This notice describes how the personal data of users who browse and use the website www.tommasovolker.com/en are processed. This notice is provided pursuant to EU Regulation 2016/679, concerning the protection of natural persons with regard to the processing of personal data, and the applicable Italian legislation on the protection of personal data.
1. Data Controller
The Data Controller is the owner of the domain associated with the website. The Data Controller may be contacted for any request concerning the processing of personal data and the exercise of the data subject’s rights.
2. Types of data processed
While browsing and using the website, the following categories of personal data may be processed.
a. Browsing data
The computer systems and software procedures used to operate the website may acquire, during their normal operation, certain technical data whose transmission is implicit in the use of Internet communication protocols.
This category includes, by way of example:
* IP address;
* type of browser used;
* operating system;
* name of the Internet provider;
* date and time of access;
* pages visited;
* technical data relating to browsing and website operation.
These data are used to allow the correct display of the website, ensure IT security, obtain aggregated statistical information and prevent possible abuse.
b. Data voluntarily provided by the user
The optional, explicit and voluntary sending of communications by email, contact form, messaging links or other contact details available on the website entails the acquisition of the data necessary to respond to the user’s requests.
The following data may be processed, by way of example:
* name or pseudonym;
* email address;
* telephone number, if provided;
* content of the message;
* any other data voluntarily entered by the user in the communication.
The user is invited not to send unnecessary data, third-party data or particularly confidential information, unless this is essential in relation to the request submitted.
c. Cookies and tracking tools
The website may use technical cookies necessary for the proper functioning of the pages and services offered.
Usage statistics for the website are collected through Umami, an analytics tool that does not use cookies or any other identifiers stored on the user’s device (see point d).
Any additional analytics cookies, profiling cookies, advertising tools, pixels, third-party plugins or other tracking tools will be used only within the limits provided for by current legislation and, where necessary, subject to the user’s prior consent.
For further information, the user may consult the website’s Cookie Policy.
d. Statistical data on website usage (Umami)
To understand how the website is used and to improve its content, structure and functioning, the Data Controller uses Umami, an open-source web analytics tool designed according to the privacy-by-design principle, in its cloud version (Umami Cloud) provided by Umami Software, Inc.
Umami does not use cookies or any other persistent identifiers stored on the user’s device, does not collect personally identifiable data and does not allow the user’s browsing to be tracked across other websites.
The information collected, in anonymous and aggregated form, concerns:
* pages visited and duration of the visit;
* the referring website or page (referrer) and any campaign parameters (UTM) contained in the page address;
* browser type and operating system;
* device type and screen resolution;
* browser language;
* country of origin, derived from the IP address;
* any interactions with elements of the website (for example clicks on links or buttons), where configured.
The user’s IP address is processed exclusively in memory, for the sole purpose of determining the geographical area of origin and generating an anonymous session identifier by means of a cryptographic hash function with a periodically regenerated key (salt), and is never stored. The data collected in this way are not associated with any other information relating to the user and do not allow the user to be identified.
3. Purposes of processing
Personal data may be processed for the following purposes:
a. to allow browsing and proper use of the website;
b. to ensure the security, maintenance and proper technical functioning of the website;
c. to produce anonymous and aggregated statistics on website usage, through Umami, in order to improve its content, structure and functioning;
d. to respond to requests sent by the user via email, contact form or other channels indicated on the website;
e. to manage any subsequent communications with the user;
f. to prevent spam, abuse, unauthorized access or unlawful activities;
g. to comply with obligations provided for by law, regulations or requests from competent authorities;
h. to protect the rights of the Data Controller in the event of any disputes.
The website does not use users’ personal data for direct marketing purposes, newsletter delivery, commercial profiling or disclosure to third parties, unless otherwise specified in a separate notice and, where necessary, subject to the user’s prior consent. Usage statistics collected through Umami are not used for profiling or advertising purposes.
4. Legal basis for processing
The processing of personal data is based on the following legal grounds:
* Article 6(1)(b) GDPR, when processing is necessary to respond to a user’s request or to take pre-contractual measures requested by the user;
* Article 6(1)(f) GDPR, for the legitimate interest of the Data Controller in ensuring the functioning, security and protection of the website, as well as in understanding how the website is used, in statistical, anonymous and aggregated form, through Umami; as this processing does not involve the use of cookies or the storage of identifying data, it has a minimal impact on users’ rights and freedoms;
* Article 6(1)(c) GDPR, when processing is necessary to comply with legal obligations;
* Article 6(1)(a) GDPR, where the user’s consent is required, for example for any non-technical cookies, tracking tools, marketing or optional processing activities.
5. Special categories of data
The website is not intended to collect special categories of personal data, such as data relating to health, religious, political or trade union beliefs.
The user is invited not to include such information in communications sent through the website, unless this is strictly necessary in relation to the request made.
If the user voluntarily provides data falling within special categories, such data will be processed exclusively within the limits necessary to manage the request and, where required by law, on the basis of the explicit consent of the data subject.
6. Processing methods
Personal data are processed using electronic and digital tools.
The Data Controller adopts appropriate technical and organizational measures to protect personal data against loss, unlawful or improper use, unauthorized access, disclosure, alteration or destruction.
Processing is carried out in accordance with the principles of lawfulness, fairness, transparency, minimization, storage limitation, integrity and confidentiality.
7. Provision of data
The provision of browsing data is necessary for the technical consultation of the website.
The provision of data via email, contact form or other communication channels is optional, but necessary to allow the Data Controller to receive and manage the user’s request.
Failure to provide the necessary data may prevent the Data Controller from responding to the request received.
8. Retention period
Personal data will be stored for the time strictly necessary to achieve the purposes for which they were collected.
In particular:
* technical browsing and security data are retained for the time necessary for the functioning and protection of the website;
* statistical data collected through Umami are retained exclusively in anonymous and aggregated form, for the time necessary to analyse website trends, and at no time allow users to be identified;
* data sent through voluntary communications will be retained for the time necessary to manage the request and, as a rule, for no longer than 12 months from the last communication;
* data necessary to comply with legal obligations or to protect the rights of the Data Controller may be retained for the period provided for by the applicable legislation or for the time necessary to manage any disputes.
9. Recipients of the data
Personal data may be processed by:
* the Data Controller;
* persons authorized by the Data Controller;
* technical service providers;
* hosting providers;
* website managers;
* email service providers;
* providers of security, anti-spam, technical maintenance or statistical analysis services;
* Umami Software, Inc., provider of the Umami Cloud statistical analysis service, which processes on behalf of the Data Controller only the anonymous and aggregated data described in point 2(d);
* consultants or professionals, where necessary;
* public authorities or subjects legally entitled to receive the data.
Personal data will not be sold, disseminated or disclosed to third parties for unauthorized commercial purposes.
10. Transfer of data outside the European Economic Area
The website is hosted on servers located in the Netherlands, within the European Union: browsing data acquired by the website’s systems (point 2(a)) are therefore processed and stored within the European Economic Area. For all other processing activities, personal data are preferably processed within the European Economic Area.
The Umami Cloud statistical analysis service is provided by Umami Software, Inc., a company based in the United States of America. The data collected through this service are anonymous and aggregated and do not allow users to be identified; the IP address, the only potentially identifying element, is processed transiently for the sole purpose of determining the country of origin and is not stored.
If certain technical services used by the website, including the one referred to above, involve the transfer of data to countries outside the European Economic Area, such transfer will take place in compliance with the safeguards provided for by the GDPR, including adequacy decisions, standard contractual clauses or other legal instruments permitted by current legislation.
11. Cookies
The website may use technical cookies necessary for browsing and for the proper functioning of the pages.
The use of non-technical cookies or similar tools, such as non-anonymized analytics cookies, profiling cookies, advertising tools, pixels or third-party services, will take place only in the cases and according to the methods permitted by current legislation.
The user may manage or disable cookies through their browser settings.
The Umami statistical analysis tool used by the website does not install cookies or any other identifiers on the user’s device and does not perform any form of cross-site tracking: statistics are collected in anonymous and aggregated form, in line with the Guidelines on cookies and other tracking tools issued by the Italian Data Protection Authority (Garante per la protezione dei dati personali) on 10 June 2021. For this reason, its use does not require the user’s prior consent.
12. Third-party services
The website may integrate links, buttons, plugins or services provided by third parties, such as messaging services, social networks, maps, anti-spam tools, statistical analysis systems, payment platforms or other external services.
Interaction with such services may involve the processing of personal data by the respective providers, according to their own privacy policies.
The Umami Cloud statistical analysis service is used by the Data Controller under the terms described in point 2(d) and point 10; the provider’s privacy policy is available on the website umami.is.
The Data Controller invites the user to consult the privacy policies of any third-party services used.
13. Links to external websites
The website may contain links to external websites.
The Data Controller is not responsible for the content, security or privacy practices adopted by third-party websites, platforms or services that may be accessed through links on the website.
14. Rights of the data subject
The user may exercise at any time the rights provided for by Articles 15 et seq. of the GDPR, including:
* right of access to personal data;
* right to rectification;
* right to erasure;
* right to restriction of processing;
* right to object to processing;
* right to data portability, where applicable;
* right to withdraw consent, where processing is based on consent;
* right to lodge a complaint with the Italian Data Protection Authority.
To exercise their rights, the user may contact the Data Controller at the following address: tommasovolker@proton.me
Please note that the statistical data collected through Umami are anonymous and do not allow the Data Controller to identify information relating to any individual user; requests concerning such data may therefore be fulfilled only to the extent technically possible.
15. Changes to this notice
The Data Controller reserves the right to amend or update this notice at any time, including as a result of regulatory, technical or organizational changes.
Last updated: September 2026.