University of Sannio

Privacy Policy

Last updated: October 17, 2026

This personal data processing notice describes how personal data is managed for users who access the "Arechi" virtual assistant service of the University of Sannio. The information provided here applies only to the "Arechi" chatbot available through this portal.

The purpose of this document is to provide clear and transparent information about the data collected through the virtual assistant service and how that data is used. Use of this service involves the processing of information that may qualify as personal data.

1. KEY DEFINITIONS

To support full understanding of this notice, the University of Sannio provides the following definitions:

  • Processing: any operation performed on personal data;
  • Personal data: any information relating to an identified or identifiable natural person;
  • Data Controller: the entity that determines the purposes and means of personal data processing;
  • User/data subject: the natural person to whom the personal data processed through the "Arechi" virtual assistant service provided by the University relates.

2. DATA CONTROLLER

The Data Controller is the University of Sannio, with registered office at Piazza Guerrazzi, 1, 82100 Benevento, Italy, Tel. +39 0824305081, tax code 01114010620, email: segreteria.rettore@unisannio.it, certified email: amministrazione@cert.unisannio.it (hereinafter, the Data Controller or Controller).

3. DATA PROTECTION OFFICER

The Data Protection Officer (DPO) can be contacted at: dpo@unisannio.it

4. TYPES OF DATA PROCESSED

The "Arechi" virtual assistant service is designed to minimize the collection of personal data. No profiling cookies or technical cookies are used for the chat; the browser stores locally only the language chosen for the interface. For statistical purposes, the site uses Web Analytics Italia, operated by Agenzia per l'Italia Digitale (AgID), in anonymous and cookieless mode (see section 10).

The only data processed when using the service is:

  • the content of messages entered by the user in conversations with the chatbot;
  • an anonymous session identifier, automatically generated in UUID format when the user accesses the service and not attributable to the user's identity;
  • the IP address of the device, used only for security purposes and to limit the number of requests sent to the service (abuse prevention): the related counter is automatically deleted within 60 seconds.

Messages and the session identifier are stored temporarily only to preserve the conversation history during the active session and are automatically deleted after 15 minutes of inactivity. Conversations are not used in any way to train or improve the artificial intelligence models used by the service.

Any personal data or personal information, such as name, surname, student ID number, special categories of personal data, and similar information, may be voluntarily provided by the user within conversations with the chatbot. Users are invited not to enter sensitive personal data, such as data relating to health, sexual orientation, religious beliefs, and similar information, in conversations with the virtual assistant.

5. PURPOSES AND LEGAL BASIS OF PROCESSING

The "Arechi" virtual assistant service is intended to make it easier to access information about services provided by the University. The processing of personal data is aimed at managing requests submitted by data subjects through the chatbot in order to:

  • obtain information about University services, educational offerings, and activities;
  • receive assistance with administrative and academic procedures;
  • receive general informational guidance and support.

Use of the chatbot is optional. Not using the service has no consequences for the user, who can still access University information through traditional channels.

6. PROCESSING METHODS AND RECIPIENTS OF PERSONAL DATA

Data is processed electronically and automatically by the IT systems that provide the service. No manual review of conversations by University staff is planned.

To generate responses, the content of the messages in the current conversation is sent to OpenRouter, Inc., which acts as a technical intermediary, and to the language model providers it routes requests to (for example Anthropic, Google, and OpenAI). The session identifier is not sent to these parties, which act as processors pursuant to Article 28 of the GDPR.

The service uses OpenRouter's European regional routing: requests are processed exclusively on infrastructure located in the European Union. The model providers used apply a zero data retention policy: request content is not retained after the response is generated and is not used to train artificial intelligence models.

To retrieve the requested information, the assistant may query public information services of the University and its suppliers (for example the lesson timetable, exam sessions, contact directories, and the library catalog), sending only the necessary search terms (for example the name of a course unit or the title of a book) and no user identifier.

Apart from the cases described above, data is not disclosed to third parties, except where required by law.

7. SECURITY OF PROCESSING

To ensure an adequate level of data protection and reduce the risk of improper or unlawful use, technical and organizational measures have been implemented in line with recognized international IT standards. These measures are regularly reviewed.

8. DATA RETENTION

Conversation data, meaning messages and the session identifier, is stored temporarily for a maximum of 15 minutes from the last interaction, only to ensure conversation continuity. After this period, the data is automatically and permanently deleted. No permanent archiving of conversations is planned.

9. DATA SUBJECT RIGHTS

Under Articles 15-22 of the GDPR, the data subject has the right to:

  • Right of access: request information about the personal data provided;
  • Right to rectification: request correction of personal data;
  • Right to erasure: request deletion of data;
  • Right to restriction of processing: request that processing be restricted;
  • Right to object: object to data processing.

Given the anonymous and temporary nature of the processing, including the session identifier not being attributable to the user and automatic deletion of data within 15 minutes, exercising the rights of access, rectification, and erasure may be objectively impossible because the Controller cannot identify the data subject pursuant to Article 11 of the GDPR.

The user also has the right to lodge a complaint with the Italian Data Protection Authority or, alternatively, to bring proceedings before the competent court.

10. STATISTICAL ANALYTICS TOOLS

This site uses Web Analytics Italia (WAI), the statistical analytics service made available by Agenzia per l'Italia Digitale (AgID) for Italian public administrations.

The service is configured in anonymous and cookieless mode: user IP addresses are truncated, making re-identification impossible, before being stored on servers managed by AgID and located in Italy. No cookies are installed on the user's device.

The data collected, such as pages visited, visit duration, device type, browser language, and country inferred from the anonymized IP address, is used exclusively for statistical purposes to understand how users interact with the service and improve it. The content of chatbot conversations is not transmitted to Web Analytics Italia in any way.

Legal basis for processing: the Controller's legitimate interest under Article 6(1)(f) of the GDPR and Article 2-ter of the Italian Privacy Code, since anonymous statistical analysis supports the provision of a public service.

More information is available on the official Web Analytics Italia website.

11. DIFFERENT PURPOSE OF PROCESSING

If the Data Controller intends to further process personal data for a purpose different from the original purposes, it will provide the data subject with a new notice before such further processing.

12. CHANGES

The Data Controller undertakes to inform users of any changes to this document and reserves the right to modify or simply update this notice, in whole or in part. Users are advised to check the documentation regularly before providing personal data.