Privacy Policy

Introduction

Sottile Alessandro ("we," "us," or "our") is committed to protecting the privacy and personal data of every individual who visits our website or participates in our coaching education programs. This Privacy Policy describes how we collect, process, store, share, and safeguard your information in connection with our website and services.

Sottile Alessandro is located at Via Giuseppe Codara, 1, 20144 Milano, Italy. You may contact us at any time regarding privacy matters by sending an email to [email protected].

By using our website, you acknowledge that you have read and understood this Privacy Policy. We encourage you to review this document regularly, as it may be updated from time to time. Changes will be notified via a homepage banner at least 14 days before taking effect.

What Data We Collect

We may collect and process the following categories of personal data when you visit our website, complete a form, or interact with our content:

• Full name
• Email address
• Phone number
• IP address
• Browser type and version
• Device type and operating system
• Cookies and tracking identifiers
• Usage data (pages visited, time on site, click paths)
• Form submission content (messages, program selections, preferred contact method)
• Conversion events (form submissions, calls, page interactions)

Cookie Categories

We categorize cookies used on this website into three tiers. Only essential cookies are activated by default. Analytics and marketing cookies are activated solely after you provide explicit consent.

Marketing Cookies: Detailed Disclosures

Consent

By clicking "Accept All Cookies," 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 offers three options: "Accept All," "Reject Non-Essential," and "Manage Preferences." The banner does not block content and can be dismissed without accepting, in which case only essential cookies remain active. Your cookie consent choice is stored in your browser's localStorage for 12 months.

EEA and UK Users

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.

Withdrawal of Consent

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.

Legal Basis for Processing (GDPR Art. 6)

We process personal data on the following legal bases, depending on the data type and purpose:

• Contact form data: Consent (Art. 6.1.a) and, where a service relationship exists, performance of a contract (Art. 6.1.b).
• Analytics data: Consent (Art. 6.1.a).
• Marketing and remarketing data: Consent (Art. 6.1.a).
• Security and fraud prevention: Legitimate interest (Art. 6.1.f).

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, remarketing lists. Governed by Google's Privacy Policy: https://policies.google.com/privacy
• Meta Platforms, Inc.: Pixel events, conversion data, custom audiences. Governed by Meta's Data Policy: https://www.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.

Lead Forms and Contact Requests

When you submit a contact form, request information about a program, or register interest in our services, we collect the information you provide. This typically includes: full name, email address, phone number, selected program, preferred contact method, and your message.

Legal basis: Consent (GDPR Art. 6.1.a) and, where a service relationship exists, performance of a contract (GDPR Art. 6.1.b).

Retention: Form submission data is retained for up to 2 years from the date of submission, unless a longer period is required by applicable law.

You may request deletion of your data at any time by contacting us at [email protected].

A link to this Privacy Policy appears adjacent to every submission button on this site. Submitting a form constitutes acknowledgment of this policy.

Google Services and Advertising

This website uses the following Google services:

• Google Analytics 4: Collects anonymized usage data, device info, and behavioral signals. IP anonymization is enabled. Data retention is set to 14 months. Users may opt out via the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout
• Google Ads Conversion Tracking: Records when a user completes a defined action (such as a form submission) after clicking one of our ads. This data is used solely for measuring ad campaign performance.
• Google Remarketing: Allows us to show ads to previous visitors across Google's network. Remarketing lists are not created from sensitive data categories (health, finance, religion, sexual orientation).
• Google Tag Manager: Deploys tracking tags on our behalf. No personal data is collected by GTM itself; it acts as a container for the tags listed above.

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

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)
• 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: https://www.facebook.com/privacy/policy

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

Retention Periods

We retain personal data only for as long as necessary for the purposes described in this policy. Specific retention periods by category:

Your Rights (GDPR Articles 15-22)

If you are located in the European Economic Area, the United Kingdom, or Italy, you have the following rights regarding your personal data:

• Access (Art. 15): Request a copy of the data we hold about you.
• Rectification (Art. 16): Correct inaccurate or incomplete data.
• Erasure (Art. 17): Request deletion of your data ("right to be forgotten").
• Restriction (Art. 18): Limit how we process your data.
• Portability (Art. 20): Receive your data in a structured, machine-readable format.
• Objection (Art. 21): Object to processing based on legitimate interest.
• Withdraw consent (Art. 7.3): Revoke consent at any time without penalty.

To exercise any of these rights, email us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with your local supervisory authority:

• Italy (Garante per la protezione dei dati personali): https://www.garanteprivacy.it
• EU users: https://edpb.europa.eu
• UK users: https://ico.org.uk

International Data Transfers

Personal data collected through 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].

Children's Privacy

This website is not directed at individuals under the age of 16. We do not knowingly collect personal data from minors. If we discover that data has been collected from a person under 16 without verifiable parental consent, we will delete it promptly. Contact us at [email protected] if you believe we have received data from a minor.

Prohibited Content Self-Declaration

This website does not promote, sell, or facilitate access to prohibited product or service categories including but not limited to: weapons, controlled substances, counterfeit goods, gambling services (unlicensed), adult content, or services that make misleading health or financial claims. All advertising conducted through Google Ads and Meta Ads complies with the respective platform policies in full.

Landing Page Integrity Statement

The content of this website accurately represents the products and services advertised. No bait-and-switch practices are employed. The experience delivered to users arriving from paid advertisements is identical to the experience for all other visitors. Cloaking, automatic redirects, and content variation by traffic source are not used on this website.

Third-Party Links

This website may contain links to external websites operated by third parties, such as Google, Meta, or industry organizations. We are not responsible for the privacy practices or content of those external sites. We recommend reviewing the privacy policies of any third-party website you visit.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include HTTPS encryption across all pages, secure form processing with server-side validation, and regular security reviews. While we take every reasonable precaution, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute data security.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify users via a prominent banner on our homepage at least 14 days before the changes take effect. The "Last Updated" date at the top of this page indicates when this policy was most recently revised. We encourage you to review this policy periodically.

Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us: