Privacy Policy & Cookie Policy
Notice provided pursuant to Articles 13 and 14 of EU Regulation 2016/679 (GDPR) and the Italian Privacy Code (Legislative Decree 196/2003 as amended by Legislative Decree 101/2018).
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1. Data Controller
The Data Controller for the personal data collected through the website matteocampagna.com (hereinafter "Website") is:
Matteo Campagna
Performance Analyst · MCPerformance
Email: [email protected]
VAT number: IT04237651205
Tax code: CMPMTT95T17A944B
Address: Via Garibaldi 23 · 40033 Casalecchio di Reno (BO) · Italia
Note: the appointment of a Data Protection Officer (DPO) pursuant to Article 37 of the GDPR is not required, as the processing does not fall within the mandatory cases provided by law for individual professional activities of this scale.
2. Types of data collected
The Website collects the following categories of personal data, distinguished by source and collection method:
2.1 Data provided voluntarily by the user
- Contact data: name (optional) and email address, which you provide when writing to us via the contact details listed on the Website or, where active, by completing the relevant sign-up forms (for example, newsletter or free-resource request forms).
- Optional profiling data: content preferences, technical level, sporting goals, only where the user provides them voluntarily through forms or email communications.
- Payment data: in the event of a purchase of manuals or courses, payment data is handled directly by the payment providers (Stripe / PayPal via Systeme.io); the Data Controller receives only confirmation of payment and billing data required by law.
- Technical analysis data (Performance Analysis service): video footage of your shooting, technical questionnaires, optional biometric data (HRV, sleep), only if you have subscribed to a consulting programme.
2.2 Data collected automatically
- Browsing data: IP address, browser type, operating system, pages visited, visit duration, referral source. Collected via Google Analytics 4 in anonymised form.
- Marketing tracking data: UTM parameters (utm_source, utm_medium, utm_campaign) from referral links, conversions measured via GA4 and Meta Pixel.
- Cookies and similar technologies: see the Cookie Policy in section 8.
3. Purposes and legal basis for processing
| Purpose | Legal basis (Art. 6 GDPR) | Duration |
|---|---|---|
| Provision of requested services (newsletter, lead magnets, manuals, courses, consulting) | Performance of a contract (Art. 6(1)(b)) | For the duration of the service |
| Sending marketing emails about content, articles, news, and offers on the Data Controller's products | Explicit consent (Art. 6(1)(a)) | Until consent is withdrawn |
| Statistical analysis of browsing behaviour (anonymised GA4) | Consent (Art. 6(1)(a)), for analytical cookies | Up to 26 months |
| Conversion tracking for advertising purposes (Meta Pixel) | Consent (Art. 6(1)(a)) | Up to 180 days |
| Invoicing and tax compliance | Legal obligation (Art. 6(1)(c)) | 10 years (tax regulations) |
| Defence of legal claims | Legitimate interests (Art. 6(1)(f)) | Limitation periods |
4. Third-party services
The Website uses the following third-party services, which may process personal data as data processors or independent data controllers:
4.1 Systeme.io (email marketing and funnels)
Provider: Systeme.io SAS (France, EU).
Data processed: email address, name, behavioural data (email opens, clicks, funnel activity).
Legal basis: user consent at the time of sign-up.
Privacy policy: systeme.io/privacy-policy
4.2 Google Analytics 4 (statistical analysis)
Provider: Google Ireland Ltd. (Ireland, EU) and Google LLC (USA).
Data processed: anonymised IP, aggregated browsing data, conversion events.
Legal basis: consent (obtained via cookie banner).
IP anonymization active.
Privacy policy: policies.google.com/privacy
4.3 Meta Pixel (Facebook/Instagram, conversion tracking)
Provider: Meta Platforms Ireland Ltd. (Ireland, EU) and Meta Platforms Inc. (USA).
Data processed: anonymous unique browser identifier, conversion events.
Legal basis: consent (obtained via cookie banner).
Privacy policy: facebook.com/privacy/policy
4.4 Hostinger (hosting)
Provider: Hostinger International Ltd. (Lithuania, EU).
Data processed: server logs (IP, timestamp, HTTP requests) for technical and security purposes.
Privacy policy: hostinger.com/legal/privacy-policy
4.5 Cloudflare (CDN and security)
Provider: Cloudflare Inc. (USA), with EU-based servers.
Data processed: IP address, HTTP headers, security logs.
Legal basis: legitimate interest of the Data Controller in the security of the Website.
Privacy policy: cloudflare.com/privacypolicy
4.6 Google Fonts (font loading)
The Website loads typefaces via the Google Fonts API (Google LLC, USA). This involves the transmission of the user's IP address to Google at the time pages are loaded. Legal basis: legitimate interest of the Data Controller in the visual presentation of the Website.
4.7 JavaScript CDN (jsDelivr)
The Website loads JavaScript libraries (Lenis, GSAP) via the jsDelivr CDN. This involves the transmission of the user's IP address to the CDN provider. Legal basis: legitimate interest in Website performance.
5. Transfers of data outside the EU
Some of the third-party services used (in particular Google and Meta) may involve the transfer of personal data outside the European Economic Area (EEA), in particular to the United States of America.
Such transfers take place on the basis of:
- Standard Contractual Clauses approved by the European Commission by Decision 2021/914;
- EU-US Data Privacy Framework for certified providers (Google, Meta);
- Supplementary technical measures (encryption in transit, pseudonymisation).
6. Data retention
Personal data is retained for the period strictly necessary to fulfil the purposes for which it was collected:
- Newsletter subscribers' email addresses: until consent is withdrawn (click "Unsubscribe" at the bottom of any email);
- Customer data (manuals / courses / consulting): 10 years from the last purchase for tax compliance purposes, then automatically deleted;
- GA4 browsing data: 26 months;
- Marketing cookies (Meta Pixel): 180 days;
- Emails exchanged with the Data Controller: 2 years from the last interaction, unless an earlier deletion request is made;
- Technical videos submitted for analysis: 12 months from delivery of the report, then deleted unless an explicit retention request is made.
7. Your rights
As a data subject, you have the right to exercise the following rights at any time (Articles 15-22 GDPR):
- Right of access (Art. 15): to obtain confirmation of whether your personal data is being processed and to receive a copy of it;
- Right to rectification (Art. 16): to update or correct inaccurate data;
- Right to erasure (Art. 17, "right to be forgotten"): to obtain the deletion of your data in the cases provided by law;
- Right to restriction of processing (Art. 18): to request the temporary suspension of processing;
- Right to data portability (Art. 20): to receive your data in a structured, machine-readable format and to transmit it to another data controller;
- Right to object (Art. 21): to object to processing based on legitimate interests or direct marketing;
- Right to withdraw consent (Art. 7): to withdraw any consent given at any time, without affecting the lawfulness of processing carried out prior to withdrawal.
To exercise these rights, send a request by email to [email protected] with the subject line "GDPR · exercise of rights". The Data Controller will respond within 30 days.
8. Cookie Policy
The Website uses cookies and similar technologies (local storage, web beacons) to ensure pages function correctly, collect aggregate statistics, and, only with your prior consent, measure the effectiveness of marketing activities.
8.1 Classification of cookies used
| Category | Type | Examples | Duration | Consent |
|---|---|---|---|---|
| Technical / Necessary | Website operation, security, user preferences | cookie_consent, session |
Session or 1 year | Not required |
| Analytical | Aggregate statistics on browsing behaviour | _ga, _ga_* (GA4) |
2 years | Required |
| Marketing / Profiling | Conversion measurement, advertising retargeting | _fbp, fr (Meta Pixel) |
180 days | Required |
8.2 Managing cookie preferences
On your first visit to the Website, a banner is displayed with three options:
- Accept all cookies: consent to all categories (technical, analytical, marketing);
- Necessary only: consent to technical cookies only, which are essential for the Website to function;
- Customise: granular selection for each category.
You can change your preferences at any time by clicking above, or through your browser settings.
8.3 Disabling cookies via the browser
You can disable cookies directly in your browser. Instructions:
9. Processing of minors' data
The Website is not intended for individuals under the age of 16. The Data Controller does not knowingly collect personal data from minors. Where processing of a minor's data is strictly necessary (e.g. courses for young archers), the explicit consent of the person exercising parental responsibility will be obtained.
10. Changes to this policy
The Data Controller reserves the right to amend this policy at any time, in particular to reflect changes in legislation or technology. Material changes will be communicated by means of a prominent notice on the Website and, where appropriate, by email. The date of the last update is indicated at the top of this document.
11. Contact and complaints
For any questions regarding the processing of your personal data, you may contact the Data Controller at:
Email: [email protected]
Suggested subject: "Privacy · information request"
You also have the right to lodge a complaint with the supervisory authority competent for personal data protection:
Garante per la Protezione dei Dati Personali
Piazza Venezia, 11, 00187 Roma
Telefono: +39 06 696771
Email: [email protected]
Sito: garanteprivacy.it
Online dispute resolution: pursuant to Article 14 of EU Regulation 524/2013, EU-resident consumers may use the online dispute resolution platform (ODR) accessible at: ec.europa.eu/consumers/odr