Cookie Policy

1. What Are Cookies?

Cookies are small text files that are placed on your computer, smartphone, or other device when you visit a website. They are widely used to make websites work more efficiently, provide a better browsing experience, and supply information to the owners of the site.

Cookies can be "first-party" cookies (set directly by the website you are visiting) or "third-party" cookies (set by a domain other than the website you are visiting). Cookies can also be "session" cookies (which expire when you close your browser) or "persistent" cookies (which remain on your device for a set period or until you delete them).

This Cookie Policy applies to the website operated by Sottile Alessandro, located at Via Giuseppe Codara, 1, 20144 Milano, Italy. For questions about this policy, you may contact us at [email protected].

2. How We Use Cookies

We use cookies and similar tracking technologies on our website for several purposes, including ensuring the site functions properly, understanding how visitors interact with our content, measuring the effectiveness of our educational programs marketing, and delivering relevant advertisements to individuals who have previously visited our website.

We categorize cookies into three distinct groups based on their purpose. The details of each category, including the specific cookies used and their retention periods, are described below.

3. Cookie Categories

4. How to Manage Your Cookie Preferences

You have several options for managing cookies on our website and across the internet:

5. Opt-Out from Personalized Advertising

You may opt out of personalized advertising at any time through the following platforms:

• Google Ads Settings: adssettings.google.com
• Your Online Choices (EU): youronlinechoices.eu
• Network Advertising Initiative: optout.networkadvertising.org
• Digital Advertising Alliance: optout.aboutads.info
• Meta Ad Preferences: facebook.com/adpreferences

Opting out does not remove ads entirely. You will continue to see non-personalized advertisements. Opting out means that the ads you see may be less relevant to your interests.

6. Your Consent

By clicking "Accept All Cookies" on our consent banner, you consent to the storing of cookies on your device for analytics and advertising purposes, including personalized advertising delivered by Google and Meta. You may withdraw consent at any time through the cookie preferences panel without affecting the lawfulness of processing that occurred before withdrawal.

Our cookie consent banner provides three options:

• Accept All: Enables essential, analytics, and marketing cookies.
• Reject Non-Essential: Enables only essential cookies. No analytics or marketing cookies will be placed.
• Manage Preferences: Opens a panel where you can toggle analytics and marketing cookies individually.

Your consent choice is stored in your browser's local storage for 12 months. After this period, you will be asked to confirm your preferences again.

7. GDPR and Privacy Compliance

Users in the European Economic Area and the United Kingdom receive this consent notice in compliance with the General Data Protection Regulation (GDPR) and UK GDPR. Marketing and analytics cookies are activated solely after explicit, informed, freely given consent under GDPR Article 6(1)(a). Consent is recorded with a timestamp and may be audited upon request.

You may withdraw consent at any time by clicking "Manage Cookie Preferences" in the website footer, or by clearing cookies via your browser settings. Withdrawal does not affect processing that occurred while consent was valid.

As Sottile Alessandro is based in Italy, this Cookie Policy also complies with Italian data protection regulations, including the provisions of the Italian Data Protection Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018) and the guidelines issued by the Italian Data Protection Authority (Garante per la protezione dei dati personali) regarding cookies and other tracking tools.

8. Data Sharing with Advertising Partners

We share certain data with advertising partners for campaign delivery and measurement. Recipients and the data categories shared include:

• Google LLC: Cookie identifiers, conversion events, anonymized behavioral data, and remarketing lists. Governed by Google's Privacy Policy: policies.google.com/privacy
• Meta Platforms, Inc.: Pixel events, conversion data, and custom audiences. Governed by Meta's Data Policy: facebook.com/privacy/policy

We do not sell personal data. All transfers to Google and Meta operate under Standard Contractual Clauses where applicable. Data is processed for ad targeting and campaign measurement only and is not resold to unaffiliated third parties.

Google and Meta may use this data across their own platforms in accordance with their respective policies. We encourage users to review those policies directly.

9. Google Services and Advertising

This website uses the following Google services:

Google's advertising products are governed by: policies.google.com/technologies/ads

10. Meta Advertising Services

This website uses the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram. The pixel may record:

• Page views and time on site
• Specific conversion events (form submissions, inquiries)
• Custom audience membership for retargeting purposes

We do not use the Meta Pixel to collect sensitive personal data, nor to target users based on health status, financial situation, religion, political views, sexual orientation, or any other special-category attribute prohibited under Meta's advertising policies.

Meta acts as an independent data controller for data collected via its Pixel and processed within its own platform. Refer to Meta's Data Policy: facebook.com/privacy/policy

To manage your ad preferences on Meta platforms, visit: facebook.com/adpreferences

11. International Data Transfers

Data collected through cookies on this website may be transferred to and processed in countries outside the European Economic Area, including the United States, where Google LLC and Meta Platforms, Inc. are based.

These transfers are conducted under Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for personal data. A copy of the applicable SCCs can be requested by contacting us directly at [email protected].

12. Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature that signals to websites that you do not want to have your online activity tracked. Because there is no universally accepted standard for how to respond to DNT signals, our website does not currently respond to DNT signals. Instead, we rely on our cookie consent mechanism described above to manage your preferences regarding tracking technologies.

13. Changes to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in the cookies we use, changes in applicable laws, or updates to our data practices. When we make changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify users via a banner on our homepage at least 14 days before the changes take effect.

We encourage you to review this Cookie Policy periodically to stay informed about how we use cookies.

14. Relationship with Our Privacy Policy

This Cookie Policy should be read together with our Privacy Policy, which provides comprehensive information about how we collect, use, store, and protect your personal data, including data collected through cookies.

For detailed information about your rights under GDPR, including your right to access, rectify, erase, restrict, or port your personal data, please refer to our Privacy Policy.

15. Contact Information

If you have any questions or concerns about this Cookie Policy or our use of cookies, please contact us: