Marketing & Electronic Communications Policy
This policy governs newsletters, email, telephone and other Firmato promotional communications and distinguishes them from strictly operational notices needed for accounts, security, billing, signing and support.
1. Service communications vs marketing
Email verification, OTP, security notices, signature notifications, invoices, renewal notices, incidents and support messages are service communications and do not require marketing consent where necessary for the relationship. Newsletters, offers, cross-selling and promotional campaigns follow the applicable marketing rules.
2. Consent and permitted alternatives
Where national ePrivacy law requires prior consent, Firmato uses a freely given, specific, informed and unambiguous opt-in that is not pre-ticked. Where law permits communications to existing customers for similar own products/services (“soft opt-in”) or specific B2B professional outreach, UESE applies those exceptions narrowly and always provides a simple, free opt-out.
3. Preference evidence
Firmato records status, source, timestamp and the version of the notice/form used. Withdrawal is implemented in UESE-controlled systems without undue delay and retained in a suppression list to the extent necessary to respect the objection.
4. Segmentation and lead scoring
Segmentation may consider trial status, plan, sector, country, service use, commercial interactions and relationship status. Special categories are not used for marketing. Lead scoring is for commercial organisation and ordinarily does not produce legal or similarly significant effects.
5. Contact centre
Operators may record call outcomes, notes and follow-ups. They must respect preferences, applicable opposition lists and national rules on timing, numbers and commercial outreach. Sender identity must not be hidden and aggressive or misleading practices are prohibited.
6. Partner messages
Partners and referrers may not send communications in UESE’s name without a mandate and approved rules. Each partner is responsible for its own databases and legal bases unless a written agreement provides otherwise.
7. Withdrawal and objection
Every promotional email contains a simple unsubscribe or objection mechanism. Withdrawal does not affect prior lawful processing or necessary service communications.
8. Contacts
Marketing preferences: account area or unsubscribe link. Privacy rights: privacy@uese.eu; DPO: dpo@uese.it.
9. National supplement — European Union / common rules
Electronic marketing
The GDPR and ePrivacy rules operate together. National law determines the detailed consent rules and exceptions for email/SMS marketing.
10. Versioning, precedence and evidence retention
Firmato records the version made available and, where the application flow provides for acceptance, the corresponding acceptance evidence including date, account and technical audit information. Material changes may require renewed acknowledgement or acceptance. Language and country are separate variables: language determines the linguistic version, while country determines the applicable national supplement.