Legal notices

Privacy notice

Last updated: 21 ottobre 2026

1. 1. Data controller
2. 2. Visitors to the site
3. 3. Anyone who sends us a request
4. 4. Customers and users of the portal
5. 5. People named in the documents
6. 6. Who we share data with
7. 7. Transfers outside the European Union
8. 8. Cookies
9. 9. Your rights
10. 10. Changes

1. Data controller

The data controller is Esquad S.r.l., with registered office in Via Pedro Alvares Cabral 6, 87036 Rende (CS), codice fiscale and partita IVA 10229340962, owner of the trademark Complify. For any request concerning data protection you can write to assistenza.clienti@complify.it. The Data Protection Officer (DPO) can be contacted at esquad@legalmail.it.

2. Visitors to the site

When you visit these pages, our servers record the technical data of the request — IP address, browser, page visited, date and time — to ensure the security and operation of the service. The legal basis is our legitimate interest (art. 6(1)(f) of the GDPR). The technical logs are kept for the time strictly necessary, normally not beyond thirty days.

The public pages do not use cookies, contain no third-party measurement tools and do not load resources from other sites.

3. Anyone who sends us a request

With the request form we collect name, business email, the type of request (briefing, meeting, trial or demo), the topic you are interested in (business information, anti-money laundering or both) and any campaign tags from which you arrive, in order to reply to your request and, if you ask for it, to activate the trial: the processing is necessary to follow up the request and to take pre-contractual steps requested by you (art. 6(1)(b) GDPR). To prevent abuse of the form we keep an encrypted fingerprint of the IP address, from which the address cannot be derived, on the basis of our legitimate interest. If the request does not turn into a relationship, the data is kept for twenty-four months from the last contact.

4. Customers and users of the portal

For portal users we process the user data (name, email, organisation), the access and usage logs and, for the organisation, the invoicing data. The data are processed to provide and manage the service, to ensure its security and to comply with tax and accounting obligations. The legal bases are, as the case may be, the contract (art. 6(1)(b)), the legitimate interest of Esquad S.r.l. in the management and security of the Service (point (f)) and legal obligations (point (c)). The data are kept for the duration of the relationship and, afterwards, for the periods required by law; accounting documents are kept for ten years.

BIAI, the Complify assistant. If your organisation has activated BIAI, the Complify assistant, we process the messages you write in the chat and the assistant's replies, the names and topics of the reading tools the assistant uses (for example a codice fiscale searched for), the page you are writing from, the ratings you give to replies and the technical data of the conversation (date, organisation, user, amount of text processed). We do not keep the data the assistant reads in order to reply to you, which stays in your archive. The purposes are to assist you in using the platform, to oversee its correct use, to control its costs and to improve the quality of replies; the legal basis is our legitimate interest (art. 6(1)(f) GDPR) in offering effective assistance. We keep conversations for twelve months. The assistant also keeps a memory of your organisation: short notes on preferences, frequently followed subjects and corrections to replies, which arise when you ask for them, when you flag a reply as wrong or, automatically, from conversations. The notes can be viewed and deleted from the assistant panel and are kept for twenty-four months. To generate replies the text is processed by Anthropic, our supplier (processor). The assistant is an automated system: it makes no decisions about you or about the subjects in the archive, and you can ask to speak to a person at any time. If you ask for a person, a short summary of the conversation and the codice fiscale of the subject opened are communicated to the supplier of the chat service; if signed identity is active, also your name, your email, the name of your organisation and your role. You can exercise your rights under art. 15 et seq. by writing to assistenza.clienti@complify.it.

5. People named in the documents

The documents our customers buy contain data on natural persons who hold positions or shareholdings in companies, or who are themselves the subject of a check: identification data, positions, shareholdings, protesti and pregiudizievoli, real estate, presence on sanctions lists or lists of politically exposed persons, press reports. The data are not collected directly from the data subjects, but come from public sources and lawfully accessible databases, in compliance with applicable regulation, including the Business Register, filed financial statements, the land registry, the registers of protesti and of pregiudizievoli, international sanctions lists and the press.

For the Report Titolare Effettivo Estero the documents also contain, for the subjects in the ownership chain and for the proposed beneficial owners, identification data and personal details (name, date and place of birth), citizenship, residence or tax domicile, positions and shareholdings, taken from Italian and foreign public registers and from the other sources accessible to Esquad S.r.l., which processes them manually with its own staff.

For the companies being checked and for their directors, the documents may also contain matches from open sources on the web — search engines, news sites, public administration records published online — over the last ten years, attributed to a person only when the source names them together with the company. These may include news about legal proceedings, which we report with the stage declared by the source.

In the course of its business information activity, Esquad S.r.l. processes such data as an independent controller.

The purpose is to provide our customers with the business information needed to assess the reliability of their counterparties and to meet anti-money laundering obligations. The legal basis is the legitimate interest of Esquad S.r.l. and of our customers (art. 6(1)(f)) and, where provided for by law, compliance with legal obligations (art. 6(1)(c)). The service is provided by virtue of licenza prefettizia ex art. 134 TULPS. People named in the documents can exercise the rights described in point 9, including the right to object to processing and to ask for an inaccurate item of data to be corrected.

The data remain in the document for the whole life of the dossier of the customer organisation that bought it, which receives them as an independent controller, and are deleted together with it. This notice is given by publication on this site, because communicating it to each data subject would require disproportionate effort (art. 14(5)(b) GDPR).

6. Who we share data with

The data are processed by our authorised staff and by suppliers acting on our behalf as processors: cloud services on which the portal is hosted, in the European Union; email services; the support chat service, reserved for users who have signed in; language-processing services used to draft the summary of the assessments and for the assistant's replies, provided by Anthropic, PBC, c/o Corporation Service Company, 251 Little Falls Drive, Wilmington, DE 19808, USA (Delaware File Number 4860621, LEI 984500B6DEB8CEBC4Z70). The information in the documents is disclosed to the customers who buy them. The data may be disclosed to the authorities that request them by law. The list of processors is available on request.

7. Transfers outside the European Union

When a supplier processes data outside the European Union, the transfer takes place with the safeguards provided for by articles 44 et seq. of the GDPR, such as the European Commission's adequacy decisions or standard contractual clauses.

8. Cookies

The public pages do not use cookies. The restricted area uses a single technical session cookie, needed to keep you signed in, which does not require consent. We do not use profiling cookies.

9. Your rights

In the cases and within the limits laid down by arts. 15-22 GDPR, you can exercise the rights of access, rectification, erasure, restriction of processing, data portability and objection to processing based on legitimate interest, by writing to the contact details in point 1. You also have the right to lodge a complaint with the Garante per la protezione dei dati personali (garanteprivacy.it).

10. Changes

We update this notice when the processing changes, publishing it on this page with the date of the update.