This Privacy Policy explains how personal data may be processed when you visit frenkowski.it (the "Website").
1. Data Controller
The Data Controller is Francesco Stranieri, a natural person based in Italy.
For privacy-related questions or requests, you can contact frenkowski@gmail.com.
2. Nature of the Website
The Website is a personal portfolio. It does not provide user accounts, online purchases, advertising, remarketing, profiling, newsletters or a contact form.
3. Website Hosting and Server Logs
The Website is hosted by Aruba S.p.A.. In order to provide, operate and secure the hosting service, Aruba may process standard technical information generated when a visitor accesses the Website, such as IP addresses, request information, timestamps and server or network logs.
The purpose of this processing is to make the Website available, maintain its technical operation and security, and prevent or investigate abuse and technical incidents.
The legal basis is the Controller's legitimate interest in operating and securing the Website pursuant to Article 6(1)(f) GDPR. Where required, processing may also be carried out to comply with applicable legal obligations.
Technical data processed by the hosting provider are handled and retained according to Aruba's applicable terms, policies and legal obligations.
More information is available in Aruba's privacy information.
4. Privacy-Friendly Web Analytics
The Website uses GoatCounter, a privacy-oriented web analytics service, to obtain aggregate statistics about Website usage.
The purpose is to understand how the Website is used at an aggregate level, for example which pages are visited, which selected links are used, how visitors reach the Website, and to improve its content and operation.
Depending on the information available and the Website's GoatCounter configuration, aggregate statistics may include pages visited, interactions with selected links, referring website, browser and operating system, screen size, and approximate geographic information such as country and region.
GoatCounter does not store visitors' IP addresses, full User-Agent headers or persistent tracking identifiers. It also does not store analytics information in the visitor's browser through cookies, localStorage or similar persistent mechanisms.
To distinguish visits within a session, GoatCounter may temporarily process technical information including the IP address and User-Agent. This information is used in memory for session identification and is not stored in the analytics database or on disk. GoatCounter states that the temporary session information is kept in memory for up to eight hours.
Individual pageview storage is disabled for this Website. The retained analytics therefore consist of aggregate statistics rather than a log of individual visitors' pageviews.
The legal basis for this processing is the Controller's legitimate interest in obtaining privacy-preserving, aggregate information about Website usage pursuant to Article 6(1)(f) GDPR.
The hosted GoatCounter service is operated by Martin Tournoij in Ireland. According to GoatCounter, hosted analytics data are stored on Hetzner Online GmbH servers located in Finland and Germany.
For this Website, aggregate analytics are configured without automatic expiration and are retained until they are manually deleted or the GoatCounter account is deleted. According to GoatCounter, deleted information may remain in backups for up to 30 days.
More information is available in GoatCounter's privacy documentation and GoatCounter's GDPR information.
5. Google Fonts
The Website uses Google Fonts to load the Source Sans 3 typeface. When the font resources are requested, the visitor's browser connects to Google's servers. As part of that connection, Google may receive technical information such as the visitor's IP address, browser information and request metadata.
The purpose is to provide consistent typography and visual presentation of the Website. The legal basis relied upon by the Controller is the legitimate interest in presenting and operating the Website consistently pursuant to Article 6(1)(f) GDPR.
Google may process data in accordance with its own privacy policy and applicable data-transfer safeguards. More information is available in Google's Privacy Policy.
6. Email Communications
The Website does not use a contact form. If you choose to contact the Controller using the email address provided on the Website, the Controller will process the information you voluntarily provide, including your email address, message content and any other information included in your communication.
The purpose is to receive, manage and respond to your communication.
The legal basis is the Controller's legitimate interest in responding to communications addressed to him pursuant to Article 6(1)(f) GDPR. Where the communication relates to steps requested by you before entering into a contract, Article 6(1)(b) GDPR may apply instead.
Email communications are retained for as long as reasonably necessary to handle the correspondence and any appropriate follow-up, unless a longer period is required by law or is necessary for the establishment, exercise or defence of legal claims.
The contact mailbox is provided through Google. Information sent by email may therefore also be processed by Google in accordance with its applicable terms and privacy policy.
7. Cookies and Tracking Technologies
The Website does not intentionally use cookies or similar persistent identifiers for analytics, advertising, remarketing or profiling.
In particular, GoatCounter does not use analytics cookies, localStorage or persistent visitor identifiers on this Website.
8. Recipients and Service Providers
Where necessary for the purposes described in this Privacy Policy, data may be processed by service providers involved in operating the Website, including:
- Aruba S.p.A., as hosting provider;
- GoatCounter, operated by Martin Tournoij, as the provider of aggregate web analytics;
- Google, in connection with Google Fonts and email communications.
The Controller does not sell or rent visitors' personal data and does not use it for behavioural advertising or profiling.
9. International Data Transfers
According to GoatCounter, its hosted analytics service is operated from Ireland and its hosted data are stored in Finland and Germany, within the European Economic Area.
Other service providers, including Google, may process information outside the European Economic Area. Where applicable, such processing is subject to the safeguards provided for by applicable data-protection law and the relevant provider's contractual arrangements.
10. External Links
The Website contains links to third-party websites and services, including professional, academic and social profiles.
When you follow an external link, the destination website may process personal data under its own privacy policy. The Controller does not control the processing carried out by those third-party websites.
11. Your Rights Under the GDPR
Subject to the conditions set out in the GDPR, you may have the right to:
- obtain confirmation as to whether personal data concerning you are being processed and request access to them;
- request rectification of inaccurate or incomplete personal data;
- request erasure of personal data where the applicable legal requirements are met;
- request restriction of processing;
- object to processing based on legitimate interests;
- receive personal data in a portable format where the right to data portability applies.
To exercise your rights or request further information, contact frenkowski@gmail.com.
You also have the right to lodge a complaint with the competent supervisory authority. In Italy, the supervisory authority is the Garante per la protezione dei dati personali.
12. Automated Decision-Making and Profiling
The Website does not use personal data for automated decision-making or profiling.
13. Changes to This Privacy Policy
This Privacy Policy may be updated if the Website, the services used by it, or applicable legal requirements change.
The date displayed at the top of this page indicates when the Privacy Policy was last updated.