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Of Your Data

Privacy Policy

Last updated: 25 March, 2026

Welcome! At ICOA Srl ("we", "us", or "our"), we respect your privacy and are committed to protecting your personal data. This simplified Privacy Policy explains how we collect, use, and look after your personal data when you visit our websites (including icoa.it and eu-bundle.workspace.it) or use our IT, Cloud, and Web services, in compliance with the EU General Data Protection Regulation (GDPR) and the UK GDPR.

1. Who we are

ICOA Srl is the Data Controller responsible for your personal data.

• Registered Office: Via del Poggio Laurentino, 9, 00196 – Rome, Italy
• VAT/Tax ID: 01610151001
• Email: info@icoa.it / helpdesk@icoa.it

2. What data do we collect?

Depending on how you interact with us, we may collect the following types of data:

• Identity & Contact Data: Name, email address, phone number, company name, and job title (especially when you fill out forms on our landing pages or contact us for a consultation).
• Technical & Usage Data: IP address, browser type, time zone, and information about how you navigate and use our websites (collected via cookies and analytics).
• Service & Support Data: Information related to the IT and Cloud services you purchase or ask support for via our Helpdesk.

3. Why do we collect your data and on what legal basis?

We will only use your personal data when the law allows us to. We use your data for the following purposes:

• To provide our services: To register you as a client, process your orders (e.g., Google Workspace, Microsoft 365, VoIP services), and provide customer support. Legal basis: Performance of a contract.
• To respond to your inquiries: When you submit a form on our websites or landing pages to ask for a quote or information. Legal basis: Legitimate interest and/or taking steps prior to entering a contract.
• To improve our website and services: Analyzing website traffic and usage. Legal basis: Legitimate interest (or Consent, where required for non-essential cookies).
• For marketing purposes: Sending you newsletters or promotional offers about our bundles and services. Legal basis: Consent (which you can withdraw at any time).

4. Who do we share your data with?

We do not sell your data. However, to provide our services, we may need to share your data with trusted third parties, including:

• Technology Partners: Such as Google Cloud, Microsoft, and 3CX, whose platforms we resell, configure, and manage.
• Service Providers: IT support systems, website hosting, and analytics providers.
• Legal and Regulatory Authorities: If required by law.

5. International Data Transfers (EU & UK)

Because we use global technology partners (like Google and Microsoft), your data may occasionally be transferred outside the European Economic Area (EEA) or the UK. When this happens, we ensure a similar degree of protection is afforded by using legally approved transfer mechanisms, such as Standard Contractual Clauses (SCCs) or relying on Adequacy Decisions.

6. How long do we keep your data?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements. For example, contact form inquiries are generally kept until the inquiry is resolved, while customer contracts are kept for legal and tax purposes for up to 10 years.

7. Your Legal Rights

Under the EU and UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Correct any inaccurate or incomplete data.
• Erase your personal data (the "right to be forgotten").
• Restrict or Object to our processing of your data.
• Portability: Request the transfer of your data to another service provider.
• Withdraw Consent at any time (e.g., for marketing emails).

If you wish to exercise any of these rights, please contact us at info@icoa.it. You also have the right to make a complaint at any time to your local Data Protection Authority (e.g., the Garante per la protezione dei dati personali in Italy, or the Information Commissioner's Office (ICO) in the UK).

8. Cookies

Our websites use cookies to improve your experience. For full details on the types of cookies we use, how long they last, and how to manage your preferences, please consult our website https://icoa.it

General Terms and Conditions of Service

Last updated: March 25, 2026

These General Terms and Conditions ("Terms") govern the contractual relationship between the Client (whether an individual, professional, SME, public entity, or other legal entity) and ICOA Srl ("ICOA" or "we") for the provision of consulting, IT, Cloud, and Web development services.

Please note that this is a simplified version of our terms designed for clarity and ease of reading. The full and legally binding text of our General Terms and Conditions of Supply is available upon request by writing to info@icoa.it.

By accepting an Order or using our Services, you agree to be bound by these Terms.

1. Definitions

• Services: ICT consulting, managed support, cloud infrastructure (IaaS), platforms (PaaS), software (SaaS), software development, and related services provided by ICOA.
• Client Data: Any information, content, or data provided by the Client or generated during the provision of the Services (excluding newsletter subscriber data).
• Third-Party Vendor: Any supplier ICOA uses to partially or fully provide the Services (e.g., Google Cloud, Microsoft, AWS, 3CX, ISPs).

2. Provision of Services and Third Parties

The specific Services provided are described in the Proposal, Order Form, or Service Agreement signed by both parties.

You acknowledge and agree that ICOA may use Third-Party Vendors to deliver part or all of the Services. ICOA reserves the right to change the location of data centers or infrastructure with a 60-day notice (30 days if initiated by a Third-Party Vendor). If such changes are significant and unfavorable, you have the right to terminate the contract with a 30-day notice.

3. Pricing and Payments

Prices are specified in Euros (EUR) in the Proposal or Order Form. Unless stated otherwise, payments are required in advance.

• Price Variations: ICOA reserves the right to modify prices with a 60-day written notice. You may terminate the agreement without penalty within this period. For resold Third-Party Services (e.g., Google Workspace, Microsoft 365), prices may vary upon annual renewal based on the Vendor's price list increases, with a 30-day notice.
• Exchange Rates: For Third-Party Services billed in currencies other than EUR, the price is based on the European Central Bank exchange rate plus a 5% flat surcharge to cover currency risk.
• Late Payments: Late payments will automatically incur statutory interest. ICOA may charge a €50.00 administrative fee for each written reminder.

4. Duration, Renewal, and Termination

• B2B Clients (SMEs, Public Entities): Unless otherwise agreed, the contract duration is 12 months from activation, automatically renewing for successive 12-month periods. You may cancel the renewal by providing written notice via certified email (PEC) or registered mail at least 90 days before the expiration date.
• Consumers (Individuals): Contracts do not automatically renew without explicit written consent. Consumers may terminate at any time with a 30-day notice, without penalties, except for services already rendered.

5. Service Level Agreements (SLA) and Best Effort

Where applicable, SLAs represent service targets, not strictly legally binding commitments. For support tickets, ICOA aims to respond within 3 business days. ICOA's liability for SLA failures is limited to proportional service credits, not exceeding the monthly fee. Requests outside defined SLAs are handled on a "Best Effort" basis, depending on internal organization.

6. Client Responsibilities and Acceptable Use

You are fully responsible for the safekeeping of your access credentials. You guarantee that all Client Data and your use of the Services are lawful, correct, and do not violate third-party rights (e.g., copyright, privacy) or include malicious activities (e.g., malware, spam). Violating these terms allows ICOA to immediately terminate the contract, suspend services, and retain paid amounts as a penalty.

7. Intellectual Property (IP)

• Custom Software and Digital Assets: For software, websites, or digital assets (videos, graphics) developed by ICOA, we grant you a non-exclusive, perpetual, non-transferable license upon full payment. ICOA retains full ownership of the source code, project files, and underlying methodology unless explicitly agreed otherwise in writing (Buyout).
• Third-Party and Open Source Software: Software or components from third parties (including open-source licenses like GNU, MIT) are governed by the respective original licensor's terms. You are responsible for compliance with these external licenses.

8. Limitation of Liability

To the maximum extent permitted by law, ICOA is not liable for indirect damages, loss of profits, data loss, or damages resulting from Third-Party Vendors, Client negligence, or force majeure events. Except in cases of willful misconduct or gross negligence, ICOA's total liability is strictly limited to 25% of the annual fee paid for the specific Service causing the dispute.

9. Third-Party SaaS and Cloud Services

When ICOA acts as a reseller for Third-Party SaaS (e.g., Google Workspace, Microsoft 365):

• Vendor Terms: You agree to abide by the original Vendor's Terms of Service and SLAs. ICOA is not liable for Vendor outages.
• Suspension for Non-Payment: If you fail to pay for third-party services, ICOA may suspend access with a 7-day notice. Prolonged non-payment will result in "Billing Offboarding," transferring billing responsibility directly to you and potentially causing the Vendor to suspend or delete your data.

10. Data Protection and Confidentiality

• GDPR Compliance: Both parties will comply with the EU and UK GDPR. ICOA acts as a Data Controller for your contact and billing information. When ICOA processes your end-users' data (e.g., hosting your databases, managing newsletters), ICOA acts as a Data Processor, and a separate Data Processing Agreement (DPA) will apply.
• Confidentiality: Both parties agree to keep all technical, commercial, and organizational information strictly confidential and not to disclose it to third parties without prior written consent, except where required by law.

11. Data Switching (Data Act Compliance)

For ICOA's proprietary Cloud and SaaS services, and in compliance with EU regulations, you have the right to switch providers. You must provide a 60-day notice. ICOA will provide reasonable assistance to export your data in a standard format. If you terminate a fixed-term contract (lock-in period) early, you remain responsible for paying the remaining fees for the entire agreed term to cover our third-party commitments.

12. Governing Law and Jurisdiction

These Terms are governed by Italian Law. Any disputes arising from these Terms will be subject to the exclusive jurisdiction of the Courts of Rome, Italy, except for Consumers, who may rely on their local consumer courts. Before pursuing legal action, parties agree to attempt an amicable resolution.

Specific Approval (Art. 1341 Italian Civil Code)

The Client declares to have read and expressly approves the following clauses: Art. 2 (Provision of Services and Third Parties), Art. 3 (Pricing and Payments), Art. 4 (Duration, Renewal, and Termination), Art. 7 (Intellectual Property), Art. 8 (Limitation of Liability), Art. 9 (Third-Party SaaS), Art. 11 (Data Switching), and Art. 12 (Governing Law and Jurisdiction).