Marketing Privacy Policy

1. Purpose of this Policy

This Marketing and Communications Policy (the "Policy") governs the marketing, commercial communication, lead generation and customer engagement activities carried out by CommerceClarity in compliance with applicable law on the protection of personal data.

2. Scope

The Policy applies to all processing of personal data carried out for the purposes of direct marketing, analysis, commercial profiling, CRM management, communication with customers and prospects, events and promotional initiatives.

3. Purposes of Processing and Data Retention

CommerceClarity processes personal data for the following purposes:

3.1 Direct Marketing Communications

Sending commercial and informational communications relating to:

• software products and solutions
• platform updates
• new features
• product releases
• service improvements
• commercial offers
• promotional and discount campaigns
• free trials
• training and educational content
• newsletters
• industry news
• corporate communications

Communications may be sent by email, telephone, instant messaging, in-app notification and push notification.

3.2 Lead Generation and Business Development

These activities include:

• handling inbound requests
• qualifying commercial opportunities
• arranging product demonstrations
• scheduling discovery calls
• contacting potential customers
• managing the commercial pipeline

3.3 Marketing Automation

Use of automated systems for:

• personalisation of communications
• campaign management and scheduling
• automated follow-up
• audience segmentation
• lead scoring
• customer journey management

3.4 Customer Relationship Management (CRM)

Processing of data through CRM systems for:

• managing relationships with customers and prospects
• tracking commercial interactions
• recording communications
• supporting contract management
• improving the customer experience

3.5 Personalisation of Communications

Communications may be personalised on the basis of:

• previous interactions
• browsing on the website
• use of the services
• industry sector
• professional role
• company size
• geographical area
• commercial interests
• participation in events or campaigns

Personalisation does not produce legal effects or significant automated decisions.

3.6 Behavioural Analysis

Analysis of user interactions with:

• pages visited
• session duration
• navigation paths
• clicks and interactions
• downloads
• product usage
• email and campaign engagement

Purpose: improvement of marketing strategy, usability and performance.

3.7 Audience Segmentation

Data may be used to segment users on the basis of:

• professional profile
• industry sector
• stage of the customer lifecycle
• level of engagement
• geographical area
• interests
• purchasing behaviour

3.8 Measurement of Marketing Performance

Analysis of:

• campaign performance
• conversions
• newsletter engagement
• web traffic
• acquisition channels
• customer acquisition cost

3.9 Remarketing and Retargeting

Subject to consent where required, CommerceClarity may carry out:

• remarketing
• retargeting
• display advertising
• social media advertising
• search engine advertising

through cookies, pixels, SDKs or similar technologies.

3.10 Advertising Platforms

Third-party platforms may be used, such as:

• Google Ads
• LinkedIn Ads
• Microsoft Advertising
• Meta Ads
• other advertising networks

3.11 Newsletter Management

Activities relating to:

• newsletter subscription and management
• subscription preferences
• performance measurement
• content optimisation
• deliverability monitoring

Users may unsubscribe at any time.

3.12 Events, Webinars and Training

Management of:

• participant registration
• sending invitations and reminders
• training materials
• attendance management
• post-event surveys
• invitations to future events

3.13 Surveys and Market Research

Activities relating to:

• customer satisfaction
• product feedback
• usability testing
• market research
• industry studies
• beta testing programmes

3.14 Customer Success Communications

Communications aimed at:

• user onboarding
• product adoption
• best practices
• usage suggestions
• customer success initiatives

3.15 Product Recommendations

Suggestions based on:

• active subscriptions
• use of the platform
• user requests
• professional interests

3.16 Account-Based Marketing (ABM)

Business-to-business marketing activities addressed to specific organisations, based on corporate contact information.

3.17 Social Media Engagement

Processing of data in the event of:

• interactions with social media pages
• participation in campaigns
• comments and messages
• contact through social networks

3.18 Competitions and Promotions

Management of:

• participant registration
• eligibility checks
• allocation of prizes
• notification of winners
• legal formalities

3.19 Referral Programmes

Activities relating to:

• managing invitations
• allocating rewards
• fraud prevention
• programme administration

3.20 Marketing Assisted by Artificial Intelligence

Use of AI technologies for:

• content generation
• optimisation of communications
• campaign analysis
• user segmentation
• lead qualification
• predictive analysis
• recommendation systems

AI supports human decision making and does not produce solely automated decisions with significant legal effects.

4. Legal Basis for Processing

The processing of personal data is based on:

• the consent of the data subject
• the performance of a contract
• legal obligations
• the legitimate interest of the controller (marketing, business development and improvement of services), within the limits set by applicable law

Consent may be withdrawn at any time.

4.1 Retention

Data is retained for up to 24 months from the last contact, unless the data subject requests the withdrawal of consent or the erasure of the data.

5. Right to Object

The data subject has the right to object at any time to the processing of data for direct marketing purposes and to the profiling connected with it.

Where an objection is made, CommerceClarity will stop the processing without undue delay.

To exercise the right to object, write to: privacy@commerceclarity.com

6. Compliance with Applicable Data Protection Law

CommerceClarity is committed to maintaining compliance with applicable privacy and data protection laws in the jurisdictions in which it operates, including:

• Regulation (EU) 2016/679 ("GDPR");
• applicable Italian data protection legislation;
• other applicable international privacy requirements, where relevant.

Privacy and security practices are periodically reviewed and updated to reflect legal, operational and technological developments.

7. Children’s Data

The Services are intended for professional and business use and are not directed to individuals under the age of 18.

CommerceClarity does not knowingly collect personal data relating to minors. Where such data is identified, appropriate measures will be taken to delete it without undue delay.

8. Changes to this Notice

CommerceClarity reserves the right to update or modify this Notice at any time to reflect:

• legal or regulatory developments;
• operational changes;
• technological updates;
• changes to the Services.

The updated version will be published on the website together with the relevant effective date.

Continued use of the Services following publication of changes constitutes acceptance of the updated version of this Notice, where permitted by law.

9. Contact Information

For questions, requests or concerns regarding this Notice or the processing of personal data, please contact:

CommerceClarity S.r.l.

Via di Affogalasino 34, 00148 Rome (RM), Italy

Email: privacy@commerceclarity.com