Last updated: June 2026

Privacy Notice pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR)

This Privacy Notice describes how personal data are processed when accessing and browsing the POLARIN Data Hub website.

The POLARIN Data Hub is developed within the framework of the POLARIN project, funded by the European Union, is committed to ensuring the protection of personal data in compliance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

1. Data Controller

The Data Controller is:

ETT S.p.A.
Via Enrico Albareto 21
16153 Genoa, Italy
VAT No. IT03873640100

For any questions concerning this Privacy Notice or to exercise your rights under the GDPR, you may contact the Data Controller through the Contact the Data Controller form.

2. Scope

This Privacy Notice applies exclusively to the POLARIN Data Hub website and governs the processing of personal data collected through users’ interaction with the website.

3. Categories of personal data

When visiting the website, the following categories of personal data may be processed:

• IP address (processed by analytics services in accordance with their configuration);
• browser type and version;
• operating system;
• device type;
• language settings;
• approximate geographic location (country or city level);
• pages visited;
• navigation behaviour and interaction with website content;
• date and time of access;
• referring website or traffic source.

The website does not require user registration and does not intentionally collect special categories of personal data as defined in Article 9 GDPR.

4. Purposes and legal basis of processing

Personal data are processed for the following purposes:

Website operation

Technical information is processed to ensure the proper functioning, security and availability of the website.

Legal basis: Article 6(1)(f) GDPR – Legitimate interest.

Website analytics

Subject to the user’s consent where required, anonymous or pseudonymised analytics information is collected through Google Analytics 4 in order to:

• understand website usage;
• analyse traffic patterns;
• improve website usability and performance;
• produce aggregated statistical reports.

Legal basis: Article 6(1)(a) GDPR – Consent.

Users may withdraw their consent at any time through the cookie preferences available on the website.

5. Cookies

The website uses technical cookies necessary for its operation and, subject to the user’s consent, analytical cookies provided by Google Analytics 4.

Cookie preferences are managed through the website’s Consent Management Platform (Complianz).

Further information is available in the Cookie Policy.

6. Google Analytics

The website uses Google Analytics 4, a web analytics service provided by Google.

Google Analytics helps understand how visitors interact with the website by collecting statistical information such as page views, session duration, device information and approximate geographic location.

Where applicable, IP anonymisation and privacy-enhancing settings are enabled to minimise the amount of personal data processed.

Google may process certain information on servers located outside the European Economic Area in accordance with applicable data protection legislation and appropriate safeguards adopted under Chapter V of the GDPR.

7. Data retention

Personal data are retained only for the period necessary to achieve the purposes described above.

Analytics data are retained according to the retention period configured within Google Analytics and are automatically deleted once that period expires.

Technical data may be retained for the time necessary to ensure website security and proper functioning.

8. Data recipients

Personal data may be processed by:

• authorised personnel of the Data Controller;
• service providers acting as data processors under Article 28 GDPR;
• providers of website hosting and infrastructure services;
• Google LLC for analytics services, where consent has been provided.

Personal data will not be sold or disclosed to third parties for marketing purposes.

9. International data transfers

Where personal data are transferred outside the European Economic Area, such transfers are carried out in accordance with Articles 44–49 GDPR and are subject to appropriate safeguards, including, where applicable, the European Commission’s adequacy decisions or Standard Contractual Clauses.

10. Data security

The Data Controller implements appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

11. Rights of data subjects

Data subjects have the right to:

• obtain confirmation as to whether personal data are being processed;
• access their personal data;
• request rectification of inaccurate or incomplete data;
• request erasure where applicable;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive their personal data in a structured, commonly used and machine-readable format where applicable;
• withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal;
• lodge a complaint with the competent supervisory authority.

12. Exercising your rights

Requests concerning the exercise of GDPR rights may be submitted through the contact form available on this website.

The Data Controller will respond without undue delay and, in any event, within one month of receipt of the request, in accordance with Article 12 GDPR.

13. Changes to this privacy notice

This Privacy Notice may be updated from time to time to reflect legal, technical or organisational changes.

Users are encouraged to review this page periodically for the latest version.