Registration

Preamble:  

Welcome to neggen, the chatbot developed by negg Group s.r.l. Our chatbot is designed to provide you with quick assistance, answer your questions about our cybersecurity products and services, and offer you personalised support. Your privacy is of paramount importance to us. This Privacy Policy describes how we process your personal data when you interact with our chatbot.  

Our chatbot is powered by artificial intelligence (AI). This means that it is a computer program designed to simulate human conversation and answer your questions based on the information it has been trained with.

How does the chatbot’s AI work? Our chatbot’s AI processes the text of your conversations to understand your requests and provide relevant answers. It is not a human being and has no consciousness, feelings or personal memories. Its responses are algorithmically generated and do not reflect individual opinions or beliefs.

Data Collection and Use: Interactions with the chatbot may be analyzed to improve its performance and ensure a more accurate and helpful user experience. However, these analyses are not used to train the underlying AI model. When such analyses are conducted, data is processed in an anonymized or aggregated form whenever possible, in order to protect your privacy.

Limitations of AI: It is important to understand that, although AI is advanced, it has limitations. It may not be able to understand all the nuances of human language, handle complex situations that require human judgement, or provide personalised advice that goes beyond its programmed capabilities. If you have any doubts or sensitive issues, we recommend that you consult a qualified human being.

Privacy Policy – Chatbot  Last Update: July 2025

This policy is provided in accordance with Regulation (EU) 2016/679 (GDPR) and Regulation (EU) 2024 on artificial intelligence (AI Act), in relation to the processing of personal data of users who access and use our public chatbot. This Privacy Policy is specific to the use of our chatbot and supplements our negg® Group | Privacy Policy. Please also refer to our General Privacy Policy for a complete understanding of our data processing practices.  

The processing concerns the interaction between users and a generative artificial intelligence system (chatbot) integrated into the Blog. The chatbot processes textual inputs provided by users to generate automatic responses in natural language. Users must register by entering their email address in the designated box in order to access the service. At the time of registration, they acknowledge having read and accepted neggen’s Privacy Policy and Terms of Use.

1. Data Controller

The Data Controller is: negg Group s.r.l.

 Legal address: Piazza del Popolo n. 18, 00187 Roma, Italia

 Email: privacy@negg.group

2. Personal data collected

In order to access the chatbot, users must complete the registration process by entering a valid email address, choosing a unique username and creating a secure password. All three fields are mandatory. The email address will be used to confirm the user’s identity. The username will serve as a public identifier within the platform, while the password must meet the security criteria required to protect the account from unauthorised access. Once all fields have been completed correctly, the user can proceed with submitting the registration form.   

During interaction with the chatbot, data voluntarily provided by the user in the text of conversations may also be collected.  

Types of data collected and their purpose:

Our chatbot automatically collects certain technical information about your use, such as your IP address (which is anonymised or truncated), device type, operating system, browser used, date and time of access. In addition, when you interact with our chatbot, all your conversations are recorded. This data is collected for the following purposes:

1. Provision of the interactive chatbot service to registered users.
2. Automated conversational simulations.
3. Statistical analysis and service operation based on the conversations.
4. Management of user accounts, including access security and abuse prevention.
5. System monitoring and logging activities to ensure proper operation, security, and regulatory compliance.

Personal Data: Please do not share personal or sensitive data during your interactions with the chatbot, unless it is strictly necessary for the management of your request. The data you voluntarily provide will be used exclusively for the purpose for which it was collected and as specified at the time of the request.

3. Legal basis of data collection

Personal data are processed for the following purposes:

• Consent of the data subject – Art. 6(1)(a) GDPR: for access, authentication, and provision of the service.
• Legitimate interest – Art. 6(1)(f) GDPR: for statistical analysis, service operation and improvement, user account management (including access security and abuse prevention), and system monitoring and logging activities.

Such processing is carried out in compliance with the transparency, traceability, and risk management requirements set forth by the AI Act.

In cases where special categories of data (e.g. sensitive data) are collected, explicit consent will be requested in accordance with Art. 9 GDPR.

Currently, conversations are not used to train the artificial intelligence that powers the chatbot. Should this change in the future, users will be provided with specific information and their explicit consent will be requested.

The processing of your conversations for the purposes indicated above is based on your explicit consent. You can withdraw your consent at any time by sending a request to privacy@negg.group and your account will be deleted as soon as possible. In some cases, data processing is based on our legitimate interest in ensuring the safe and optimal functioning of the service and continuously improving our offering, always in compliance with your fundamental rights and freedoms, in particular with regard to the processing of technical and usage data for security and aggregate analysis of chatbot performance (legal basis: legitimate interest – Article 6.1.f GDPR).

4. Processing and storage methods

The data is processed using electronic tools, in accordance with the principles of minimisation, security and storage limitation set out in the GDPR.

• Data retention: User data and system admin files are stored on servers exclusively used by negg and are retained for a maximum of 18 months.
• The servers exclusively used by negg, where the data is stored and retained, are provided by AWS Amazon Web Services, Inc.
• Conversely, conversation data transit through, but are not stored on, servers exclusively used by negg, operated by RunPod Inc.

5. Access to conversation history

The history of conversations with the chatbot is stored securely and is accessible only to authorised personnel within the organisation (administrators and developers) for the purposes indicated in Article 3. This data is not publicly visible or shared with external parties, except in cases provided for by law. All access is in compliance with current regulations on the protection of personal data.  

If the methods of accessing or sharing the history change, you will be sent an email explicitly requesting your consent.

6. Recipients of the data

Personal data may only be processed by authorised personnel who have been trained and are bound by confidentiality obligations, as well as by external service providers appointed, where necessary, as data processors pursuant to Article 28 of Regulation (EU) 2016/679 (‘GDPR’).  

Technical service providers include Amazon Web Services, Inc. (‘AWS’) and Runpod, Inc., which provide cloud infrastructure services. These providers are contractually bound to ensure an adequate level of personal data protection, including through the adoption of appropriate technical and organisational measures.

7. Transfers to third countries

Any transfers of personal data outside the European Economic Area will be carried out in accordance with Articles 44 et seq. of the GDPR, ensuring an adequate level of protection through standard contractual clauses or adequacy decisions.  

If your data needs to be transferred outside the European Economic Area (EEA), we will take all necessary measures to ensure an adequate level of protection, in accordance with applicable regulations (e.g. by using Standard Contractual Clauses approved by the European Commission or by verifying that the country of destination offers an adequate level of protection).  

We may be required to disclose your personal data in response to valid legal requests from public authorities, including national security or law enforcement requirements.

8. Rights of the data subject

As a data subject, you may exercise your rights under Articles 15-22 of the GDPR at any time, including:  

• access to personal data;  
• rectification or erasure;  
• restriction of processing;  
• withdrawal of consent;  
• objection to processing;  
• data portability;  
• complaint to the supervisory authority (Personal Data Protection Authority).

The data subject may submit requests related to the exercise of the rights guaranteed by the GDPR, as explained in this section, to the email address privacy@negg.group. This address is managed by the Legal Department, which promptly forwards the request to the Research & Development Department. The request is processed within one month; this period may be extended by two additional months if necessary, taking into account the complexity and number of requests. In such cases, negg will inform the data subject within one month of receiving the request.

9. Changes to this policy

We reserve the right to update this policy. Any changes will be communicated to the user with reasonable notice. Please check this page periodically.

10. Third-Party Service Providers

For the operation of our chatbot and for the purposes described in this policy, we may use third-party service providers, for example for secure data hosting, or usage analysis. These providers operate on the basis of contractual agreements that guarantee confidentiality, security and the processing of personal data in accordance with applicable data protection regulations (such as the GDPR).

Specifically, the servers exclusively used by negg, where the data is stored and retained, are provided by AWS Amazon Web Services, Inc.

Conversely, conversation data transit through, but are not stored on, servers/cloud platform exclusively used by negg, operated by RunPod Inc.

In some cases, the technologies used may involve the use of textual data – including copyrighted material such as books or articles – for artificial intelligence training activities using text and data mining techniques, as permitted by European legislation. However, authors or rights holders have the right to opt out, explicitly excluding their works from use for these purposes. In the absence of such formal exclusion, the content may be legally used for the development of AI systems.

Welcome to neggen, the free chatbot provided by negg Group s.r.l. (hereinafter referred to as ‘we’, “our” or ‘the Company’). Please read these Terms of Use (‘Terms’) carefully before you start using our chatbot. Accessing and using neggen implies full and unconditional acceptance of these Terms. If you do not accept these Terms, you will not be able to use the chatbot.  

Please note that neggen is an automated system based on artificial intelligence and you are not interacting with a human operator. The responses generated are the result of automatic processing of your inputs and do not constitute direct communication from the Company or its employees.

1. Purpose of the Service and Definitions

Purpose
neggen is designed to provide you with quick assistance, answer your questions about our cybersecurity products and services, and offer you personalised support. It is not intended as legal, financial, medical, or specific professional advice. The information provided by the chatbot is for informational purposes only and should not replace the advice of a qualified human being.  

In particular, neggen is a platform based on open-source generative artificial intelligence. Its main features are: dynamic text conversation, contextual memory for conversation.

Definitions:

For the purposes of these Terms and Conditions:

• “User” means any person who accesses or uses neggen.
• “Content” means the information, responses, suggestions or messages generated by neggen.
• “Service” means access to and use of the neggen chatbot made available through our website.

2. Acceptable Use

neggen is intended for users aged 16 and over. If you are under 16, please do not use the service without the consent of a parent or legal guardian.

You agree to use neggen responsibly and legally. By way of example and without limitation, you agree not to:

• Use the chatbot for illegal, fraudulent or unauthorised purposes.  
• Send content that is offensive, defamatory, threatening, discriminatory or that violates the rights of third parties.  
• Attempting to access, interfere with or damage the functioning of the chatbot, our servers or connected networks.
• Distributing malware, viruses or any other malicious code through the chatbot.
• Collecting personal information about other users.

3. Disclaimer of Warranties

neggen is provided ‘as is’ and ‘as available’, without any warranty of any kind, either express or implied. We do not guarantee that the chatbot will always be available, uninterrupted, error-free, or that the information provided will always be accurate, complete, or up to date. The Company disclaims all liability for any errors or omissions in the chatbot’s responses, as well as for any damage or loss resulting from the use or inability to use neggen.

4. Limitation of Liability

To the maximum extent permitted by applicable law, the Company shall not be liable for any direct, indirect, incidental, special, consequential or punitive damages, including, but not limited to, loss of profits, data or other intangible losses, arising out of the use or inability to use neggen. This includes liability for any service interruption, error or omission, regardless of the cause.

5. Intellectual Property

All intellectual property rights relating to neggen, including software, design, text and graphics, are the exclusive property of the Company. Use of the chatbot does not grant you any rights to such intellectual property.

It remains prohibited to attribute authorship or responsibility for the generated texts to the Company.

6. Licence of Use

You are granted a limited, non-exclusive, non-transferable and revocable licence to access and use neggen for personal and non-commercial use, in accordance with these Terms. You may not copy, distribute, modify or use the generated content for commercial purposes without the prior written consent of the Company.

7. Data Privacy

We are committed to protecting your privacy. Any information you provide to us during your interaction with neggen will be treated in accordance with our negg® Group | Privacy policy and neggen’s privacy policy. In any case, we recommend that you do not enter your own or third-party personal data in conversations with the chatbot.  

Please read our Privacy Policy carefully to understand how we collect, use and protect your data. Please note that conversations with the chatbot may be monitored and analysed to improve the quality of the service and for security purposes. During your interaction with the chatbot, we may collect technical data (such as IP address, device type, date and time of access) and conversation content for security, analysis and service improvement purposes. We do not collect sensitive personal data unless it is voluntarily provided. We encourage you not to share personally identifiable information when using the chatbot.

8. Changes to the Terms and Conditions

The Company reserves the right to change these Terms and Conditions at any time and at its sole discretion. The changes will take effect immediately upon publication on the website. Your continued use of neggen after the publication of the changes and acceptance via email will constitute your acceptance of the changes. If you do not accept the changes, you must cease using the service. We encourage you to review these Terms regularly to stay informed of any updates.

9. Termination of Service

The Company reserves the right to suspend or terminate access to neggen at any time, without notice and at its sole discretion, in the event of a breach of these Terms or for any other reason deemed appropriate by the Company.

10. Severability, Applicable Law and Jurisdiction

If any provision of these Terms is held to be invalid, illegal or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect.  

These Terms and Conditions are governed by and interpreted in accordance with Italian law. Any dispute arising from or relating to these Terms and Conditions or the use of neggen shall be subject to the exclusive jurisdiction of the courts of Rome.

11. Contact

If you have any questions or require clarification regarding these Terms of Use, please contact us at the following email address: privacy@negg.group.