Privacy Policy - Ugo Fiasconaro

This Application collects some Personal Data from its Users.

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Data Controller

Ugo Fiasconaro – Via Torregrotta, 15 – 00132 Rome (Italy)
Owner’s email address: [email protected]

Types of Data Collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Usage Data; Trackers; first name; last name; phone number; email address; answers to questions; clicks; keypress events;
motion sensor events; mouse movements; position relative to scrolling; touch events; number of Users; city;
device information; session statistics; latitude (of the city); longitude (of the city);
browser information.

Full details on each type of data collected are provided in the dedicated sections of this privacy
policy or through specific information texts displayed before the data are collected.
Personal Data may be freely provided by the User, or, in the case of Usage Data, collected
automatically when using this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User
refuses to communicate this Data, it may be impossible for this Application to provide its Service. In cases where
this Application specifically states that some Data is optional, Users are free not to communicate
this Data without any consequences on the availability or operation of the Service.
Users who are uncertain about which Data is mandatory are encouraged to contact the
Owner.
Any use of Cookies – or other tracking tools – by this Application or by the
owners of third-party services used by this Application, unless otherwise specified, is intended to
provide the Service requested by the User, in addition to any other purposes described in this document and in the
Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through
this Application and guarantees that he/she has the right to communicate or disseminate them, freeing the Owner from
any liability towards third parties.

Method and place of processing of the collected data

Treatment methods

The Data Controller takes appropriate security measures to prevent
unauthorized access, disclosure, modification or destruction of Personal Data.
Processing is carried out using computer and/or telematic tools, with organizational methods and
logic strictly related to the purposes indicated. In addition to the
Data Controller, in some cases, other parties involved in the organization of this Application (administrative,
commercial, marketing, legal, system administration personnel) or external parties (such as
third party technical service providers, postal couriers, hosting providers, IT companies, communications agencies) may have access to the Data,
also appointed, if necessary, as Data Processors by the Data Controller. The updated list of
Data Processors may always be requested from the Data Controller.

Legal basis for processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

the User has given consent for one or more specific purposes; Note: under some jurisdictions the Owner
may be allowed to process Personal Data without the User’s consent or
any other of the legal bases specified below, until the User objects (“opt-out”)
to such processing. However, this does not apply if the processing of Personal Data is regulated
by European data protection law;
processing is necessary for the performance of a contract with the User and/or for the execution of
pre-contractual measures;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of
official authority vested in the Owner;
processing is necessary for the pursuit of the legitimate interest of the Owner or of a third party.

It is always possible to ask the Owner to clarify the specific legal basis of each
treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or
necessary to conclude a contract.

Place

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the
processing are located. For further information, contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located.
To obtain further information on the place of processing, the User can refer to the section
containing details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis of the transfer of Data outside
the European Union or to an international organization governed by public international law or consisting of
two or more countries, such as the UN, as well as regarding the security measures adopted by the Owner to
protect the Data.

The User can verify whether one of the transfers described above is taking place by checking the section of this
document relating to the details on the processing of Personal Data or by asking the Owner
by contacting him at the contact details provided at the beginning.

Retention period

The Data is processed and stored for the time required by the purposes for which it was collected.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User
will be retained until the performance of such contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Owner will be retained
until such interest is fulfilled. The User can obtain further information regarding
the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting
the Owner.

When the processing is based on the User’s consent, the Owner may retain the Personal Data for a longer period
until such consent is revoked. Furthermore, the Owner may be obliged to
retain Personal Data for a longer period in compliance with a legal obligation or by order of
an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of such period

Once this period has expired, the right to access, erasure, rectification and the right to portability of the Data can no
longer be exercised.

Purpose of the Processing of Collected Data

The User’s Data is collected to allow the Owner to provide its Service, comply with
legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or
third parties), identify any malicious or fraudulent activity, as well as for the following purposes:
Displaying content from external platforms, Tag Management and Contacting the User,
SPAM protection and Statistics.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each
purpose, the User may refer to the section “Details on the processing of Personal Data”.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contact the User

Contact form (this Application)

By filling in the contact form with their Data, the User consents to their use to respond
to requests for information, quotes, or any other nature indicated by the
form header.

Personal Data processed: email address; first name; last name; phone number.

Tag Management

This type of service is functional to the centralized management of the tags or scripts used on this
Application.
The use of such services involves the flow of User Data through them and, if necessary, their
retention.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.

Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly
from the pages of this Application and interact with them.
This type of service may still collect data on web traffic relating to the pages where the
service is installed, even when users do not use it.

Google Fonts (Google Ireland Limited)

Google Fonts is a font display service managed by Google Ireland Limited that
allows this Application to integrate such content within its pages.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: Ireland – Privacy Policy.

Google Maps Widget (Google Ireland Limited)

Google Maps is a map viewing service managed by Google Ireland Limited that
allows this Application to integrate such content within its pages.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

SPAM Protection

This type of service analyzes the traffic of this Application, potentially containing
Personal Data of Users, in order to filter it from parts of traffic, messages and contents recognized as
SPAM.

Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
Use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.

Personal Data processed: clicks; Usage Data; keypress events; motion sensor events;
touch events; mouse movements; position relative to scrolling; answers to questions;
Trackers.

Place of processing: Ireland – Privacy Policy.

Statistics

The services contained in this section allow the Data Controller to monitor and
analyze traffic data and are used to track User behavior.

Google Analytics 4 (Google Ireland Limited)

Google Analytics is a statistics service provided by Google Ireland Limited (“Google”). Google
uses the Personal Data collected for the purpose of tracking and examining the use of this Application,
compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the ads of
its own advertising network.
In Google Analytics 4, IP addresses are used at the time of collection and then deleted
before the data is recorded in any data center or server. To learn more, you can
consult the official documentation of Google.

Personal Data processed: city; browser information; device information;
latitude (of the city); longitude (of the city); number of Users; session statistics; Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

User Rights

Users may exercise certain rights with reference to the Data processed by the Owner.

In particular, within the limits established by law, the User has the right to:

withdraw consent at any time. The User may withdraw consent to the processing of their
Personal Data previously expressed.
object to the processing of their Data. The User may object to the processing of their Data when
it occurs on a legal basis other than consent. Further details on the right to object
are provided in the section below.
access their Data. The User has the right to obtain information on the Data processed by the Owner, on
certain aspects of the processing and to receive a copy of the Data processed.
verify and request rectification. The User can verify the accuracy of their Data and
request its updating or correction.
obtain the limitation of processing. The User may request the limitation of the processing of
their Data. In this case, the Owner will not process the Data for any purpose other than its conservation.
obtain the deletion or removal of their Personal Data. The User may request the
deletion of their Data by the Owner.
receive their Data or have it transferred to another owner. The User has the right to receive his/her Data
in a structured, commonly used and machine-readable format and, where technically
feasible, to obtain the transfer without hindrance to another owner.
lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority
or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public authority vested in
the Owner or to pursue a legitimate interest of the Owner, Users have the right to
object to the processing for reasons related to their particular situation.

Users are hereby informed that, if their Data is processed for direct marketing purposes, they may
object to the processing at any time, free of charge and without providing any justification. If
Users object to the processing for direct marketing purposes, the Personal Data will no longer be
processed for such purposes. To find out whether the Owner processes Data for direct marketing purposes, Users
may refer to the respective sections of this document.

How to exercise your rights

To exercise their rights, Users may address a request to the Data Controller’s contact details indicated in
this document. The request can be filed free of charge and the Data Controller will respond as soon as
possible, in any case within one month, providing the User with all the information required by law.
Any corrections, cancellations or limitations of the processing will be communicated by the Data Controller to each
of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or
involves a disproportionate effort. The Data Controller informs the User of such recipients if he/she requests it.

Further information on treatment

Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages
of its possible establishment for the defense against abuse in the use of this Application or related Services
by the User.
The User declares to be aware that the Owner may be required to reveal the Data by order
of public authorities.

Specific information

Upon request of the User, in addition to the information contained in this privacy policy, this
Application may provide the User with additional and contextual information regarding
specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For needs related to operation and maintenance, this Application and any third-party services
used by it may collect system logs, which are files that record interactions and may
also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any
time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Application does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is invited to consult their
respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at
any time by giving notice to Users on this page and, if possible, on this Application
and, if technically and legally feasible, by sending a notification to Users through one of the
contact details in its possession. Please therefore consult this page frequently, referring
to the date of the last modification indicated at the bottom.

If the changes affect treatments whose legal basis is consent, the Data Controller will
collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in
connection with any other information, including a personal identification number, makes
a natural person identified or identifiable.

Usage Data

This information is collected automatically through this Application (also from
third-party applications integrated into this Application), including: the IP addresses or domain names of the computers
utilized by the User who connects to this Application, the URI (Uniform
Resource Identifier) addresses, the time of the request, the method utilized to submit the request to the server, the
size of the file obtained in response, the numerical code indicating the status of the server’s response (successful
, error, etc.), the country of origin, the characteristics of the browser and operating system utilized by the
visitor, the various temporal connotations of the visit (for example, the time spent on each
page) and the details relating to the itinerary followed within the Application, with particular reference to the
sequence of pages visited, the parameters relating to the operating system and the
User’s IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with
the Data Subject.

Interested

The natural person to whom the Personal Data refers.

Data Controller (or Controller)

The natural person, legal person, public administration or any other entity that processes personal data on
behalf of the Owner, as set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together
with others, determines the purposes and means of the processing of personal data and the tools used, including
the security measures relating to the operation and use of this Application. The
Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool by which the Personal Data of Users is collected and processed.

Service

The Service provided by this Application as defined in the relevant terms (if any) on this
site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document shall
be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookies are Tracking Tools that consist of small portions of data stored within the
User’s browser.

Tracking Tool

By Tracking Tool we mean any technology – e.g. Cookies, unique identifiers, web
beacons, embedded scripts, e-tags and fingerprinting – that allows tracking Users, for example
by collecting or storing information on the User’s device.

Legal references

This privacy policy is drafted on the basis of multiple legislative systems, including Articles 13 and
14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy concerns only this Application.
Last modified: May 26, 2025