Privacy Policy

1. Data controller

Samuele Rebecchi, VAT no. 01834540195, Via Mirandola 12, 26100 Cremona (CR), Italy, email samuelerebecchi3@gmail.com. The website samuelerebecchi.com presents an independent performance marketing consulting service.

2. Data collected

Data submitted through the contact form: name, email address, company / brand and message.

3. Purposes and legal bases

• Replying to contact requests and taking steps toward an engagement: pre-contractual measures and contract performance.
• Legal obligations: legal obligation.

4. Recipients

Services used for the website include Lovable (hosting), WordPress.com (domain management), Formspree (contact form submissions) and Gmail (contact email).

We do not sell or share data with third parties for their own marketing purposes.

5. Retention

Contact information is retained as needed to respond to the request and, if a business relationship arises, for the duration of the relationship and for the period required by law.

6. Role

To carry out our engagements we use internal tools that connect, with the client's authorization, to the client's advertising and analytics accounts (Google Ads, Google Analytics 4, Google Tag Manager, Google Search Console, Meta Ads). The data belongs to the client. We process it on the client's behalf and according to the client's instructions.

7. Data we access

Through Google APIs, and only with the client's consent: performance data (impressions, clicks, costs, conversions, value), campaign, ad group, ad and keyword structure, settings and budgets. We do not access payment data and we do not collect personal data of the end users who see the ads, except what may appear in aggregated form in reports.

8. How we use it

Only to provide the client with the functions covered by the engagement: reports and analyses, optimization proposals and, only after explicit approval from the client or the person representing the client for the engagement, changes to the accounts. We do not use the data for advertising, profiling or sale, and we do not share it with third parties for their own purposes.

9. Where it is stored and who processes it

• Working archives on computers and servers (VPS) under our control.
• Services we use to share reports with the client: Notion, Slack, Google Drive.
• Artificial intelligence services that process the data to generate analyses: Anthropic (Claude) and OpenAI.

These providers process the data only to deliver the requested service.

10. Human access

Account data is read only by us, by the client it belongs to, and by collaborators authorized by the client, or where required by law or for security reasons.

11. Compliance with Google's policy

Our use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

12. Retention and deletion

We keep account data for the duration of the engagement and delete it at its end or upon the client's request, unless the law requires otherwise. The client can revoke access at any time from the settings of their Google or Meta account.

13. Transfers outside the EU

Some providers (Anthropic, OpenAI, Google, Notion, Slack) are based in the United States.

14. Security

Encrypted connections, restricted access and two-factor authentication. Credentials are stored separately from working data.

15. Your rights

You may request access, rectification, erasure, restriction, portability and objection, and withdraw any consent, by writing to samuelerebecchi3@gmail.com. We reply within 30 days.

16. Complaints

You may lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or with the authority of your country of residence.

17. Updates

If we change how we use data, we will update this page and inform our clients before the change applies.