Privacy Policy
Last updated: October 2026
Data Controller
eNextGen S.R.L.
Via Principe Eugenio 9, 20155 Milan, Italy
VAT 12692290963
Email: info@enextgen.it
Types of Data Collected
Depending on how you use the site and our services, we may collect:
- Browsing data: IP address, browser and device type, pages visited.
- Contact-form and “pre-assessment” form data (sector, country, revenue/employee ranges, energy/fuel data, optional email).
- “complai” guided-path data (type of organisation, sector, size, role under the AI Act, declared AI systems with supplier and purpose of use, governance checklist answers, email): collected only if you choose to receive the action plan and give your consent.
- “decize” tool data: see the “decize” section.
- Account registration data:
- Individuals: first name, last name, email, date of birth, gender, profession, country of residence.
- Companies: email, company name, VAT / tax ID, registered office, sector of activity.
- Authentication data: credentials managed by our authentication provider, or — if you sign in with Google — the identifier and email provided by Google.
- Service usage data: a log of calls to our APIs/tools (volumes, timestamps) for security and usage-limit purposes.
- Data you upload into the tools (e.g. data for CBAM calculations): see “Data uploaded into the tools”.
Purpose of Processing
- Respond to contact requests and deliver the “pre-assessment” preliminary estimate.
- Create and manage your account and give you access to tools and datasets.
- Deliver and maintain the services (nxbase, cbamanager and future tools).
- Ensure security, abuse prevention and usage limits.
- Comply with legal obligations.
Legal Basis
- Consent (e.g. registration, optional marketing communications).
- Performance of a contract or pre-contractual measures (use of the tools under the Terms of Service).
- Legal obligations.
- Legitimate interest for security, abuse prevention and service improvement.
For the “pre-assessment” form, processing is solely to deliver the requested preliminary estimate; the email is optional and used only if provided.
For the “complai” guided path, your answers stay in your browser until you ask to receive the action plan: only then, and only with your consent, are they sent to our systems and used to send you the plan and — if you ask us to — to get back in touch.
decize
decize works out in your browser whether solar, a battery, a heat pump or an electric car pay off for you. What you enter in the questions (consumption, spend, habits) and the load-curve files you upload stay in your browser: we do not receive them.
- Full report. If you ask for the full report we collect your email, your acknowledgement of this notice, your optional consent to receive news about decize, the contribution you choose (zero included) and a minimal summary of the outcome: province, verdict, size of the assessed system, estimated economic value, needs considered and whether you used a measured curve. We record no consumption and no curves. We send the summary of the calculation (outcome, spending, investment cost, configuration) to the address you give: those figures are used only to write that email and are not stored. Legal basis: your request (pre-contractual measures) and, for news, your consent, which you can withdraw at any time. We keep this data for up to 24 months, or until you ask us to delete it.
- Contribution. Payment of the contribution is not active yet: if you choose an amount we only record the intention, collect no payment data and charge nothing.
- Grid operator login. If you choose to fetch your curve by logging in to your grid operator’s portal (e.g. e-distribuzione), your username, password and OTP code pass through our servers only to log in on your behalf and download the last twelve months of readings. They are neither stored nor logged, and the same applies to the access tokens and to the curve, which goes back to your browser; at the end the portal session is closed. To limit abuse we count attempts per hour using a non-reversible fingerprint of your IP address.
Registration and account
Registration is reserved for adults (18+): accounts may not be created by minors. You can register with email and password or via Google; in the latter case you will be asked to complete your profile with the data listed above. Fields marked as optional (e.g. marketing consent) do not affect access to the services.
Data uploaded into the tools
Some tools (e.g. cbamanager) let you upload data for processing and reports. For such data:
- The user (or the company) remains the controller of the uploaded data; eNextGen processes it as a data processor, following the user’s instructions and the Terms of Service.
- For business users processing personal data of third parties, a Data Processing Agreement (DPA) under Art. 28 GDPR is available on request.
- We do not request and do not wish to receive special categories of data (Art. 9 GDPR, e.g. health data): please do not upload them into the tools.
Where data is hosted
Data is hosted on infrastructure within the European Union (Frankfurt, Germany). We do not transfer data outside the European Economic Area, except through providers offering adequate safeguards (e.g. standard contractual clauses).
Providers and external processors
We rely on providers that process data on our behalf, as processors:
- Supabase — authentication, database and hosting (EU region, Frankfurt).
- Netlify — website hosting and delivery.
- Render — application hosting (nxbase, cbamanager).
- Google — only if you choose to sign in with Google.
- Resend — email delivery: personal-area access and the decize summary (EU region, Ireland).
This list may be updated; the current version is available on request.
Security
We apply appropriate technical and organizational measures, including: encryption of data in transit (TLS) and at rest, database-level access isolation (row-level security) so that each user/company can access only its own data, and control and minimization of internal access.
Data Retention
Data is retained for the time necessary to fulfil the stated purposes and, for account data, for as long as the account remains active. On account closure, the associated data is deleted or anonymized, subject to legal obligations.
User Rights
You may at any time request: access, rectification, erasure, restriction, objection to processing, data portability, and withdrawal of consent (without affecting processing already carried out). You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante).
To exercise your rights: info@enextgen.it
Changes
This policy may be updated; material changes will be communicated via the website or by email.