Privacy Policy

This privacy policy is provided pursuant to art. 13 of EU Regulation 679/16 (hereinafter “GDPR”)


Data Controller

The data controller is Inclusive S.r.l. (VAT number 05173250282) (hereinafter referred to as “Inclusive” or “we”) with registered office in Piazza Alcide De Gasperi 45/A, ZIP code 35131 – Padua. The Data Controller can be contacted by PEC or email at or


We respect your privacy. This privacy policy applies every time you access our website and has the purpose of informing you about the object, the nature and the purpose of our processing of your personal data. Personal data is information that relates to an identified or identifiable individual. A person can be identified by their name, for example. On the other hand, a natural person is identifiable when it is possible to identify him or her by reference to certain identifiers, such as an online identifier, a telephone number, an e-mail address, location data, or one or more distinctive elements of their identity, whether physical, physiological, genetic, psychic, financial, cultural or social.
This Privacy Policy does not apply to other sites that can be reached via hypertext links found on the website. We reserve the right to make changes to this policy if any services and features are added to the Website, as well as to meet any technical-IT or legislative requirements.

Data processed and processing methods

Using and browsing our Website are generally possible without you providing any personal data, other than those required by Internet communication protocols or whose collection is automatic through cookies. For more detailed information on cookie settings and use, please click on the cookie policy page. Our Website does not knowingly collect data from minors under the age of 18. If you are under the age of 18, we reserve the right to make any necessary checks to ensure that there is a valid declaration of consent from the person exercising parental responsibility, where necessary.

Data provided to us on a voluntary basis.

If you are interested in receiving information on our way of working, on our services, if you want to become a SOQUA ambassador or tester, if you want to keep up to date on the progress of our App or if you are interested in trying its beta version, you can contact us by filling in the specific information request form on our Website. In this case, the data we acquire are only the contact data that you provide voluntarily, i.e. Your first name, last name, place of origin and e-mail address and, if you want, your telephone number as well as any other data contained in your message. To be sure that you have read the Privacy Policy, you will be asked to tick the box confirming that you have read it before submitting the form. The personal data communicated by you are processed using both electronic and/or automated tools and on paper, in both cases using methods that ensure security and confidentiality.

Data subsequently collected by us.

If you are interested in becoming a SOQUA ambassador you will be contacted by our team and we may ask you to provide your tax and payment details, where this is necessary to start and manage your contract with us. This data will be processed in accordance with this privacy policy.

Browsing data collected automatically.

When you access the Website, the computer systems and software procedures used to operate it automatically collect your browsing data. These include your IP address or the domain name of your computer, the addresses of the websites from which you have accessed the Website (by referral), the addresses of the requested resources in URI (Uniform Resource Identifier) notation, the time of such requests, the method used for submitting a given request to the server, the returned file size, the numerical code indicating the web server response status, and other parameters relating to your browser type (eg Internet Explorer, Google Chrome, Firefox), operating system (eg Windows) and IT environment. These data are acquired through technical and analytical cookies and are treated in an aggregate and anonymous form. This Website does not use any profiling cookies.

Purpose and lawfulness of processing

We process your personal data:
with your consent

  1. expressed with the optional, explicit and voluntary provision of your data by submitting the contact form on the Website after agreeing to this Privacy Policy, in order to manage and respond to requests for information;
  2. for direct marketing purposes, by sending newsletters and/or promotional materials in general, invitations to events, in relation to our services and the SOQUA APP, via e-mail, post, text message and/or telephone. Your consent for the marketing purposes described here is optional and does not in any way affect your browsing experience on the Website or your ability to get in touch with us and receive information about our services. You can agree to the processing of your data for this purpose by ticking this box: I agree [I have read the Privacy Policy and agree to the processing of my personal data.*] Consent for this purpose may be withdrawn at any time by simply ticking the “opt-out” box at the bottom of our messages. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  3. to the use of cookies, except those use to analyse user behaviour, to use web services and monitor their correct functioning. Consent to the use of cookies for automatically collected data can be provided via the settings in the short privacy policy pop-up that appears the first time you visit the Website. You can disable some or all cookies at any time by following the instructions in our cookie. policy [hypertext link]. However, please be aware that disabling cookies could compromise your browsing experience on our Website and the use of our services.
  4. to improve and maintain our Website, based on our legitimate interest in improving our offer;
  5. in order to assign you the role of SOQUA ambassador and to provide you with the relevant benefits, where necessary for the execution of the pre-contractual measures requested by you and/or for the correct execution of the contract;
  6. for the administrative and tax management of your role as ambassador, as necessary for the fulfilment of our tax and accounting obligations;
  7. to manage any disputes, where necessary to defend or assert our right in court.

Providing your data for the purposes under v. and vi. is a prerequisite for starting your contract as a SOQUA ambassador. Failure to provide your data will affect your ability to enter into a business relationship with us.

Data dissemination

Your personal data will not be disseminated.
For the purposes indicated above, your personal data may, however, be disclosed to some specific categories of subjects such as:

  1. employees and collaborators of Inclusive, in their capacity as persons authorised to process data and/or system administrators;
  2. third parties who perform specific tasks or services that are necessary to fulfil the aforementioned purposes, operating as data processors (e.g. providers of IT services and infrastructures, consultants and professionals who offer banking, administrative, accounting and legal services, individuals who provide promotional and communication services in general, including the organisation of meetings and events aimed at promoting our services);
  3. Judicial or administrative authorities for the fulfilment of legal obligations.

The list of recipients can be made available to you at your request.

Data retention

The personal data you provide for the purpose of obtaining information on the SOQUA App and its services are processed only to the extent necessary to reply.
If you have agreed to the processing of your data for marketing purposes, your data will be processed for a period not exceeding 2 (two) years from the time of their collection.
For the administrative and accounting management of your relationship with Inclusive in your role as SOQUA ambassador, your personal, tax and contact details will be processed for the entire duration of the contract and subsequently for 10 (ten) years from its termination to comply with accounting and tax obligations. In the event of a dispute, your data will also be processed for as long as necessary to manage the dispute. At the end of the retention period as identified above, personal data will be irreversibly anonymised or destroyed securely.

International data transfers

Your personal data are stored on servers located both within the EU/EEA area or transferred to third countries, such as the USA, which ensure adequate levels of data protection based on the assessments made by the EU Commission.

Automated processes

Your personal data are not subject to any fully automated decision-making process, including profiling.

Your rights according to articles 15 to 22 of the GDPR

You can at any time:

  • request access to your personal data and any relevant information; the correction of inaccurate data or the integration of incomplete ones; the cancellation of personal data concerning you (upon the occurrence of one of the conditions indicated in art. 17, paragraph 1 of the GDPR and in compliance with the exceptions provided for in paragraph 3 of the same article); restrict the processing of your personal data (upon the occurrence of one of the conditions indicated in article 18, paragraph 1 of the GDPR);
  • request and obtain – in the event that the legal basis for the processing is a contract or consent, and the same is done in an automated way – that your personal data is transferred to you in structured, machine-readable formats, also in order to disclose such data to another data controller (the so-called right to data portability);
  • object at any time to the processing of your personal data in the event of particular situations concerning you as well as, even regardless of the occurrence of such situations, to the processing of your data for direct marketing purposes.

How to exercise your rights

You can exercise your rights at any time by sending a registered letter with return receipt to Inclusive S.r.l., Piazza Alcide De Gasperi n. 45 / A, CAP 35131 – Padua, or a certified/regular e-mail to or, or by filling in and sending to the above addresses the relevant form that you can download from the Italian Data Protection Authority website under “Forms and online services”.

Right to complain

If you believe that the processing of your personal data carried out through this website breeches the provisions of the GDPR, you can lodge a complaint with the Italian Data protection Authority –, based in Piazza Venezia 11, IT-00187 , Rome, e-mail:, pec:, or take legal action in the competent court.