We use artificial intelligence tools to support our work. This page explains which ones, for what, with what checks and with what safeguards for personal data. It applies to all consulting engagements and all courses.
[Art 13 – Law 132/2025; Art 4 – Law 132/2025]
1. The principle
Artificial intelligence is a support tool. The intellectual work remains predominant and remains ours. Every result produced with AI is reviewed by a person before it reaches you.
[Art 13 and Art 3 par. 3 – Law 132/2025]
2. Who is responsible
Thrive-O S.r.l.
Via Goffredo Mameli 23/25, 21049 Tradate (VA)
For questions: [email protected]
Privacy requests: privacy request form
The contact person is the legal representative, currently Fabio Cocchi, Founder.
3. What we do with AI
| Activity | What the tool does | Human control |
|---|---|---|
| Transcription and summary of calls and sessions | Transcribes and summarises recordings or notes of meetings. | We review the transcript and the summary before using them. |
| Evaluation of course participants | Processes our draft of the evaluation forms. | We always start from our own evaluation. The form is fully verified by Fabio Cocchi, with cross-checking when it concerns specific references. On sensitive topics a second person at Thrive-O also reviews it. |
| Analysis of the Client’s documents and data | Reads and summarises documents, procedures and data exports to find where time or margin is lost. | We draw the conclusions ourselves, on verified data. |
| Drafting of documents and reports | Proposes drafts of documents, presentations and course materials. | Every text is rewritten and approved by us before release. |
We use AI only for these activities.
[Art 13 and Art 3 par. 3 – Law 132/2025]
4. Which tools we use
The artificial intelligence model is Claude, by Anthropic. To store and organise materials we use Google Workspace, Notion and Miro. If we add or change a tool that processes personal data, we update this page and inform the clients with ongoing engagements.
5. The safeguards
- No solely automated decisions. No decision that concerns you is taken solely by an AI system.
- Full human review. Every output is verified by a person before release.
- No training. Client and participant data is not used to train models.
- Recordings only with notice. We record calls and sessions only after informing those present.
- Transfers outside the EU with safeguards. If a supplier processes data outside the European Economic Area, it does so with an adequacy decision or with adequate safeguards, such as standard contractual clauses.
- Contracts with suppliers. Suppliers process data as our data processors, under a written agreement.
[Art 22 – Regulation (EU) 2016/679; Art 28 – Regulation (EU) 2016/679; Art 44, Art 45 and Art 46 – Regulation (EU) 2016/679; Art 3 and Art 4 – Law 132/2025]
6. Personal data and retention
When AI processes personal data, the legal bases and the periods given in the privacy notice apply. Recordings, transcripts and evaluation forms, including the AI outputs that contain them, are kept for up to 2 years from the end of the supply.
[Art 5 par. 1 letter e) and Art 13 – Regulation (EU) 2016/679; Art 4 – Law 132/2025]
7. Your rights
You can object to the processing of your data with AI, ask for a person to intervene, express your view and challenge an evaluation. You can also exercise all the other rights provided by the privacy notice: access, rectification, erasure, restriction, portability, withdrawal of consent. Use the privacy request form. The request goes directly to the person in charge, Fabio Cocchi.
If you believe the processing breaches the rules, you can lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).
[Art 21, Art 22 par. 3 and Art 77 – Regulation (EU) 2016/679; Art 4 – Law 132/2025]
8. If you work for a client
If you take part in the activities as an employee or collaborator of the Client, the Client, as employer, has the obligation to inform you about the use of AI in the employment relationship. This page describes the use we make of it.
[Art 11 – Law 132/2025]
9. Updates
We update this page when the uses or the tools change. The version in force is shown at the top.
Privacy request
Fill in the form and choose the subject. The request goes directly to the person in charge, Fabio Cocchi.