Tracking pixel

Use of tracking pixels in emails – Extended privacy notice

Introduction

This ‘extended privacy notice’ is provided in accordance with Article 13 of European Regulation 2016/679 (GDPR) and Article 122 of Legislative Decree 196/2003 (Privacy Code) and the Order of 17 April 2026 issued by the Data Protection Authority concerning the use of ‘tracking pixels’ in email communications.

It also supplements the other privacy notices available on the website and, together with them, provides all the elements required by Article 13 of the GDPR and by further Orders of the Data Protection Authority.

Subject matter of the notice

In its email communications, our company uses tracking technologies that make use of so-called ‘tracking pixels’ to collect certain information about recipients, which may include personal data. Consequently, this notice is intended to explain to the user, in a clear and precise manner, the purposes and methods of use.

Definition of a tracking pixel

Tracking pixels are very small images embedded within emails in the form of hyperlinks. When the recipient opens the email, a code embedded in the message can automatically trigger a request to the server to download the image. This mechanism enables the sender to collect information, for example on whether messages have been opened and on any deletion, forwarding or archiving, as well as data about the recipient, such as the IP address and the type of device used.

Tracking pixels used and their purposes

The purposes for which our company may use tracking pixels are set out below:

• Anonymous and aggregated statistics: pixels are used to obtain overall statistics on the opening of messages, in order to improve email deliverability and combat spam, which also benefits the user. The recipient’s consent is not required for this use.
• Security: pixels are necessary to implement specific security measures, for example those connected with the authentication procedure for the provision of services requested by the user, for which it is relevant to obtain information on the opening of messages. The recipient’s consent is not required for this use.
• Institutional or service-related communications: pixels are used for particularly important communications, for which it is relevant to verify that they have actually been taken note of, by means of information on the opening of messages (e.g. communications regarding contractual changes, security incidents, deadlines and compliance obligations, etc.). The recipient’s consent is not required for this use.
• Promotional purposes/activities: information on the opening of messages, collected via pixels, is used to evaluate and improve our company’s promotional campaigns, for example by adapting their frequency to the interest shown by recipients.

  Such use may be carried out only with the prior consent of the recipient of the emails. Consent, as expressly provided for by the legislation, may be included within the more general consent to receive promotional communications, obtained prior to the inclusion of the address on the ‘mailing lists’, subject to the exceptions provided for in relation to ‘soft spam’. As set out in more detail below, consent may be withdrawn at any time and the recipient may choose either to stop receiving promotional communications or to continue receiving them without tracking pixels.

Data collected via tracking pixels

Tracking pixels may enable our company to collect certain personal data of recipients, closely connected with information on the opening of messages, such as the IP address, the type of device used, the time spent viewing messages and similar information.

Such data will be managed in full compliance with current legislation, limiting processing to what is strictly necessary to achieve the purposes pursued, in line with the principle of minimisation enshrined in the GDPR.

Computer settings to prevent tracking

Recipients are reminded that tracking, regardless of the purpose of the communications, can occur only if the ‘download’ of images is enabled. If the user reads the email in text-only format, the pixel, like the other images, is not downloaded and cannot perform its tracking function.

Withdrawal or ‘granular’ amendment of consent

The user/recipient of the emails may, at any time, withdraw or amend their consent on a ‘granular’ basis, in particular by choosing whether to stop receiving communications or to continue receiving them without tracking pixels.

Specifically, the user will be able to manage their choices easily by using the dedicated links and buttons included in each email received.

Legal basis for processing

With regard to the use of tracking pixels for statistical and security purposes and/or for sending institutional or service communications, the processing is necessary to optimise the services provided to users. The legal basis may, depending on the circumstances, be the legitimate interests of the data controller and the recipients, the performance of contractual or pre-contractual measures at the data subject’s request, and/or the fulfilment of legal obligations by the data controller.

For the use of tracking pixels for promotional purposes, the legal basis is the consent optionally given by the user, which may be withdrawn or amended at any time.

Recipients or categories of recipients of personal data

The data may be disclosed to third parties only to comply with legal or contractual obligations and to give effect to the user’s choices and/or any requests. The data will not be disseminated under any circumstances.

Persons authorised to perform processing

The data will be processed exclusively by personnel specifically authorised and designated for that purpose.

Rights of the data subject

The user has all the rights laid down in the European Regulation, including the right to request access to their personal data, to have it rectified, to have it erased, to obtain restriction of processing, to object to its processing, and to data portability. The user also has the right to lodge a complaint or submit a report to the Supervisory Authority, namely the Data Protection Authority, or to bring an action before the courts.

Transfers to third countries

Any transfer of personal data to a third country outside the European Union or to an international organisation will take place on the basis of a Commission adequacy decision, or, in the case of transfers referred to in Articles 46, 47 or 49, second paragraph, of the European Regulation, on the basis of appropriate and suitable safeguards.

Data controller

The data controller is Motovario S.p.A. – a single-member company, with registered office in Via Quattro Passi 1/3, Formigine (MO).

Data protection officer

The data protection officer is Mr Juri Torreggiani, with office located at Via Piccard 16/G, Reggio Emilia. Any request for clarification or information may be addressed to this officer.

This notice may be supplemented, orally or in writing, with further details and guidance to best meet any need for information on the subject of ‘Privacy’ and to keep pace with regulatory developments.

Date on which this document was drawn up: 14/10/2026