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This document contains information on the technologies that allow this Website to achieve the purposes described below. These technologies allow the Data Controller to collect and save information (for example through the use of Cookies) or to use resources (for example by running a script) on the User's device when the latter interacts with this Website.
For the sake of simplicity, in this document these technologies are summarized as "Trackers", unless there is reason to differentiate.
For example, although Cookies can be used in both web and mobile browsers, it would be inappropriate to talk about Cookies in the context of applications for mobile devices, since these are Trackers that require the presence of a browser. For this reason, in this document the term Cookie is only used to specifically indicate that particular type of Tracker.
Moreover, some of the purposes for which Trackers are used may require the User's consent. If consent is given, it can be freely revoked at any time by following the instructions contained in this document.
This Website uses Trackers managed directly by the Data Controller (commonly called "first-party" Trackers) and Trackers that enable services provided by third parties (commonly called "third-party" Trackers). Unless otherwise specified herein, such third parties have access to their respective Trackers.
The duration and expiry of Cookies and other similar Trackers may vary depending on the parameters set by the Data Controller or by each third party provider. Some of them expire at the end of the User's browsing session.
In addition to the descriptions provided for each category below, Users may obtain more detailed and updated information on duration, as well as any other relevant information - such as the presence of other Trackers - in the privacy policies of the respective third-party providers (via the links made available) or by contacting the Data Controller.
Activities strictly necessary to ensure the functioning of this Website and the provision of the Service
This Website uses what is commonly known as "technical” Cookies or other similar Trackers to carry out activities strictly necessary to ensure the functioning of the Website or the provision of the Service.
1. Third-Party Trackers
Infrastructure monitoring
This type of service allows this Website to monitor the use and behavior of its components with a view to improving performance, functionality, maintenance, and problem resolution.
The Personal Data processed depends on the characteristics and method of implementation of these services, which by their nature filter the activities of this Website.
New Relic (New Relic)
New Relic is a monitoring service provided by New Relic Inc.
The way New Relic is integrated means it filters all the traffic of this Website, i.e. the communications between this Website and the User's browser or device, also allowing the collection of statistical data relating to same.
Personal Data processed: Usage data, Trackers and various types of Data as specified in the privacy policy of the service.
Place of processing: United States - Privacy Policy.
Other activities involving the use of Trackers
2. Measurement
This Website uses Trackers to measure traffic and analyze User behavior with the aim of improving the Service.
Anonymous statistics services
The services in this section allow the Data Controller to process and manage statistics anonymously through the use of first-party Trackers.
Google Analytics with anonymized IP
Google Analytics is a web analytics service provided by Google LLC or by Google Ireland Limited ("Google"), depending on how the Data Controller manages data processing. Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use said Personal Data to contextualize and personalize the ads of its advertising network.
The integration of Google Analytics makes your IP address anonymous. Anonymization works by shortening the IP address of Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to a Google server and shortened in the United States.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Storage duration:
· AMP_TOKEN: 1 hour
· _ga: 2 years
· _gac*: 3 months
· _gat: 1 minute
· _gid: 1 day
· Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
Google Analytics (Google LLC)
Google Analytics is a web analytics service provided by Google LLC ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use this Personal Data to contextualize and personalize the ads of its advertising network.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out.
Storage duration:
· AMP_TOKEN: 1 hour
· _ga: 2 years
· _gac*: 3 months
· _gat: 1 minute
· _gid: 1 day
Google Ads conversion tracking
Google Ads conversion tracking is a statistics service provided by Google LLC or by Google Ireland Limited (depending on how the Data Controller manages data processing), which connects data from the Google Ads advertising network with the actions performed on this website.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy; Ireland – Privacy Policy.
Storage duration:
· IDE: 2 years
· test_cookie: 15 minutes
Google Analytics 4
Google Analytics is a statistics service provided by Google LLC or by Google Ireland Limited ("Google"), depending on how the Data Controller manages data processing. Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use this Personal Data to contextualize and personalize the ads of its advertising network.
With Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To find out more, please consult the official Google documentation.
Personal Data processed: City, usage data, browser information, device information, number of Users, session statistics and Trackers.
Place of processing: United States - Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Storage duration:
· _ga: 2 years
· _ga_*: 2 years
· _gac_gb_*: 3 months
· _gid: 1 day
Google Floodlight Conversion Tracking (Floodlight Tag)
Google Floodlight Conversion Tracking (Floodlight tag) is a statistics service provided by Google LLC or by Google Ireland Limited (depending on how the Data Controller manages data processing), which connects Data from Google's advertising services (e.g. Search Ads 360 and Campaign Manager 360) with the actions performed on this Website. Depending on the settings of the service, such Data could also be processed for retargeting purposes.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Facebook Ads conversion tracking (Facebook pixel)
Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited (depending on how the Data Controller manages data processing), which connects data from the Meta advertising network with the actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to Facebook, Instagram and Audience Network ads.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy; Ireland – Privacy Policy.
Storage duration:
· _fbp: 3 months
· fr: 3 months
1. Targeting and Advertising
This Website uses Trackers to deliver personalized commercial content based on User behavior and to manage, disseminate and track advertisements.
· Affiliate marketing
This type of service allows this Website to display advertisements for products or services offered by third parties. The ads can be displayed both as advertising links and as banners in various graphic forms.
Clicks on the icons or banners published on this Website are tracked by the third-party services listed below and are shared with this Website.
To find out what data is collected, please refer to the privacy policies of each service.
Awin (AWIN AG)
Awin is an affiliate marketing service provided by AWIN AG.
Personal Data processed: Usage data and Trackers.
Place of processing: Germany – Privacy Policy.
Storage duration: up to 1 year
CJ Affiliate
CJ Affiliate is an affiliate marketing service provided by Commission Junction LLC (part of Publicis Groupe) or by Epsilon International UK Ltd (part of Publicis Groupe), depending on how the Data Controller manages data processing.
Personal Data processed: Purchase history, usage data and Trackers.
Place of processing: United States - Privacy Policy; United Kingdom - Privacy Policy.
Storage duration:
· cje: 2 years
Stylight
Stylight affiliation
· Advertising
This type of service allows the User's Data to be used for business communication purposes. Such communications are shown on this Website as banners or as other forms of advertising, also in relation to the interests of the User.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are set out below.
Some of the services listed below may use Trackers to identify Users or they may use behavioral retargeting, i.e. displaying personalized advertisements based on the User's interests and behavior, also detected outside this Website. For more information in this regard, please consult the privacy policies of the respective services.
Generally, services of this type offer the possibility of disabling such tracking. In addition to any opt-out feature provided by any of the services listed in this document, Users may find out more about how to opt out of interest-based advertising in the section of this document entitled “How to opt out of interest-based advertising".
Microsoft Advertising (Microsoft Corporation)
Microsoft Advertising is an advertising service provided by Microsoft Corporation.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out.
Storage duration:
· MUID: 2 years
· _uetmsclkid: 3 months
· _uetmsclkid: not defined
· _uetsid: 1 day
· _uetsid: not defined
· _uetvid: 2 years
· _uetvid: not defined
Zemanta (Zemanta Inc, a branch of Outbrain Inc.)
Zemanta is an advertising service provided by Zemanta Inc, a branch of Outbrain Inc.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out.
Storage duration: up to 1 year
RTB House (RTB House S.A.)
RTB House is an advertising service provided by RTB House S.A.
Personal Data processed: Usage data and Trackers.
Place of processing: Poland – Privacy Policy – Opt out.
Storage duration:
· ts: 1 year
· u: 1 year
Criteo (Criteo SA)
Criteo is an advertising service provided by Criteo SA.
Personal Data processed: Usage data and Trackers.
Place of processing: France – Privacy Policy – Opt out.
Storage duration:
· cto_bundle: 2 years
· cto_bundle: not defined
· cto_optout: 5 years
· cto_optout: not defined
· optout: 5 years
· uid: 2 years
Google Ads Similar Audiences
Similar Audiences is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited (depending on how the Data Controller manages data processing), which uses Google Ads Remarketing Data to display advertisements to Users who behave in a similar way to other Users already present on the remarketing list due to their previous use of this Website.
Based on this Data, personalized ads will be shown to Users suggested by Google Ads Similar Audiences.
Users who do not want to be included in Similar Audiences can choose not to participate and disable the use of ad Trackers by visiting Google’s ad settings.
To learn more about how Google uses Data, please consult the Google partner policies.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Storage duration:
· AID: 2 years
· ANID: 2 years
· Conversion: 3 months
· DSID: 14 days
· FCNEC: 1 year
· FLC: 10 seconds
· FPAU: 3 months
· FPGCLAW: 3 months
· FPGCLDC: 3 months
· FPGCLGB: 3 months
· IDE: 2 years
· NID: 6 months
· RUL: 1 year
· TAID: 14 days
· __gads: 2 years
· __gsas: 2 years
· _gac_: 3 months
· _gac_gb_: 3 months
· _gcl_au: 3 months
· _gcl_aw: 3 months
· _gcl_dc: 3 months
· _gcl_gb: 3 months
· _gcl_gf: 3 months
· _gcl_ha: 3 months
· id: 2 years
· test_cookie: 15 minutes
Google AdSense
Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages data processing. This service uses the "DoubleClick" Cookie, which tracks use of this Website and User behavior in relation to advertisements, products and services offered.
The User may decide at any time to disable all DoubleClick cookies on Ads settings.
To learn more about how Google uses Data, please consult the Google partner policies.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Storage duration:
· AID: 2 years
· ANID: 2 years
· Conversion: 3 months
· DSID: 14 days
· FCNEC: 1 year
· FLC: 10 seconds
· FPAU: 3 months
· FPGCLAW: 3 months
· FPGCLDC: 3 months
· FPGCLGB: 3 months
· IDE: 2 years
· NID: 6 months
· RUL: 1 year
· TAID: 14 days
· __gads: 2 years
· __gsas: 2 years
· _gac_: 3 months
· _gac_gb_: 3 months
· _gcl_au: 3 months
· _gcl_aw: 3 months
· _gcl_dc: 3 months
· _gcl_gb: 3 months
· _gcl_gf: 3 months
· _gcl_ha: 3 months
· id: 2 years
· test_cookie: 15 minutes
· Remarketing and behavioral targeting
This type of service allows this Website and its partners to communicate, optimize and publish advertisements based on the User’s past use of the Website.
This activity is facilitated by the tracking of Usage Data and by the use of Trackers to collect information which is then transferred to the partners who manage the remarketing and behavioral targeting activities.
Some services offer a remarketing option based on electronic mailing lists.
Generally, services of this type offer the possibility of disabling such tracking. In addition to any opt-out feature provided by any of the services listed in this document, Users may find out more about how to opt out of interest-based advertising in the section of this document entitled “How to opt out of interest-based advertising".
Criteo Dynamic Retargeting (Criteo SA)
Criteo Dynamic Retargeting is a remarketing and behavioral targeting service provided by Criteo SA, which connects the activities of this Website with the Criteo advertising network.
Personal Data processed: Usage data and Trackers.
Place of processing: France – Privacy Policy – Opt out.
Storage duration:
· criteo_write_test: session duration
· cto_tld_test: session duration
· has_js: session duration
Google Ads Remarketing
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited (depending on how the Data Controller manages data processing), which connects the activities of this Website with the Google Ads advertising network and the DoubleClick Cookie.
To learn more about how Google uses Data, please consult the Google partner policies.
Users can choose not to use Google's Trackers for ad personalization by visiting the Google Ad settings.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Storage duration:
· AID: 2 years
· ANID: 2 years
· Conversion: 3 months
· DSID: 14 days
· FCNEC: 1 year
· FLC: 10 seconds
· FPAU: 3 months
· FPGCLAW: 3 months
· FPGCLDC: 3 months
· FPGCLGB: 3 months
· IDE: 2 years
· NID: 6 months
· RUL: 1 year
· TAID: 14 days
· __gads: 2 years
· __gsas: 2 years
· _gac_: 3 months
· _gac_gb_: 3 months
· _gcl_au: 3 months
· _gcl_aw: 3 months
· _gcl_dc: 3 months
· _gcl_gb: 3 months
· _gcl_gf: 3 months
· _gcl_ha: 3 months
· id: 2 years
· test_cookie: 15 minutes
Facebook Remarketing
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited (depending on how the Data Controller manages data processing), which connects the activities of this Website with the Facebook advertising network.
Personal Data processed: Usage data and Trackers.
Place of processing: United States - Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Storage duration:
· _fbp: 3 months
How to manage preferences and give or withdraw consent
There are various ways to manage preferences relating to Trackers and to give or withdraw consent, where necessary:
Users can manage Tracker preferences directly through their device settings - for example, they can prevent the use or storage of Trackers.
In the case of strictly necessary cookies (see point 1), these are installed by default and do not require the User’s consent for their installation. The use of these cookies allows the correct functioning of the Website.
Whenever the use of Trackers depends on consent (see points 2 and 3), the User can freely give or revoke their consent by setting their preferences via the cookie policy or through the Aspesi "cookie banner": (a) the can give consent by granularly selecting the type of cookies they intend to enable and clicking on the "On/Off" button, or by consenting to the installation of all cookies by clicking on "Accept all cookies"; (b) or they can deny consent and refuse installation of cookies by clicking on "Continue without consent", at the top right of the banner, or on "Reject everything". In the absence of the User’s consent, expressed as described above, only strictly necessary cookies will operate.
Through specific browser or device features, it is also possible to remove previously saved Trackers.
Other Trackers present in the browser's local memory can be removed by deleting the browsing history.
As regards third-party Trackers, Users can manage their preferences and revoke their consent by clicking on the relevant opt-out link (if available), using the tools described in the third party's privacy policy or contacting the latter directly.
Locating Tracker settings
Users can find information on how to manage Cookies in some of the most popular browsers at the following addresses:
· Google Chrome
· Mozilla Firefox
· Apple Safari
· Microsoft Internet Explorer
· Microsoft Edge
· Brave
· Opera
Users can also manage some Trackers for mobile applications by disabling them through the appropriate device settings, such as advertising settings for mobile devices or general tracking settings (see the device settings to identify the relevant method).
How to opt out of interest-based advertising
Without prejudice to the foregoing, Users may also consult the information on YourOnlineChoices (EU), Network Advertising Initiative (USA) and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. With these services it is possible to manage the tracking preferences of most advertising tools. The Data Controller, therefore, advises Users to use these resources in addition to the information provided in this document.
The Digital Advertising Alliance also makes available an application called AppChoices which helps Users control behavioral advertising on mobile applications.
Consequences of refusing to consent
Users are free to decide whether or not to give consent. However, please note that Trackers allow this Website to provide Users with a better experience and advanced features (in line with the purposes outlined herein). Therefore, in the absence of the User's consent, the Data Controller may not be able to provide the related features.
Data Controller
ASPESI Corso Venezia 14, 20121 Milan, Italy
Data Controller's email address: support@aspesi.it
Since the use of third-party Trackers on this Website cannot be fully controlled by the Data Controller, any specific references to third-party Trackers are to be considered indicative. For more in-depth information, Users are kindly invited to consult the privacy policy of the respective third-party services listed in this document.
Given the objective complexity of identifying tracking technologies, Users are invited to contact the Data Controller should they wish to receive further information regarding the use of such technologies on this Website.
Definitions and legal references
Personal Data (or Data)
Personal data is any information which results in a natural person being identified or identifiable, directly or indirectly, also in connection with any other information, including a personal identification number.
Usage Data
The term "Usage Data" refers to information collected automatically through this Website (also by third-party applications integrated into this Website), including: IP addresses or domain names of the computers used by Users connecting to the website, URI (Uniform Resource Identifier) addresses of requested resources, the time of request, the method used to submit the request to the server, the returned file size, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various elements of time related to the visit (e.g. the time spent on each page) and details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, parameters regarding the users’ operating system and the User’s computer environment.
User
The individual who uses this Website. Unless otherwise specified, this coincides with the data subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor
The natural person, legal person, public administration or other body that processes personal data on behalf of the Data Controller, in accordance with the provisions of this privacy policy.
Data Controller
The natural person, legal person, public authority, service or other body that, individually or jointly, determines the purposes and means of processing personal data and the tools adopted, including security measures relating to the functioning and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.
This Website (or this Application)
The hardware or software tool through which the Personal Data of Users is collected and processed.
Service
The Service provided by this Website as described in the terms (if available) used on this website/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document extends to all current member states of the European Union and of the European Economic Area.
Cookies
Cookies are Trackers that consist of small portions of data stored in the User's browser.
Tracker
The term "Tracker" refers to any technology - e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - which allows Users to be tracked, for example by collecting or saving information on the User's device.
Legal references
This privacy policy has been drawn up based on multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to this Website.
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