the contract between you and Agile (Article 6(1)(b) GDPR). The connection of your social media accounts and the processing of associated data is necessary to fulfil our contractual obligation to enable you to publish and manage content on your YouTube channel and other connected platforms through the Lora platform.
d. Data Protection Mechanisms
All data obtained through third-party platform APIs, including the YouTube API Services, is protected by the following security measures:
- Encryption in transit: all data is encrypted during transmission using TLS 1.3 protocols;
- Encryption at rest: all stored data is encrypted using AES-256 encryption;
- Access controls: strict role-based access controls (RBAC) ensure that only authorized personnel can access user data, following the principle of least privilege;
- EU data residency: all personal data is stored and processed exclusively within the European Economic Area (EEA);
- Regular audits: we conduct regular security audits and vulnerability assessments to maintain the highest data protection standards;
- Incident response: documented breach notification procedures ensure timely notification within 72 hours in case of data breaches, as required by GDPR.
e. Data Retention and Deletion
We retain data obtained through third-party platform APIs only for as long as necessary to provide the service. When you disconnect a social media account from our platform, all associated data obtained through that platform's API is deleted from our systems within 30 days. You may also request immediate deletion by contacting privacy@agiletelecom.com.
f. Revoking Access
You can revoke our application's access to your third-party platform data at any time:
- YouTube/Google: visit your Google Account permissions page and remove "Lora Agile Telecom" from the list of authorized applications;
- Other platforms: visit the respective platform's application settings to revoke access;
- Via our platform: you can disconnect any social media account directly from the Lora platform settings.
g. Google API Services User Data Policy Compliance
Our use and transfer to any other application of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:
- We only use access to Google user data to provide and improve the features of the Lora platform as described in this Privacy Policy;
- We do not transfer Google user data to third parties, except as necessary to provide the service, as required by law, or with your explicit consent;
- We do not use Google user data for serving advertisements;
- We do not allow humans to read Google user data, unless we have your affirmative agreement, it is necessary for security purposes, to comply with applicable law, or the data is aggregated and anonymized for internal operations.