Privacy Policy
Last updated: 19 August 2026
This Privacy Policy explains how Davide Tesoro, trading as Suapa Network (“Suapa Network”, “we”, “us” or “our”) collects, uses and protects personal information when you visit or interact with suapa.com or suapanetwork.com (the “Websites”).
We are committed to protecting your privacy and processing personal information fairly, lawfully and transparently.
This Privacy Policy has been prepared with regard to applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Where applicable to individuals located in the European Economic Area (EEA), relevant provisions of the EU General Data Protection Regulation (EU GDPR) may also apply.
1. Data Controller
The data controller responsible for the processing of personal information through the Websites is:
Davide Tesoro trading as Suapa Network
Tax / Business Identification: SA74078377
120 Kingsway North
York
YO30 6JB
United Kingdom
Email: info@suapa.com
Websites: suapa.com and suapanetwork.com
2. Personal Information We Collect
Depending on how you use our Websites, we may collect the following categories of information:
your name;
your email address;
information included in messages sent through our contact form;
IP address;
browser type and device information;
approximate location derived from your IP address;
pages visited and interactions with the Websites;
referral information and traffic source;
cookie and tracking technology identifiers;
information voluntarily provided when contacting us through WhatsApp, Facebook, Instagram or other communication channels.
We do not intentionally collect special category personal data through the Websites.
Please do not submit sensitive personal information through our contact form unless it is necessary for your enquiry.
3. Contact Form
Our Websites use WPForms to provide a contact form.
When you submit the contact form, the information you provide, such as your name, email address and message, is processed so that we can receive, review and respond to your enquiry.
The lawful basis for this processing will normally be our legitimate interests in communicating with prospective or existing clients and responding to business enquiries, or taking steps at your request prior to entering into a contract.
Information submitted through the contact form will not be used for unrelated direct marketing unless we have an appropriate lawful basis to do so.
4. How We Use Your Information
We may process personal information for the following purposes:
responding to enquiries and messages;
providing information about our services;
taking steps requested by you before entering into a contract;
providing and administering services for clients;
operating, maintaining and securing our Websites;
detecting and preventing spam, fraud and abuse;
understanding how visitors use our Websites;
improving our Websites, services and marketing;
measuring advertising and marketing performance;
complying with legal, regulatory, accounting or tax obligations;
establishing, exercising or defending legal claims.
We only process personal information where we have an appropriate lawful basis under applicable data protection legislation.
5. Legal Bases for Processing
Depending on the circumstances, we may rely on one or more of the following lawful bases:
Consent – where you have actively agreed to a particular use of your information, including where consent is required for non-essential cookies and tracking technologies.
Contract – where processing is necessary to take steps at your request before entering into a contract or to perform an agreement with you.
Legitimate interests – where processing is reasonably necessary for operating and developing our business, communicating with clients and prospective clients, protecting our Websites and understanding their performance, provided that those interests are not overridden by your rights and interests.
Legal obligation – where we are required to process or retain information to comply with applicable law.
Where processing is based on consent, you may withdraw that consent at any time.
6. Google Analytics
Our Websites may use Google Analytics 4 (GA4) to help us understand how visitors interact with the Websites.
Google Analytics may process information such as pages visited, session information, approximate location, device and browser information, referral source and interactions with the Websites.
Where required by law, Google Analytics will only be activated after you have provided the appropriate consent through our cookie consent system.
Analytics information is used to understand Website performance and visitor behaviour and to improve our services and online presence.
7. Google Site Kit
We may use Google Site Kit for WordPress to integrate and manage Google services associated with our Websites, including Google Analytics and other Google tools where enabled.
The specific information processed depends on which Google services are activated.
Non-essential Google technologies will be subject to the cookie consent choices available on the Websites where required.
8. Meta Pixel, Facebook and Instagram
Our Websites may use technologies and services provided by Meta Platforms, including the Meta Pixel and links or integrations relating to Facebook and Instagram.
Where enabled, the Meta Pixel may collect information about visits and interactions with our Websites for purposes such as:
measuring advertising effectiveness;
understanding conversions;
creating aggregated audience statistics;
improving advertising campaigns.
Where consent is required, Meta Pixel and similar advertising technologies will not be activated until the visitor has provided the appropriate consent.
Our Websites may also contain links to Facebook and Instagram. When you interact with these services, Meta may process information according to its own privacy policies.
9. Google reCAPTCHA
Our Websites may use Google reCAPTCHA to protect forms and Website functionality against spam, automated submissions and abuse.
reCAPTCHA may process technical information relating to your device, browser, IP address and interaction with the Website in order to determine whether an interaction is likely to originate from a human user.
This processing helps us protect the security and integrity of our Websites.
10. Google Fonts
Our Websites may use Google Fonts to display fonts and visual elements consistently.
Where Google Fonts are loaded directly from Google’s servers, technical information such as your IP address may be transmitted to Google as part of the request required to deliver the font files.
Where appropriate, we may configure fonts to be hosted locally in order to minimise external data transfers.
11. WhatsApp
Our Websites may provide links or buttons allowing visitors to contact Suapa Network through WhatsApp.
If you choose to contact us using WhatsApp, information you provide through that service will also be processed by WhatsApp/Meta in accordance with their own privacy terms.
We will use information received through WhatsApp primarily to respond to your enquiry and communicate with you regarding our services.
12. Hosting and Technical Providers
Our Websites are hosted using infrastructure and services provided by OVHcloud.
Our hosting provider may process limited technical information necessary to operate, secure and maintain the Websites, including server logs, IP addresses and diagnostic information.
We may also use trusted technical service providers, WordPress plugins and security or maintenance services where reasonably necessary to operate the Websites.
13. Cookies and Similar Technologies
Our Websites use cookies and similar technologies.
We use WPConsent to provide visitors with controls over non-essential cookies and tracking technologies.
Cookies may be used for:
essential Website functionality;
security;
remembering cookie preferences;
analytics;
Website performance;
advertising and conversion measurement;
third-party integrations.
More information is available in our separate Cookie Policy.
You can change or withdraw your cookie preferences using the cookie settings available on the Websites.
14. Sharing Personal Information
We do not sell personal information.
We may share limited personal information with service providers where necessary to operate our business and Websites, including providers of:
website hosting;
website infrastructure and security;
analytics;
spam prevention;
advertising and social media services;
professional, accounting or legal services where required.
These organisations may act as processors or independent controllers depending on the service concerned.
We may also disclose information where required by law or where reasonably necessary to establish, exercise or defend legal rights.
15. International Data Transfers
Some of the technology providers used by our Websites are international organisations and may process information outside the United Kingdom or European Economic Area, including in the United States.
Where a restricted international transfer takes place, we seek to rely on a legally recognised transfer mechanism where required, which may include applicable adequacy regulations or decisions, the UK Extension to the EU-US Data Privacy Framework where applicable, contractual safeguards or other mechanisms recognised under applicable data protection law.
16. Data Retention
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, accounting or reporting requirements.
Contact enquiries that do not result in an ongoing business relationship will generally be retained only for as long as reasonably necessary to deal with the enquiry and any relevant follow-up.
Information relating to clients, transactions and contractual relationships may be retained for longer periods where required for tax, accounting, contractual or legal purposes.
Analytics information is retained according to the retention settings configured within the relevant analytics service.
17. Data Security
We take reasonable technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.
These measures may include secure hosting, HTTPS encryption, access controls, software updates, backups and security measures implemented through WordPress and our hosting infrastructure.
However, no internet-based system can be guaranteed to be completely secure.
18. Your Data Protection Rights
Depending on your location and the applicable law, you may have rights relating to your personal information, including the right to:
request access to personal information we hold about you;
request correction of inaccurate or incomplete information;
request deletion of your personal information in certain circumstances;
request restriction of processing;
object to certain processing;
request portability of information where applicable;
withdraw consent where processing is based on consent;
lodge a complaint with the relevant data protection authority.
These rights are subject to applicable legal conditions and exemptions.
To exercise your rights, contact:
We may need to verify your identity before responding to certain requests.
19. Complaints
If you are located in the United Kingdom and believe that your personal information has not been handled appropriately, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
We would appreciate the opportunity to address your concerns first, and you can contact us at info@suapa.com.
Individuals located in the EEA may also have the right to complain to the competent supervisory authority in their country.
20. Third-Party Websites
Our Websites may contain links to third-party websites, social networks and services.
We are not responsible for the privacy practices, security or content of websites operated by third parties. We recommend reviewing their privacy information before providing personal information.
21. Children’s Privacy
Our Websites and services are intended primarily for businesses and adult users.
We do not knowingly use the Websites to collect personal information from children.
22. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes to our Websites, services, technology providers or applicable legal requirements.
The latest version will always be published on suapa.com and suapanetwork.com, with the date of the latest update shown at the top.
23. Contact Us
For questions about this Privacy Policy or how Suapa Network processes personal information, please contact:
Davide Tesoro trading as Suapa Network
120 Kingsway North
York
YO30 6JB
United Kingdom
Email: info@suapa.com
