We support the Client in analysing and allocating the roles and responsibilities provided for by the Data Act (data holder, user, data recipient) in its relationships with commercial partners. In practice, we verify with the partners what the correct allocation is, establishing who — between the Client and the partner — acts as data holder for the data generated by each connected product or related service, distinguishing the situations where the Client manufactures or develops the product directly from those where it is supplied by third parties. On this basis we define the allocation of obligations and crystallise the outcome in the agreements between the parties. To get there, we analyse the structure of the supply chain and the Client’s business model. Our aim is to prevent disputes and simplify the management of compliance obligations.