Privacy
policy

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.

In compliance with Articles 13 and 14 of the GDPR, Panajotis Angjelos Sulce, as Data Controller, informs users of the website https://sulko.pages.dev and its clients/suppliers about how their personal data is processed.

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:

04 Data Controller

05 Data collected and purposes of processing

5.1 Data provided through the contact form

Through the form on the Contact page, we collect: name, email, company, reason for the request, and message. This data is processed solely to respond to the user's request and, should the relationship continue, for the pre-contractual phase with a potential client. Emails are sent via the Resend service; they are received in the Controller's Gmail inbox.

5.2 Browsing data and cookies

The website, hosted on Cloudflare Pages, automatically collects some technical browsing data (e.g. IP address, browser type, pages visited). Consent for non-technical cookies is managed via Cookiebot: for full details, see the Cookie Policy published on the site.

5.3 Client and supplier data

As part of the performance of a software development or supply contract, we process identification, tax, and contact data, as well as bank details necessary for wire-transfer payments.

06 Purposes and legal bases of processing

07 Recipients and external data processors

Data may be disclosed to the following parties, acting either as independent controllers or as processors under specific agreements/contractual terms:

Some of these providers (Resend, Google, Cloudflare, Cookiebot) may process data outside the European Economic Area, in particular in the United States. In such cases, the transfer takes place based on the safeguards provided for in Chapter V of the GDPR (e.g. Standard Contractual Clauses and/or adherence to recognized adequacy frameworks).

08 Retention period

• Data collected via the contact form: 12 months from the closing of the request, unless a contractual relationship is established;
• Client and supplier data: 10 years, for tax and civil-law retention obligations;
• Browsing and cookie data: as specified in the Cookie Policy.

09 Rights of data subjects

To exercise these rights, data subjects can write to sulko.development@gmail.com. They also have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

10 Changes to this notice

This Privacy Policy may be updated to reflect regulatory, organizational, or tooling changes on the website. Last revised: 07/13/2026.

11 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.