Privacy & Cookie Policy

Last update: October 24, 2025

This Privacy & Cookie Policy describes how Hobo Coin by Massimo Cuccagna (hereinafter, the “Controller”) processes personal data of users who visit or use the website and e-commerce services.

1) Data Controller

• Controller: Hobo Coin di Massimo Cuccagna

• Registered office: Via Rizziconi 20, 00118 Rome, Italy

• VAT number: IT14126721001 — REA: RM-1508324

• E-mail: sales@hobocoin.it

The Controller has not appointed a Data Protection Officer (DPO). Any future updates will be published in this section.

2) Purposes and Legal Bases of Processing

Personal data is processed in accordance with EU Regulation 2016/679 (GDPR) and Legislative Decree 196/2003, as amended by Legislative Decree 101/2018.

Providing mandatory data is necessary to use the services. Failure to provide such data may prevent completion of registration or orders.

3) Data Recipients

Data may be processed by:

• IT and hosting providers;

• Payment processors (e.g., PayPal, Stripe, banking systems);

• Shipping and logistics partners;

• Accounting, tax, and legal consultants;

• Email marketing and CRM platforms;

• Analytics and advertising providers (Google, Meta/Facebook, etc.).

All parties act as Data Processors under Art. 28 GDPR or as Independent Controllers, depending on the type of service.

4) Transfers Outside the EU

Some providers (e.g., Google LLC, Meta Platforms) may process data in non-EU countries. Such transfers comply with Chapter V GDPR, using Standard Contractual Clauses (SCCs) or other appropriate safeguards. Copies of these safeguards are available upon request at sales@hobocoin.it.

5) Data Subject Rights

Users can exercise their rights under Articles 15–22 GDPR, including:

• Access to personal data;

• Rectification or deletion;

• Restriction or objection to processing;

• Data portability;

• Withdrawal of consent (without affecting lawfulness before withdrawal).

To exercise rights: contact sales@hobocoin.it or send a written request to the Controller’s address.

Users also have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it) or their local supervisory authority.

6) Data Security

The Controller adopts appropriate technical and organizational measures to ensure data confidentiality and prevent unauthorized access, loss, or misuse.

7) Minors

This website and its services are intended for users aged 18 and over. If data from minors is processed without verified parental consent, it will be deleted. Under Italian law, the minimum age for digital consent is 14 years.

8) Cookies and Tracking Technologies

8.1 What are Cookies

Cookies are small text files stored in the user's browser that contain information about website activity. They can be temporary (session cookies) or permanent.

8.2 Types of Cookies Used

• Technical cookies: necessary for the operation of the site (cart, authentication, security). Legal basis: legitimate interest.

• Preference/functionality cookies: remember optional settings (language, currency). Legal basis: consent.

• Analytics cookies: collect anonymous or aggregated statistics about site usage. Legal basis: consent, unless anonymized.

• Marketing and profiling cookies: used for personalized ads and remarketing. Legal basis: consent.

8.3 Third-Party Tools

The site uses or may use:

• Google Analytics 4 (Google LLC) — traffic and performance analysis.

• Google Ads / Conversion Tracking — conversion measurement and advertising.

• Meta (Facebook/Instagram) Pixel & Conversion API — analytics and remarketing via Meta platforms.

Data may be transferred to the United States with adequate safeguards (SCCs and privacy-by-design configurations).

8.4 Consent Management

When first visiting the site, a cookie banner allows users to accept, reject, or manage preferences. Choices can be changed at any time through the “Cookie Settings” link in the website footer.

8.5 Browser Control

Users can manage cookies directly via their browser, deleting or blocking them. Disabling technical cookies may affect site functionality.

9) Data Retention

Data is retained for the time necessary to fulfill the stated purposes or for longer periods required by law (e.g., tax obligations). Afterward, data is securely deleted or anonymized.

10) Automated Decisions and Profiling

No automated decision-making that produces legal or significant effects on users is carried out. Any profiling activities are based on explicit consent and used only for promotional purposes.

11) Policy Updates

The Controller may modify this Policy to comply with new regulations or technical updates. Significant changes will be communicated via banner, email, or on-site notifications.

12) Contact Information

For any inquiries or to exercise data protection rights:

• E-mail: sales@hobocoin.it

• Mail: Hobo Coin di Massimo Cuccagna, Via Rizziconi 20, 00118 Rome, Italy

Appendix — Promotional Communications (Soft-Spam)

Under Art. 130(4) of the Italian Privacy Code, the Controller may use an email address provided during a purchase to send information about similar products or services, unless the user objects. You may object at any time, free of charge, via the unsubscribe link or by writing to sales@hobocoin.it.