Cookie Policy

Data Controller: SPAPPERI NT S.r.l.

Site: www.spapperi.com

Last updated: 25 May 2026

Version: 2.0

Language note: This Cookie Policy is available in Italian (official version), English, French, German, Spanish, Portuguese and Chinese. In case of discrepancy, the Italian version shall prevail.

1. Introduction and scope

This Cookie Policy describes how SPAPPERI NT S.r.l. (hereinafter "Spapperi", "we" or "the Controller"), with registered office at Via Pietro Ercolani 5/B, 06012 Città di Castello (PG), VAT/Tax Code IT03467460543, uses cookies and similar tracking technologies on the website www.spapperi.com (hereinafter "Site").

This notice is provided pursuant to Art. 13 of EU Regulation 2016/679 (GDPR), Art. 122 of Legislative Decree 196/2003 (Privacy Code, as amended by Legislative Decree 101/2018), as well as the Guidelines of the Italian Data Protection Authority (Garante) on cookies and other tracking tools (Order of 10 June 2021, no. 231) and the related FAQ of 9 December 2021.

This Cookie Policy supplements our Privacy Policy, available separately on the Site, which governs the processing of personal data collected through contact forms, newsletters, job applications, videocall requests and the Customers' Reserved Area.

2. What are cookies and tracking technologies

Cookies are small text files that a website sends to the user's browser and which are stored on the device (computer, tablet, smartphone). On the next visit to the same site, the browser sends them back to the server, allowing the site to recognise the device and remember certain information.

In addition to traditional cookies, the Site uses the browser's localStorage functionality, which allows data to be stored client-side in a persistent manner. From a regulatory standpoint, the use of localStorage falls within the scope of Art. 122 of the Privacy Code (access to or storage of information on the user's terminal device), and is subject to the same consent rules as cookies.

3. Types of cookies used

3.1 Technical and strictly necessary cookies

Technical cookies are indispensable for the correct functioning of the Site. They do not require prior user consent as they are intended to provide a service expressly requested by the user or strictly necessary for the transmission of communication.

Note on language preference: The Site is available in multiple languages. The user's language selection may be stored in the URL structure (path prefix) and/or in a session cookie. No personal data is collected for this purpose.

Note on the Reserved Area: The authentication cookie is set exclusively when the user logs in with their credentials in the Reserved Area. The cookie is of type `httpOnly` (not accessible to client-side JavaScript), `Secure` (transmitted only over HTTPS) and `SameSite=Lax` (CSRF protection). The session lasts 24 hours; rate limiting and blocking mechanisms are implemented after repeated unauthorised access attempts.

3.2 Analytical cookies (subject to consent)

Analytical cookies allow us to measure traffic and interactions on the Site in aggregate form, in order to understand how users navigate and improve the browsing experience. They are activated only if the user provides their consent via the cookie banner.

Google Analytics 4 (GA4)

The Site may integrate Google Analytics, a web analytics service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) or, for EU users, by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland).

The integration is conditional on consent: the Google Analytics script is dynamically loaded in the browser only after the user has accepted the "Analytics cookies" category in the banner. In the absence of consent, no Google Analytics script or cookie is installed.

Risk mitigation measures:

- IP anonymisation: the IP address anonymisation feature is active by default (`anonymize_ip: true`), in accordance with the requirements of the Italian Data Protection Authority and the recommendations of the European Data Protection Board (EDPB). The IP address is truncated before any processing by Google.

- Aggregate data: the data collected is used in aggregate form and is not combined with other data to identify individuals.

- Extra-EU transfers: Google Analytics may involve the transfer of data to the United States. Google adheres to the EU-USA Data Privacy Framework and uses Standard Contractual Clauses (SCC) approved by the European Commission. For more information: [https://policies.google.com/privacy/frameworks](https://policies.google.com/privacy/frameworks).

Data collected through Google Analytics is processed by Google as Data Processor pursuant to Art. 28 GDPR, on the basis of an agreement concluded through acceptance of the Google Analytics for Measurement Terms of Service.

For information on how Google processes data: [https://policies.google.com/privacy](https://policies.google.com/privacy).

3.3 Marketing and profiling cookies (subject to consent)

The "Marketing cookies" category is currently configured in the consent management system but is not currently associated with any active tracking tools on the Site. The related toggle is present in the preferences panel in order to ensure the scalability of the consent system for any future integrations (e.g. tracking pixels for advertising campaigns, retargeting, email marketing platforms).

If marketing tools are activated, this Cookie Policy will be updated with a precise indication of each tool, its provider, duration and specific purpose, and users will be asked for new consent (through an update of the policy version in the banner).

4. Third-party cookies

The Site may contain technical elements (images, videos, scripts) loaded from third-party domains, which may set their own cookies independently of the Controller. This section lists the third parties potentially involved.

For third parties, the Controller has no direct control over the installation of their respective cookies. We recommend consulting the privacy and cookie policies of each third party for complete information.

5. The consent management system (CMP)

The Site is equipped with a cookie banner (Cookie Management Platform – CMP) that appears on the first access of each new user or when previously expressed preferences have expired or have been invalidated due to an update of the policy version.

5.1 How it works

- First visit: when the Site loads, an overlay banner appears that informs the user about the types of cookies used and requests consent for non-technical categories.

- Available choices:

- "Accept all" – activates all cookie categories, including analytics and marketing.

- "Reject non-essential" – rejects all non-technical categories; only strictly necessary cookies will remain active.

- "Manage preferences" – opens a detailed panel that allows the user to selectively activate or deactivate individual categories.

- Saving: the user's choice is stored in the browser's `localStorage` under the key `spapperi_cookie_consent_v2`. This storage serves exclusively to avoid repeating the banner on subsequent visits and has no tracking purpose.

- Reopening preferences: at the bottom of the page there is a discreet button (cookie icon) that allows the user to reopen the preferences panel and modify their choices at any time.

5.2 Consent validity and versioning

The consent system is versioned. The current version is v2. In the event of substantial changes to this Cookie Policy (e.g. introduction of new cookies, new purposes), the version will be updated and users will be shown the banner again to request a new informed consent. Consent previously expressed for a previous version of the policy will not be considered valid for the new version.

5.3 Withdrawal of consent

Previously expressed consent may be withdrawn at any time, without prejudice to the lawfulness of processing based on consent before its withdrawal, through:

1. The "Cookie preferences" button always visible at the bottom of every page of the Site.

2. Browser settings.

3. Deleting localStorage via the browser's developer tools.

6. How to manage cookies through browser settings

Regardless of the choices made through the Site's banner, the user may manage, block or delete cookies through their browser settings. Please note that blocking certain categories of technical cookies may impair the correct functioning of some features of the Site (in particular the Customers' Reserved Area).

Below are links to instructions for the main browsers:

- Google Chrome: [https://support.google.com/chrome/answer/95647](https://support.google.com/chrome/answer/95647)

- Mozilla Firefox: [https://support.mozilla.org/kb/cookies](https://support.mozilla.org/kb/cookies)

- Apple Safari (macOS): [https://support.apple.com/guide/safari/sfri11471/mac](https://support.apple.com/guide/safari/sfri11471/mac)

- Apple Safari (iOS): [https://support.apple.com/HT201265](https://support.apple.com/HT201265)

- Microsoft Edge: [https://support.microsoft.com/microsoft-edge/delete-cookies](https://support.microsoft.com/microsoft-edge/delete-cookies)

For specific opt-out from Google Analytics: [https://tools.google.com/dlpage/gaoptout](https://tools.google.com/dlpage/gaoptout).

7. Consequences of withholding consent

Withholding consent to analytics and/or marketing cookies does not in any way affect the ability to browse the Site, consult public content, fill in contact forms, access the Customers' Reserved Area (if credentials are available) or make use of any other functionality of the Site. Such cookies are strictly optional.

8. Personal data processed through analytical cookies

Data collected through Google Analytics analytical cookies (anonymised IP address, session data, navigation paths in aggregate form) are processed on the legal basis of the data subject's consent pursuant to Art. 6(1)(a) GDPR. For details regarding data subjects' rights (access, rectification, erasure, portability, objection to processing, restriction) and the methods of exercising them, please refer to the Site's Privacy Policy.

9. Data Controller

The Controller of personal data potentially collected through first-party cookies is:

SPAPPERI NT S.r.l.

Via Pietro Ercolani 5/B

06012 Città di Castello (PG) – Italia

P.IVA / C.F.: IT03467460543

REA: PG-291249

Tel.: +39 075 85 78 156

Fax: +39 075 85 78 848

PEC: spapperint@pec.it

E-mail: info@spapperi.com

10. Changes to the Cookie Policy

This Cookie Policy may be updated at any time to reflect regulatory, technological or service-related changes. The "Last updated" date at the top of the document will indicate the current version. In the event of substantial changes affecting the use of cookies subject to consent, the banner will be shown again to users of the Site requesting new consent.

We invite you to periodically consult this page to stay informed about the use of cookies.

For any questions or requests regarding the processing of personal data and the use of cookies, you may contact the Controller at the addresses indicated through the [contact form](/contatti) on the Site.

This Cookie Policy is available in Italian (official version), English, French, German, Spanish, Portuguese and Chinese.