Privacy notice of the “don Luigi Sturzo” chat
Artificial intelligence (Regulation (EU) 2024/1689, “AI Act”, Article 50). You are talking to an artificial intelligence system, not to a person. The answers are a generated historical reconstruction based on the writings of Luigi Sturzo and on records verified by the Foundation: they are not the words of the real person and may contain errors. Each answer states whether it was approved by the Foundation or generated live and not yet reviewed, and shows its sources.
1. Data controller
Fondazione Casa Natale Luigi Sturzo ETS, Caltagirone (CT), Italy.
Registered office: [DA COMPLETARE] · Tax code: [DA COMPLETARE]
Privacy e-mail: [DA COMPLETARE] · Certified e-mail (PEC): [DA COMPLETARE]
Data protection officer (DPO), if appointed: [DA COMPLETARE]
2. What the service does
The chat answers written questions about the life, works and times of Luigi Sturzo, in Italian, English, French, Spanish and German. Access is restricted: with the password provided by the Foundation, or from the reserved page of the casasturzo.it website for people with a portal account. You do not register with the chat and no profile is created.
3. What data we process
- The text of your question, the chosen language and the optional audience (visitor, school, university). To understand follow-up questions, up to 3 previous questions of the same conversation travel with it: they are used only to answer and are not stored.
- Automatic removal of personal data. Before a question is stored, the system replaces e-mail addresses, web addresses, telephone numbers, long numbers (5 digits or more) and recognised personal names (names of historical figures are kept) with placeholders. The page warns you and blocks sending when it recognises an e-mail address or a telephone number. Removal is automatic and may not catch everything: please do not enter personal data about yourself or others.
- Technical browsing data. The web server receives your IP address in order to deliver the pages. In the web server log the address is truncated (for example 93.51.0.0) and recorded with date and time, requested address, browser type and outcome. Passwords, access codes, cookies and authentication headers are not written to the log.
- Abuse protection. To limit the number of questions per visitor, a code derived from the IP address is computed with a random key that exists only in the server's memory, changes every day and is never written to disk.
- Cookies. Only one technical session cookie (“fcns_chat”, 12 hours) that remembers a successful sign-in. It holds a random code and its expiry, nothing that identifies you. It is strictly necessary for the service you request, so no consent is needed. No profiling cookies, no analytics or tracking tools, no external services in the page. Your language, audience and theme preferences stay in your browser's local storage and are not sent to us.
- Access from the Foundation's website. The website checks that you are signed in to the portal and passes to the chat only a single-use code, valid for 10 minutes, with the website name: no name, e-mail or user identifier reaches the chat. Your portal account is covered by the privacy notice of casasturzo.it.
We use no accounts, profiles or automated decisions with legal effects on you.
4. Purposes and legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Answering questions | Question, language, audience, previous questions of the conversation | Legitimate interest and the Foundation's cultural purposes in the public interest (Art. 6(1)(f) and (e) GDPR) [to be confirmed by the Foundation] |
| Improving the answers: anonymous collection of questions and detection of recurring questions, from which the editors prepare approved answers | Anonymised text, language, audience, outcome of the answer | As above [to be confirmed by the Foundation] |
| Security of the service and abuse prevention | Web server log with truncated IP, daily in-memory code, technical cookie | Legitimate interest in security (Art. 6(1)(f) GDPR) |
5. How long
- Anonymised question texts: 90 days, then deleted automatically every night. Aggregated counts (number of questions by language, audience and outcome) may be kept.
- Answers kept for repetition: when a question contains no names, addresses or other personal data and is not the follow-up of a conversation, the question and don Luigi's answer are stored, with no link to whoever asked, so that the same answer can be given to whoever asks the same question. The Foundation's editors review them; those never reviewed are deleted after 2 years.
- Groups of recurring questions (one representative text and up to 8 examples, already anonymised): kept for the editors [DA COMPLETARE: retention period].
- Database backups: nightly copies on the server, the last 7 are kept; extra copies made before updates and copies transferred to the administrator's computer [DA COMPLETARE: retention period].
- Web server log: the file is rotated when it reaches 50 MB; at most 5 previous files are kept, and they are deleted after 90 days in any case.
- Rate-limit code: memory only, at most 24 hours. Session cookie: 12 hours.
6. Who receives the data
- Aruba S.p.A. (Italy), provider of the virtual server running the chat and the database, in data centres in Italy: data processor.
- Anthropic, provider of the artificial intelligence model (Claude): only for answers generated live it receives the question, the previous questions of the conversation, the language, the audience and the passages found in the writings. Answers already approved by the Foundation do not go through Anthropic. Under its commercial API terms, Anthropic does not use data sent through the API to train its models by default and keeps it for a limited period. Anthropic also processes data outside the European Union, in particular in the United States: the transfer relies on the safeguards provided by the GDPR (standard contractual clauses in Anthropic's data processing agreement) [DA VERIFICARE: contracting entity and safeguards in the signed agreement].
- Authorised staff and editors of the Foundation, who only see anonymised questions and groups of recurring questions.
The chat, the question database and the web server log are hosted in the European Union (Italy). We do not sell or hand over data to third parties for commercial purposes.
7. Schools and minors
Questions sent with the “School” audience are treated like all others: only the anonymised text is kept. We ask teachers to remind students not to write names, classes, schools or other personal data.
8. Your rights
You may ask the controller for access, rectification, erasure, restriction of processing and portability, and you may object to processing (Articles 15–22 GDPR), by writing to the address in section 1. Because questions are stored without any link to you, the exact text and date may be needed to find them (Article 11 GDPR). You also have the right to lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it, Piazza Venezia 11, 00187 Rome), or with the authority of your country of residence.
9. Changes
We will update this notice if the service changes. The version date is shown at the top.