Cookie Policy

This document contains information about the technologies that allow this Website to achieve the purposes described below. These technologies allow the Owner 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 simplicity, in this document these technologies are briefly defined as "Tracking Tools", 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 Tracking Tools that require the presence of a browser. For this reason, within this document the term Cookie is used only to specifically indicate that particular type of Tracking Tool.

Some of the purposes for which Tracking Tools are used may also 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 Tracking Tools managed directly by the Owner (commonly called "first-party" Tracking Tools) and Tracking Tools that enable services provided by third parties (commonly called "third-party" Tracking Tools). Unless otherwise specified within this document, these third parties have access to their respective Tracking Tools.

Duration and expiry of Cookies and other similar Tracking Tools may vary depending on what is set by the Owner or by each third party supplier. Some of them expire at the end of the User's browsing session. In addition to what is specified in the description of each of the categories below, Users can obtain more detailed and updated information on the duration, as well as any other relevant information – such as the presence of other Tracking Tools – in the privacy policies of the respective third-party suppliers (via the links made available) or by contacting the Owner.

This Website uses Cookies commonly called "technical" or other similar Tracking Tools to carry out activities strictly necessary to guarantee the functioning or provision of the Service.

Payment Management

Unless otherwise specified, this Website processes all payments by credit card, wire transfer or other means through external payment service providers. In general, and unless otherwise indicated, Users are asked to provide payment details and personal information directly to such payment service providers. This Website is not involved in the collection and processing of such information: instead it will only receive a notification from the payment service provider in question that the payment has been made.

Stripe (Stripe Technology Europe Ltd)

Stripe is a payment service provided by Stripe Technology Europe Ltd.

Personal Data processed: surname, purchase history, email, billing address, payment information, name, Tracking Tool and various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Storage duration:

• __Host-LinkSession: 2 years
• __stripe_mid: 1 year
• __stripe_sid: 30 minutes
• dashboard.banner-dismissals: session duration
• link.auth_session_client_secret: session duration
• m: 2 years
• pay_sid: 1 year

Klarna (Klarna AB)

Klarna is a payment service provided by Klarna AB.

Personal Data processed: surname, email, billing address, payment information, name, telephone number, Tracking Tool and various types of Data as specified in the privacy policy of the service.

Place of processing: Sweden – Privacy Policy.

Tag Management

This type of service is functional to the centralized management of tags or scripts used on this Website. The use of these services involves the flow of User Data through them and, if applicable, their retention.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: Ireland – Privacy Policy.

SPAM Protection

This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited. Use of the reCAPTCHA system is subject to Google's privacy policy and terms of use. To understand Google's use of data, please review Google's partner policies.

Personal Data processed: clicks, Usage Data, keypress events, motion sensor events, touch events, mouse movements, scrolling position, question responses and Tracking Tool.

Place of processing: Ireland – Privacy Policy.

Storage duration:

• _GRECAPTCHA: session duration
• rc::a: indefinite
• rc::b: session duration
• rc::c: session duration

Traffic Optimization and Distribution

This type of service allows this Website to distribute its contents via servers located throughout the territory and to optimize its performance. The Personal Data processed depends on the characteristics and implementation methods of these services, which by their nature filter communications between this Website and the User's browser. Given the distributed nature of this system, it is difficult to determine the locations to which content, which may contain the User's Personal Data, is transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The Cloudflare integration methods provide that it filters all the traffic of this Website, i.e. the communications between this Website and the User's browser, also allowing the collection of statistical data on it.

Personal Data processed: Tracking Tool and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Functionality

This Website uses Tracking Tools to allow simple interactions and activate features that allow Users to access certain resources of the Service and simplify communication with the Owner.

Registration and Authentication

By registering or authenticating, the User allows this Website to identify him and give him access to dedicated services. Depending on what is indicated below, registration and authentication services may be provided with the help of third parties. If this happens, this Website may access some Data stored by the third-party service used for registration or identification. Some of the services indicated below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Facebook OAuth (Facebook Ireland Ltd)

Facebook OAuth is a registration and authentication service provided by Facebook Ireland Ltd and connected to the Facebook network.

Personal Data processed: Tracking Tool and various types of Data.

Place of processing: Ireland – Privacy Policy.

Storage duration:

• _fbp: 3 months

Direct Registration

It allows the User to access content reserved for members and Edusogno services. It requires you to enter your first name, last name, date of birth, curriculum vitae, mobile number, email address and other personal information.

Experience

This Website uses Tracking Tools to improve the quality of the user experience and allow interactions with external content, networks and platforms.

Viewing Content from External Platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

Wistia Widget (Wistia, Inc.)

Wistia is a video content viewing service managed by Wistia, Inc. which allows this Website to integrate such content within its pages.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: United States – Privacy Policy.

This Website uses Tracking Tools to measure traffic and analyze User behavior to improve the Service.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User's behavior.

Google Analytics (Universal Analytics) (Google Ireland Limited)

Google Analytics (Universal Analytics) is a web analytics service provided by Google Ireland Limited ("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 Personal Data to contextualize and personalize the ads of its advertising network. To understand Google's use of data, please review Google's partner policies.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: Ireland – Privacy Policy – Opt Out.

Storage duration:

• AMP_TOKEN: 1 hour
• _ga: 2 years
• _gac*: 3 months
• _gat: 1 minute
• _gid: 1 day

Google Analytics Demographics and Interest Reporting (Google Ireland Limited)

Google Analytics Demographics and Interest Reporting is an advertising reporting feature that makes Demographic and Interest Data available within Google Analytics for this Website (Demographic Data means age and gender Data). Users can choose not to use Google cookies by visiting the Ads settings by Google.

Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example) and Tracking Tool.

Place of processing: Ireland – Privacy Policy – Opt Out.

Storage duration:

• IDE: 2 years
• _gcl*: 3 months
• test_cookie: 15 minutes

This Website uses Tracking Tools to provide personalized commercial content based on User behavior and to manage, disseminate and track advertisements.

User Database Management

This type of service allows the Owner to build user profiles starting from an email address, name or any other information that the User provides to this Website, as well as to track the User's activities through statistical functions. This Personal Data may also be cross-referenced with publicly available information about the User (such as profiles on social networks) and used to build private profiles that the Owner can view and use to improve this Website. Some of these services may also allow the scheduled sending of messages to the User, such as emails based on specific actions performed on this Website.

ActiveCampaign (ActiveCampaign, Inc.)

ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.

Personal Data processed: email, Tracking Tools and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Storage duration:

• ac_enable_tracking: 1 month

Advertising

Some of the services indicated below may use Tracking Tools to identify the User, or use the behavioral retargeting technique, i.e. display personalized advertisements based on the User's interests and behavior, or measure the performance of the advertisements. For more information on this matter, we suggest you check the privacy policies of the respective services. Generally, services of this type offer the possibility of deactivating such tracking. In addition to any opt-out feature provided by any of the services listed in this document, you can read more about how to opt-out of interest-based advertising in the "How to opt-out of interest-based advertising" section in this document.

Meta Ads Conversion Tracking (Meta Pixel) (Meta Platforms Ireland Limited)

Meta ads conversion tracking (Meta pixel) is a statistics service provided by Meta Platforms Ireland Limited that connects data from the Meta advertising network with actions performed within this Website. The Meta pixel monitors conversions that can be attributed to Facebook, Instagram and Audience Network ads.

Personal Data processed: Usage Data and Tracking Tools.

Place of processing: Ireland – Privacy Policy – Opt out.

Storage duration:

• _fbp: 3 months
• fr: 3 months

Remarketing and Behavioral Targeting

This type of service allows this Website and its partners to communicate, optimize and serve advertisements based on the User's past use of this Website. This activity is facilitated by tracking Usage Data and the use of Tracking Tools to collect information which is then transferred to partners who manage remarketing and behavioral targeting activities. Some services offer a remarketing option based on email lists. In addition to the opt-out features offered by the services listed below, the User can opt-out by visiting the Network Advertising Initiative opt-out page.

Users may also choose not to participate in certain advertising features through corresponding device setup options, such as mobile device advertising setup options or general advertising setup.

Facebook Remarketing (Facebook Ireland Ltd)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of this Website with the Facebook advertising network.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: Ireland – Privacy Policy – Opt Out.

Storage duration:

• _fbp: 3 months

If the use of Trackers is based on consent, the User can provide or withdraw such consent by setting or updating their preferences through the relevant privacy choices panel available on this Website.

With regards to third-party Tracking Tools, Users can manage their preferences by visiting the relevant opt-out link (if available), using the tools described in the third party's privacy policy or by contacting the latter directly.

Users can use their browser settings to:

• See which Cookies or other similar technologies have been set on your device;
• Block Cookies or similar technologies;
• Delete Cookies or similar technologies from your browser.

Your browser settings, however, do not allow granular control of consent by category.

Users can, for example, 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 deactivating them through the appropriate device settings, such as mobile advertising settings or settings related to tracking in general (Users can consult their device settings to find the relevant one).

Without prejudice to the foregoing, Users are informed of the possibility of using the information on YourOnlineChoices (EU and UK), 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 Owner, therefore, advises Users to use these resources in addition to the information provided in this document.

The Digital Advertising Alliance also provides an application called AppChoices that helps Users control behavioral advertising on mobile applications.

Users are free to decide whether or not to allow the use of Tracking Tools. However, please note that Tracking Tools allow this Website to provide Users with a better experience and enhanced functionality (in line with the purposes outlined in this document). Therefore, if the User decides to block the use of Tracking Tools, the Owner may not be able to provide the related functions.

Edusogno s.r.l.

Via Caldera 21, Milan (MI), Italy

DPO: Domenico Campanaro, President of Edusogno s.r.l.

Owner's email address: [email protected]

Call Recording

By providing your telephone contact, you agree to receive recorded telephone calls in order to optimize the quality of the service. These recordings will be treated in accordance with this privacy policy and will be used solely for internal training and service improvement purposes.

Since the use of third-party Trackers on this Website cannot be completely controlled by the Owner, any specific reference to third-party Trackers is to be considered indicative. To obtain complete 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 Owner if they wish to receive further information regarding the use of such technologies on this Website.

Personal Data (or Data)
Any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data
This is 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 the User who connects to this Website, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, 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 temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User's IT environment.

User
The individual who uses this Website who, unless otherwise specified, coincides with the interested party.

Interested Party
The natural person to whom the Personal Data refers.

Data Processor (or Manager)
The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including security measures relating to the operation 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 defined in the relevant terms (if available) on this site/application.

European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to include all current member states of the European Union and the European Economic Area.

Cookie
Cookies are Tracking Tools that consist of small portions of data stored within the User's browser.

Tracking Tool
Tracking Tool means any technology – e.g. Cookies, unique identifiers, web beacons, integrated 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
Unless otherwise specified, this privacy policy applies exclusively to this Website.