Privacy Policy

This Application collects some Personal Data from its Users.

Data Controller and Owner

Perform Agency Srl
Via Ottaviano P.co Parisi 147
80040 – San Gennaro Vesuviano (NA)

Owner contact email: info@performagency.it

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, email address, username and website.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
All Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application serves the purpose of providing the service required 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 to the Owner.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The 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 the site (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.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of 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: Analytics, Contacting the User, Content commenting and, upon User’s explicit consent, transfer to third parties such as clients, partners and contractor of the Owner.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data

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

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out

Contacting the User

Contact form (This Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address, first name and last name.

Mailing list or newsletter (This Application)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data collected: email address.

Content commenting

Content commenting services allow Users to make and publish their comments on the contents of this Application.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Comment system managed directly (This Application)

This Application has its own internal content comment system.

Personal Data collected: email address, first name, last name, username and website.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

MailUp (MailUp)

MailUp is an email address management and email sending service provided by MailUp S.p.A.

Personal Data collected: email address.

Place of processing: Italy – Privacy Policy

Displaying content from external platform

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Gravatar (Automattic Inc.)

Gravatar is an image visualization service provided by Automattic Inc. that allows this Application to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.

Personal Data collected: email address and Usage Data.

Place of processing: US – Privacy Policy

Google Fonts (Google Inc.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy

Tracking pixels in commercial communications

Commercial communications sent by email contain a tracking pixel: a very small image, not visible to the user, whose loading upon opening the message makes it possible to detect that the communication has been opened.

The marker used is identical for all recipients of the same campaign and does not contain any identifier of the individual recipient or their email address. The purpose pursued is exclusively the aggregate statistical counting of the total number of opens of the campaign, for the purpose of monitoring the correct delivery of communications and the reputation of the sending domains. No individual measurements of the recipient’s behaviour are carried out, nor is the open data used for profiling purposes, to modify the frequency or content of mailings based on observed behaviour, or to infer the user’s preferences or interests.

IP addresses associated with the loading of the marker are subject to truncation of the last octet at the time of recording, so as to reduce the possibility of linking the event to a specific device. Detection takes place via the TUNE platform (TUNE, Inc., United States), which acts as data processor.

Legal basis: Article 122, paragraph 2-bis, of Legislative Decree No. 196/2003, in relation to the purpose of statistical counting of opens, as provided for by Provision No. 284 of 17 April 2026 of the Italian Data Protection Authority (Guidelines on the use of tracking pixels in email communications).

The recipient may at any time request the discontinuation of the use of tracking pixels in messages addressed to them, while continuing to receive communications, via the link in the footer of each email or by writing to info@iwnews.eu. The request takes effect for all markers present in subsequent communications.

Third-party tracking pixels
Creatives provided by third-party advertisers may contain additional markers, implemented by such parties as independent data controllers for their own purposes. The Controller requires its advertisers to provide prior declaration of the markers present and their respective purposes.

Further information on Personal Data

Transfer to third parties

Upon explicit consent by the User, Personal Data can be transferred to third parties as above specified, which, becoming Data Owners themselves, can send commercial communications (Email/DEM) or do market research for preference profiling through the media they judge appropriate. The list of these subjects can be requested to the Data Controller of this policy.

Here follows a non-complete list of the market areas these subjects belong to: communication products and services, technology, electronics, informatics, internet, websites, financial entities, investors, insurances, social services, welfare, sport, tourism, art, hobbies, entertainment, music, publishing industry, cinema, media, fashion, accessories, clothing, textile, retail, cosmetics, sanitary, chemistry, pharmaceuticals, bio-technology, bodybuilding, food, supermarkets, drinks, stationery, furnishing, appliances, design, transport product and services, vehicles, education, training, instruction, advertising, marketing, events, consultancy, PR, franchises, surveys, market researches, media centres, communication, building sector, civil engineering, real estate products and services and exhibitions.

Should the User refuse to give explicit consent, would still be able to use other Services of This Application.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests.
To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy

This privacy statement is drafted on the basis of multiple legislative orders, including articles 13 and 14 of Regulation (EU) 2016/679.

Last edit: 21/02/2023