Slow Sicily Privacy Policy

Data Controller: Tommaso Ragonese and Marco Crupi – contact: [email protected]. Slow Sicily (https://slow-sicily.com/) does not collect personal data via registration or newsletter forms. Contact with the Data Controllers occurs only via email (mailto:). Personal data are collected only through cookies and third-party analytics tools.

Personal Data Collected

We use only technical and analytical cookies. Third-party tools (Google Analytics 4, Microsoft Clarity, Jetpack, etc.) collect browsing data and connection data such as IP address (generally anonymized) and user behavior (pages visited, clicks, scrolls). For example:

  • Google Analytics 4 (Google LLC, USA): captures aggregate visit and session data using cookies (e.g. _ga).
  • Microsoft Clarity (Microsoft Ireland Ltd, EU): records user sessions (heatmaps, clicks, mouse movements) with masked data.
  • Jetpack (Automattic Inc., USA): provides similar traffic statistics.
  • Polylang: sets a language preference cookie.
  • Consent Management Plugins (CookieYes, WP Consent API): implement the cookie consent banner and do not collect personal data themselves.

No sensitive personal data (such as names or emails) are collected, since there are no forms. Users browse anonymously until they choose to consent via the cookie banner.

Purposes and Legal Basis

Collected data are used only for statistical analysis and improvement of the site (traffic analysis, site performance, content optimization). No profiling or commercial use is made of the data. The legal basis for processing is the explicit consent of the user under EU ePrivacy rules and GDPR (Art.6(1)(a)). Consent is obtained via the cookie consent banner (CookieYes plugin), which allows users to accept or reject analytics cookies. Strictly necessary cookies for basic site functionality do not require consent.

Cookies and Third-Party Tools

We use cookies and scripts from third parties under their respective privacy policies:

  • Google Analytics 4: Google LLC’s analytics service. It collects anonymous traffic data (no individual profiling) using cookies like _ga. Data are transferred to the USA under the EU-US Data Privacy Framework (the EU-US data transfer agreement).
  • Microsoft Clarity: A behavior analytics tool. Records interactions (clicks, scrolls, heatmaps). Microsoft Ireland (EU) hosts EU data and uses Standard Contractual Clauses (SCC) for any transfers to Microsoft Corp. in the USA. Clarity is GDPR-compliant.
  • Jetpack (WordPress.com Stats): Collects basic visit/pageview stats and transfers data to USA. Automattic applies analogous safeguards.
  • Other plugins (Yoast SEO, Redirection, Polylang, etc.): Do not collect additional personal data beyond technical or preference cookies.
  • CookieYes (Cookie Consent plugin): Handles the consent banner, blocking non-essential scripts until consent. It does not track personal data.

Details about cookie usage (types, purposes, durations) are given in our Cookie Policy, which is linked from the CookieYes banner. The banner ensures transparency by informing users which cookies are used and for how long.

International Data Transfers

Data collected by Google LLC (GA4) may be transferred to the USA under adequacy protections (EU-US Data Privacy Framework). . Microsoft Clarity processes data via Microsoft Ireland; any necessary transfers to the USA are covered by SCCs. In all cases, adequate data protection measures are in place during transfers outside the EU, in compliance with GDPR.

User Rights

Under the GDPR (Articles 15-22), users have the following rights regarding their personal data: access, rectification, erasure (the right to be forgotten), restriction of processing, objection to processing, data portability, and withdrawal of consent. Users can exercise these rights at any time by contacting the Data Controller via the email above. They also have the right to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority) if they believe their rights have been violated.

Cookie Policy and CookieYes Banner

We use the CookieYes platform (a leading GDPR/CCPA cookie consent solution) to implement the cookie consent banner. No non-essential cookies are set until the user gives consent. The banner provides a link to our comprehensive Cookie Policy, which explains in detail the cookies used, their purposes, and how users can manage or withdraw consent.