Cookie
policy
Which cookies we use, why, and how you can manage your preferences at any time.
Cookie notice pursuant to the measure of the Italian Data Protection Authority (Garante) of June 10, 2021, No. 231, and the ePrivacy Directive 2002/58/EC. Data Controller: Panajotis Angjelos Sulce (SULKO). DPO: not appointed — the conditions requiring mandatory appointment under Art. 37 GDPR do not apply. You can change or withdraw your consent at any time via the "Cookie preferences" button at the bottom of the page.
01 Introduction
This document is adopted by Panajotis Angjelos Sulce, sole proprietor of the individual business operating under the trade name "SULKO" (hereinafter also "the Controller"), as part of its personal data protection management system, in implementation of the accountability principle set out in Article 5(2) of Regulation (EU) 2016/679.
In carrying out its software development-on-commission activity, the Controller processes personal data mainly relating to website visitors, prospects, clients and suppliers, and such processing must constantly be guided by the principles of lawfulness, fairness, transparency, minimization, accuracy, storage and purpose limitation, integrity and confidentiality.
Although this is a small individual business, Regulation (EU) 2016/679 nonetheless requires the adoption of technical and organizational measures appropriate to the risk and the keeping of adequate documentation, as good accountability practice even in the absence of a specific size-based obligation.
This Cookie Policy applies to the website https://sulko.pages.dev, operated by Panajotis Angjelos Sulce (SULKO). For full details on the processing of personal data, please refer to the Privacy Policy published on the site.
02 Regulatory framework
This document falls within the following regulatory framework, to which full reference is made for anything not expressly covered herein:
- Regulation (EU) 2016/679 (GDPR), on the protection of natural persons with regard to the processing of personal data and on the free movement of such data;
- Italian Legislative Decree No. 196 of June 30, 2003 (Data Protection Code), as amended by Legislative Decree No. 101 of August 10, 2018;
- Directive 2002/58/EC (ePrivacy) and its national implementing legislation, on electronic communications and cookies;
- Measure of the Italian Data Protection Authority (Garante) of June 10, 2021, No. 231, on cookies and other tracking tools;
- Guidelines and opinions of the European Data Protection Board (EDPB);
- Articles 2050 and 2220 of the Italian Civil Code and applicable civil/tax law on liability and document retention.
03 Relevant definitions (Art. 4 GDPR)
For the purposes of this document, and unless the context requires otherwise, the terms below have the meaning assigned to them by Article 4 of Regulation (EU) 2016/679:
| Term | Definition |
|---|---|
| Personal data | Any information relating to an identified or identifiable natural person ("data subject"). |
| Processing | Any operation, whether or not by automated means, performed on personal data. |
| Data Controller | The natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data. |
| Data Processor | The natural or legal person which processes personal data on behalf of the Controller, based on an agreement under Art. 28 GDPR. |
| Data subject | The identified or identifiable natural person to whom the personal data relates. |
| Consent | Any freely given, specific, informed and unambiguous indication of wishes by which the data subject agrees to the processing of their data. |
| Personal data breach | A security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. |
| Recipient | The natural or legal person, public authority, agency or other body to which personal data is disclosed. |
| Supervisory authority | The competent independent public authority; for Italy, the Garante per la protezione dei dati personali. |
04 Data Controller
| Field | Information |
|---|---|
| Controller | Panajotis Angjelos Sulce |
| Trade name | SULKO |
| sulko.development@gmail.com | |
| Website | https://sulko.pages.dev |
05 What cookies are
Cookies are small text files that websites send to a user's device (computer, tablet, smartphone), where they are stored before being sent back to the same sites on the next visit. Thanks to cookies, a site remembers a user's actions and preferences over time.
06 Consent management via Cookiebot
The website uses Cookiebot (Cybot A/S) to manage the cookie banner and user consent. On first access, Cookiebot displays a banner allowing the user to accept, reject or customize non-technical cookies by category; non-essential scripts remain blocked until the user gives the relevant consent.
Preferences can be changed or withdrawn at any time via the "Cookie preferences" link in the site footer, which reopens the Cookiebot panel.
07 Categories of cookies used
| Category | Description | Consent required |
|---|---|---|
| Necessary / Technical | Essential for the website to function and to store cookie preferences (including Cookiebot's consent status). | NO — Art. 122(1) Legislative Decree 196/2003 |
| Preferences | Allow the website to remember information that changes its behavior or appearance. | YES |
| Statistics | Collect information in aggregate/anonymous form on how visitors use the site, if and when enabled. | YES |
| Marketing | Used to track visitors across websites, if and when enabled. | YES |
The detailed list of individual cookies actually installed (name, provider, purpose, duration) can be viewed in real time in the "Cookie declaration" automatically generated by Cookiebot below, also always accessible from the banner or the "Cookie preferences" panel in the footer: this list always reflects the site's up-to-date state, even following technical changes made after the publication of this document.
08 Links to external profiles (LinkedIn, GitHub)
The website includes, on the Contact page and in the footer, simple links to the Controller's LinkedIn and GitHub profiles. These are plain hyperlinks, not embedded content: no LinkedIn or GitHub cookie is therefore set simply by browsing the site, but only if the user clicks the link and is directed to the external site, whose use is governed by that platform's own privacy and cookie notices.
09 How to withdraw consent
- Via the "Cookie preferences" panel at the bottom of the site (managed by Cookiebot), at any time;
- Via your browser settings, which allow you to block or delete cookies already installed.
Disabling necessary technical cookies may impair the correct functioning of the website.
10 Rights of data subjects
To exercise the rights of access, rectification, erasure, restriction, portability and objection, users can write to sulko.development@gmail.com, or contact the Italian Data Protection Authority (www.garanteprivacy.it).
11 Updates
This Cookie Policy may be updated to reflect regulatory changes or changes in the tracking tools used on the website. Last revised: 07/13/2026.
12 Final provisions
Effectiveness and commencement
This document is effective from its date of publication and remains in force until a subsequent amendment or revocation by the Controller.
Update and review
The document is subject to periodic review, generally at least annually, as well as whenever significant regulatory, organizational or technological changes occur (e.g. new tools used on the site); every revision is tracked in the relevant history.
Governing law and jurisdiction
This document is governed by Italian law; for any dispute concerning its interpretation, validity or execution, the Court of Como has jurisdiction, without prejudice to the mandatory jurisdiction provided by law for the protection of consumers.
Severability clause
The invalidity, nullity or ineffectiveness of any single clause does not affect the validity and effectiveness of the remaining provisions.