GDPR compliance and Privacy NoticeĀ 

Policy on the processing of personal data in Emotiva

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This page summarizes the personal data processing activities carried out by Emotiva both in the provision of the services commissioned by its customers (as Data Processor) and directly to its data subjects (as Data Controller) carried out through or from this site.

Affective computing and data protection

Emotiva carries out, as the main activity, the development and implementation of software allowing affective computation and the consequent recognition of emotions expressed by human faces (Facial Emotion recognition – FER).

For this purpose, Emotiva processes personal data:

  • on behalf of customers who use the software (SaaS or APIs) and/or commission research or studies, thus acting as a Data Processor (for information concerning the Data Controller, you can always write us as indicated below);
  • for itself, as Data Controller, when carrying out internally promoted analyzes or researches.

How does it work?

In facts, emotion recognition consists in the detection, in photographs of a person subjected to a stimulus , of the movements of facial muscles, and in their association with the Action Units codified by Ekman’s studies to be represented in universal expressions and related inferences (e.g. level of attention).

Are there biometric data?

When we talk about affective computing and FER, however, the first concern that arises is related to the possible collection and use of biometric data that can allow the unique identification of people (the so-called ā€œfacial recognitionā€).
The Artificial Intelligence developed and used by Emotiva does not use or allow the subsequent processing/extraction of biometric data: if by biometrics we mean the technology through which some unique individual traits of the “body” are detected (in this case the face of a person) and are registered through an information system (which can also allow comparison with other data sets to identify the subject), Emotiva does not use this technology because at no point in the process of analyzing the movement of facial muscles is detected, extracted or inferred any unique category of information to identify a person.

How is the AI trained?

The second very common concern is related to the reuse of images for training Artificial Intelligence. Here too we can reassure you: at the moment no re-training activity of the neural network, which has learned to recognize emotions starting from regular databases provided by prestigious universities, is implemented or planned.

Personal data and responsibilities

During the analysis, EMOTIVA collects frames (directly or via interfaces with our Customers applications) of the participants’ faces (at predetermined time intervals) and answers to the questions proposed. We do not ask the participant to provide us with his identification data, therefore, none of this information is associated with his/her identity, neither when we act as a Data Controller nor when we act as Data Processor, but to the ID assigned by the company providing the data subjects or to the random one that we attributed. Participants’ data are pseudonymized: we can trace the identity of each subject only if the subject (either the customer or the panel provider) that assigned the IDs gives us the decryption key.

In the case of studies promoted by EMOTIVA, we ask participants for their consent to use their personal data; the same can clearly be revoked at any time.

The data collected are processed by authorized personnel only, bound to confidentiality, and are stored in systems made available by the suppliers of cloud hosting and survey services, specifically appointed as Data Processors. All personal information (e.g. images and answers) are kept until the end of each study, then anonymized and used for statistical purposes.

For studies promoted by our customers, the information concerning the lawful basis of processing, the retention period and the recipients are established by the customer (Data Controller) and are communicated through the related information notices, as described in the following shared responsibility model.

For more information on responsibilities in the FER service, on the life cycle of personal data in the FER process, or on the security measures adopted, do not hesitate to contact us at or by writing to our DPO.

For information about the Data Controller who commissioned the survey, you can send an email to and indicate the day, time and content displayed in order to allow us to trace your ID.

Data processing on

B2B marketing

In the legitimate interest of carrying out direct marketing activities, Emotiva uses e-mail addresses of customers and potential customers contacts collected through the website or other public online channels (e.g. LinkedIn) to send communications related to the company and the services it provides, that are in line with the objectives and needs of the potential customers.
If there is no reply from the contact person or if the latter requests to no longer receive communications from the appropriate link on the e-mail footer, the data is immediately deleted.



Emotiva periodically sends a newsletter to its customers and potential customers, even if they have not directly subscribed to it, in its legitimate interest to keep them updated on the company’s activities and to transmit their news and insights relating to the world of affective computing.
However, it is always possible to subscribe to the newsletter by filling out the appropriate form at the foot of each page of this site.
To send the newsletter, we only collect the e-mail address of the data subject acting for the company.
The e-mail addresses are transmitted to the provider of the massive mailing system, appropriately appointed as data processor
Data are kept for the entire duration of the service and subjects who receive the newsletter can unsubscribe at any time by clicking on the appropriate link on the footer of each e-mail.


Work with us

If you are interested in joining the Emotiva team, you can submit your spontaneous application or respond to our job search by filling out the form on this site and uploading your curriculum vitae. The data contained in the CV and collected in the selection process will be used by dedicated staff for the sole purpose of evaluating the application and concluding a possible collaboration contract. The provision of the CV is mandatory for participation in the selection process and the data thus collected are kept for a maximum period of 6 months and are not accessible to third parties.
If you have applied for an open position or spontaneously, you can always request the updating or deletion of data during the retention period, by writing to


Management of the employment relationship

Emotiva processes personal data of its employees, collaborators, and consultants to manage the employment relationship in its entirety, starting from the selection process up to including the integration of the worker in the company, training, administrative management, and all the formalities mandatory, including health surveillance.
The data collected are necessary for the execution of the contract and are kept for 10 years starting from the end of the employment relationship.


Request for further information

If you want to receive more information about Emotiva’s activities or have clarifications on the FER process or other services, you can write us a message by filling out one of the dedicated forms on this website. The request involves the subsequent acquisition of the e-mail address, necessary to reply to you, as well as any other personal data included in the message (the processing of this data is carried out in the execution of the contract between the parties).
The data transmitted in this way will be kept by Emotiva for the entire duration of the relationship that we will eventually establish and in general for the legal retention time of the administrative documentation.


Book a demo

If you want to receive a demo of EmPower you can book it through our website. We collect your identification and contact data, as well as the name of your company, for the sole purpose of contacting you to customize the demo and subsequently provide you with the service. The provision of data is necessary for booking.
The data transmitted in this way will be kept by Emotiva for the entire duration of any relationship established.


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Rights of data subjects

Individuals participating in the research activities and studies promoted by EMOTIVA can exercise their rights by writing to They have the right to request access to their personal data (during the period of data retention), the rectification of answers, restriction of processing or deletion of all information, and may also withdraw their consent to the processing of data.

Surfers of this site and direct data subjects of Emotiva can exercise the rights of access to their personal data, rectification, or cancellation at any time, they can also withdraw consent and oppose the processing by disabling cookies and requesting their limitation by sending an e-mail to
Other data subjects can contact us to be put in contact with the relevant data controllers (customers of studies and research) and to have information about them or the processing.

All data subjects also have the right to contact the Italian Supervising Authority, according to the procedure indicated on the site, to propose a complaint to any violations of their rights or current data protection legislation.


General information

Our Data Protection Officer can always be reached at
The Data Controller is Emotiva Srl – Viale Papiniano 44, 20144 Milan, IT – VAT number IT10058000968.