This Privacy Policy explains how 727 SRLS collects, uses, shares and protects personal information when you use our customer support chatbot, including when we exchange support messages with you by SMS/MMS text message.
The data controller for the processing described in this policy is:
727 SRLS — società a responsabilità limitata semplificata (S.r.l.s.)
Registered office: Via Odoardo Tabacchi 3, 20136 Milano (MI), Italy
VAT number and tax code: 13678980965 · REA: MI-2738292
Website: https://727.services
Privacy contact: [email protected] · Support: [email protected]
Certified email (PEC): [email protected]
Where we handle support data on behalf of a client organisation under a written services agreement, that organisation is the data controller and we act as its processor. In that case, the organisation's own privacy notice also applies to you, and this policy describes how we handle the data as processor.
This policy covers the customer support chatbot (the "Service") that we make available inside the custom software we develop for our client organisations, and the two-way support conversations delivered through it, including SMS/MMS text messages.
The Service is provided for internal business use: it is made available to the employees, staff and other authorised users of organisations that have signed a contract with us. It is not a consumer marketing programme. We do not use it to send advertising, promotional or bulk marketing messages, and we do not purchase, rent, or import mobile phone number lists.
| Category | Examples | Where it comes from |
|---|---|---|
| Contact data | Name, business email address, mobile phone number, employer / client organisation | Your organisation, or you when you start a conversation |
| Support conversation content | The messages you send to the chatbot, our replies, ticket descriptions, screenshots or files you attach | You |
| Account and software data | User ID, role, product or licence configuration relevant to your request | Your organisation, our systems |
| Technical and delivery data | Timestamps, message identifiers, carrier delivery receipts and delivery status, IP address, device and application logs | Automatically, and from our messaging provider |
| Consent and opt-out records | Reference to the signed contract authorising support messaging, and your STOP / START history | Your organisation, you |
We do not seek to collect special categories of personal data. Please do not send passwords, payment card numbers, health information or other sensitive data through the chatbot or by text message.
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Answering product and service enquiries, account questions, troubleshooting and support requests, and providing general guidance | Performance of a contract; our legitimate interest in supporting our clients' authorised users |
| Sending you conversational support messages by SMS/MMS in reply to your request | Performance of a contract; consent documented in the agreement signed by your organisation and confirmed when you start the conversation |
| Routing your request to the right team and escalating it to a human specialist | Performance of a contract; legitimate interest |
| Quality assurance, diagnosing faults and improving the reliability of the Service | Legitimate interest (using aggregated or pseudonymised data where practicable) |
| Security, abuse prevention and protecting our systems and users | Legitimate interest; legal obligation |
| Keeping records of consent and of opt-out requests, and complying with telecommunications and other legal requirements | Legal obligation |
The chatbot uses automated processing to interpret your request and to draft responses. It does not make decisions that produce legal effects concerning you or similarly significantly affect you, and you can ask to be transferred to a human at any time. We do not use your personal information for advertising, and we do not sell it.
We receive your mobile number from the client organisation that engaged us, under the written contract it has signed with us; that contract states that support may be provided by text message, and your organisation is responsible for informing you of it. In practice, every messaging conversation is started by you: we reply to the messages you send us. We never buy, rent, or import phone number lists, and we do not send unsolicited messages.
Message frequency varies and depends entirely on your own use of the support service. Because the Service is conversational, you normally receive a message only in reply to one you have sent. As an indication, a typical support conversation involves approximately 2–10 messages, and many users receive no messages at all in a given month.
Message and data rates may apply. Any charges for sending or receiving text messages are set by your mobile carrier and are your responsibility. Please check your mobile plan for details.
You can stop receiving text messages from us at any time by replying STOP (or STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT) to any message. We will send a single confirmation message and then stop sending you SMS. To resume, reply START or simply write to us again. Reply HELP at any time, or email [email protected], for assistance. Opting out of text messages does not close your support request; we will follow up through another channel where one is available.
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
In plain terms: we do not sell, rent, trade, or otherwise share your mobile phone number, your SMS opt-in or consent, or the content of your text messages with any third party for marketing or promotional purposes, and we never share SMS opt-in or consent data with anyone. Your mobile number is disclosed only to the licensed communications providers strictly necessary to transmit the messages you have asked to receive — our messaging provider (Twilio Inc.) and the mobile network operators that deliver them — and only for that purpose.
We do not sell personal information, and we do not share mobile numbers or SMS consent with third parties or affiliates for marketing or promotional purposes.
We are based in the European Union and store support data within the European Economic Area wherever possible. Some of our providers (for example our messaging provider) may process data in other countries. Where personal data is transferred outside the EEA, we rely on an adequacy decision of the European Commission or on Standard Contractual Clauses together with supplementary safeguards where required. You can request a copy of the safeguards we use by writing to [email protected].
When a retention period ends, we delete the data or irreversibly anonymise it.
We protect personal information with technical and organisational measures appropriate to the risk, including encryption in transit (TLS), encryption at rest, role-based access control on a need-to-know basis, multi-factor authentication for administrative access, logging, and confidentiality obligations for our staff and suppliers. No method of transmission is completely secure; text messages in particular are not encrypted end-to-end, so please avoid sending confidential credentials or sensitive data by SMS.
Subject to the conditions in applicable law, you have the right to request access to your personal data, its rectification or erasure, restriction of processing, portability, and to object to processing based on our legitimate interests. Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal — for text messages, simply reply STOP.
To exercise your rights, write to [email protected]. We respond within one month, and we may need to verify your identity first. If we act as processor for your organisation, we will forward your request to it.
You also have the right to lodge a complaint with a supervisory authority — in Italy, the Garante per la protezione dei dati personali (www.garanteprivacy.it) — or with the authority of your country of residence.
If you are located in the United States, you may also have the right to request access to, correction of, or deletion of your personal information, and to opt out of the "sale" or "sharing" of it. We do not sell or share personal information as those terms are defined by US state privacy laws, and we do not use personal information for cross-context behavioural advertising.
The Service is a business tool intended for adults acting in a professional capacity. It is not directed to children, and we do not knowingly collect personal information from anyone under 16. If you believe a child has provided us with personal information, contact us and we will delete it.
We may update this policy from time to time. The current version is always published at this address, with the effective date shown at the top. If a change materially affects how we handle your information, we will give notice through the Service or through your organisation.
727 SRLS — società a responsabilità limitata semplificata (S.r.l.s.)
Privacy enquiries: [email protected]
Support: [email protected]
Certified email (PEC): [email protected]
Post: Via Odoardo Tabacchi 3, 20136 Milano (MI), Italy