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Privacy Policy

Spùn collects some Personal Data of its Users.


Data Controller

Piazzale Egeo S.r.l., via Vincenzo Foppa 8, 20144 Milan

Data Controller Email Address:


Types of Data collected

Among the Personal Data collected by this Application, either independently or through third parties, there are: Tracking Tools; first name; last name; phone number; email; Usage Data.

The complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data is collected. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. If not otherwise specified, all Data requested by this Application is mandatory. If the User refuses to disclose them, this Application may be unable to provide the Service. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or functioning of the Service. Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller. Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application, unless stated otherwise, serves to provide the Service requested by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published, or shared through this Application and confirm that they have the third party's consent to provide the Data, releasing the Data Controller from any liability to third parties.


Methods and location of processing the collected Data

Processing methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.


Legal basis of processing

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

  • The User has given consent for one or more specific purposes. Note: Under some legislations, the Data Controller may be allowed to process Personal Data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply whenever the processing of Personal Data is subject to European data protection law;

  • processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations thereof;

  • processing is necessary for compliance with a legal obligation to which the Data Controller is subject;

  • processing is necessary for the performance of a task carried out in the public interest or for the exercise of official authority vested in the Data Controller;

  • processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

In any case, the Data Controller will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.



The Data is processed at the Data Controller's operating offices and in any other places where the parties involved in the processing are located. For further information, please contact the Data Controller. Personal Data of the User may be transferred to a country other than their own. To find out more about the location of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Data Controller to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Data Controller using the information provided in the contact section.


Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Data Controller's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data Controller.


The Data Controller may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.


Purpose of processing the collected Data

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Tag Management Services, Statistics, and Platform services and hosting.

For specific information on the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.


Detailed information on the processing of Personal Data

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


Tag Management Services

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.


Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: Ireland – Privacy Policy.


Platform services and hosting

These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g., analytics, user registration, commenting, database management, e-commerce, payment processing, etc. – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data is stored.


Wix (, Ltd.)

Wix is a hosting service provided by, Ltd. that allows the Owner to build, run and host this Application.

Wix is an extremely versatile and customizable tool that allows hosting various types of websites, from simple blogs to complex e-commerce platforms.

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

Place of processing: Israel – Privacy Policy.


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

Google Analytics (Google Ireland Limited)

Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports, and sharing them with other Google services. Google may use Personal Data to contextualize and personalize ads from its advertising network.

Personal Data processed: Usage Data; Tracking Tools.

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


Meta Events Manager (Meta Platforms Ireland Limited)

Meta Events Manager is a statistical service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can provide the Data Controller with information about traffic and interactions on this Application.

Personal Data processed: Usage Data; Tracking Tools.

Location of processing: Ireland – Privacy Policy.


User Rights

Users can exercise certain rights regarding the Data processed by the Controller.

In particular, the User has the right to:

  • withdraw consent at any time. The User can revoke consent to the processing of their Personal Data previously expressed.

  • object to the processing of their Data. The User can 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 about the Data processed by the Controller, certain aspects of the processing, and to receive a copy of the processed Data.

  • verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.

  • obtain the restriction of processing. When certain conditions are met, the User can request the restriction of the processing of their Data. In this case, the Controller will not process the Data for any purpose other than their storage.

  • obtain the erasure or removal of their Personal Data. When certain conditions are met, the User can request the erasure of their Data by the Controller.

  • receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, on a contract of which the User is a party, or on contractual measures connected to it.

  • lodge a complaint. The User can 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 Controller, or for the legitimate interests pursued by the Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are informed that if their Data is processed for direct marketing purposes, they can object to the processing without providing any justification. To find out if the Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to Exercise Rights

To exercise User rights, Users can make a request to the contact details of the Controller provided in this document. Requests are made free of charge and processed by the Controller as soon as possible, in any case within one month.

Additional Information on Processing

Legal Defense

The User's Personal Data may be used by the Controller in court or in the preparatory stages leading to its possible establishment for defense against abuse in the use of this Application or the related Services by the User. The User declares to be aware that the Controller may be required to disclose the Data by 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 operation and maintenance purposes, this Application and any third-party services it uses 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

Additional information regarding the processing of Personal Data may be requested at any time from the Controller using the contact details provided.

Response to "Do Not Track" Requests

This Application does not support "Do Not Track" requests. To find out if any third-party services used support them, Users are encouraged to consult the 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 notifying Users on this page and, if possible, on this Application, and, if technically and legally feasible, by sending a notice to Users through one of the contact details it holds. Therefore, please check this page frequently, referring to the last modified date indicated at the bottom.

If the changes affect processing for which consent is the legal basis, the Controller will collect User consent again, if necessary.

Definitions and Legal References

Personal Data (or Data) 

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 

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


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

Data Subject 

The natural person to whom the Personal Data refers.

Data Controller (or Controller) 

The natural or legal person, public authority, service, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data and the tools adopted, including the security measures related 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 through which the Personal Data of Users is collected and processed.


The service provided by this Application as described in the relative terms (if available) on this site/application.

European Union (or EU) 

Unless otherwise specified, any reference to the European Union contained in this document is extended to all current member states of the European Union and the European Economic Area.


Cookies are Tracking Tools consisting of small pieces 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 saving information on the User's device.

Legal References 

This privacy policy is drafted based on multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy exclusively concerns this Application.

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