Cookie Policy

A. Who are we and what information do we provide?

We are Magellano Tech srl and for years we have placed the protection of the personal data of our current and prospective clients at the centre of our attention. We are committed to ensuring that all handling of personal data complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the processing of personal data.

Definition of Personal Data: By personal data, we mean any information relating to an identifiable individual, whether directly or indirectly. This includes name, identification numbers, location data, online identifiers and other characteristics specific to the individual.

What is meant by “Processing” of Data? This refers to any operation performed on personal data, such as collection, recording, storage, alteration, consultation, use, sharing and erasure, among others.

Before handling such data, it is essential that you, as a user or visitor of our website or mobile app, are informed about why we collect this information and how we will use it.

This document aims to provide you with clear and understandable information on the use and management of your personal data, in particular data collected through cookies on our website.

We have developed a detailed Cookie Policy based on the principle of transparency and in line with Article 13 of the Regulation. This policy is divided into specific sections to make it easier to understand and to make reading smoother and more straightforward.

B. Definition and Function of Cookies

Cookies are pieces of code sent by a web server (for example, by a website) to the user’s internet browser and stored within it. Essentially, they are small text files that the websites visited transfer to the user’s device, where they are stored and then sent back to the same websites on subsequent visits. The standard configuration of most browsers allows cookies to be stored automatically on the user’s device.

Purposes and Types of Cookies:

Cookies are used for various purposes and can be classified into different categories:

1. Cookie Duration:
   • Session Cookies: These last for a single browser session and allow websites to link the user’s actions during that session. They are deleted when the browser session ends.
   • Persistent Cookies: These remain stored on the device across different browser sessions, for varying periods of time, and retain the user’s preferences for a specific website.
2. Nature of Cookies:
   • Technical Cookies: Used solely to transmit communications over an electronic network or, where strictly necessary, to provide a service requested by the user. They do not require prior consent if managed directly by the website.
   • Profiling Cookies: These create user profiles and are used to send advertising messages based on the user’s preferences while browsing. Due to their potential invasiveness, the user must be adequately informed and give their explicit consent.
3. Origin of Cookies:
   • First-Party Cookies: Set and managed directly by the operator of the website visited.
   • Third-Party Cookies: Set by domains other than the website visited. The obligation to provide information and the means to give consent or block them lies with the third party. The website operator is required to provide a link to the third party’s website for further details and information.

For each category, it is essential that users are properly informed and, where necessary, give their consent to the use of cookies. Users may withdraw or change their consent at any time.

C. Technologies Similar to Cookies in Mobile Applications

The Data Controller, the Joint Controllers and third parties may use, especially in mobile applications, technologies that work in a similar way to Cookies, with the aim of storing and retrieving information relating to the device and its use. These technologies include:

1. Pixel Tags or Web Beacons: These are small graphic files, often measuring 1 pixel x 1 pixel, embedded in a web page or mobile application. In combination with a Cookie, they make it possible to collect information on how a specific page or application is used. This technology is employed for various purposes, such as analysing the use of websites or applications and personalising content and advertising.
2. Mobile Device Identifiers and SDKs: Mobile SDKs are the counterpart of pixel tags or web beacons for mobile applications. These snippets of code, embedded by developers in applications, enable the display of advertisements, the collection of data and the provision of related services. Among other things, they are used to show targeted advertising and features through mobile applications.

Some third parties using SDKs may not request the user’s consent and may, even without the knowledge of the Data Controller or the Joint Controllers, carry out additional tracking of the user. We therefore recommend consulting the privacy policies of the services listed below to obtain complete information and decide whether to give or refuse consent.

• Google AdSense or Google Ad Manager: Provides personalised advertising to users and supports other third parties with similar services. It uses identifiers to deliver ads based on user behaviour.
• Google Analytics GA4: Collects statistics on website use to better understand customers’ interests and behaviour. Google Analytics Privacy Policy
• ComScore: Collects statistics on website use to better understand customers’ interests and behaviour. Comscore Privacy Policy.
• Nielsen Measurement: Collects statistics on application use to better understand customers’ interests and behaviour. Nielsen Privacy Policy.
• Push Notifications: When using the Mobile App, you can choose to receive push notifications on your device. These can be disabled at any time through the device or application settings.

Users are invited to review their preferences and adjust their settings according to their needs, taking care to consult the detailed information provided for each service mentioned.

D. Who Will Manage Your Personal Data?

Your personal data will be managed in accordance with the provisions of data protection legislation. As set out in Article 4(7) of the Regulation, which defines the “controller” as “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”, the controller of your personal data is:

Magellano Tech srl

• Registered Office: Via dei Due Macelli 60, 00187 – Roma
• Registered with the Companies Register of: Rome
• Tax Code and VAT No.: 16801361003

Magellano Tech srl will therefore be responsible for deciding the means and purposes of the processing of your personal data and must ensure that such processing respects your rights and the applicable data protection legislation.

E. Who Can You Contact?

If you have any questions or concerns about the processing of your personal data, or if you wish to exercise your rights in relation to your data, you can contact the Data Controller and/or the Joint Controllers through various channels:

1. By Post:
   By addressing your communication to the Privacy Office of Magellano Tech srl
   Via dei Due Macelli, 60
   00187 Roma.
2. By Email:
   By sending an email to: amministrazione@magellanotech.it,
   stating that it is intended for the Privacy Office of Magellano Tech srl
3. By Phone:
   By calling +39 06 2440 5925
   and asking to speak to the Privacy Office.

The European General Data Protection Regulation introduced the role of the “data protection officer”, commonly known as the Data Protection Officer (DPO), who serves as a point of reference for data protection matters.

Magellano Tech srl has designated a DPO responsible for:

• Informing and advising on compliance with data protection legislation.
• Monitoring compliance with data-related laws and internal policies.
• Acting as the main point of contact for individuals regarding the processing of their data.
• Cooperating with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali).

You can contact the DPO of Magellano Tech srl via:

1. Email: info@magellanotech.it
2. Post:
   By addressing your communication to:
   Magellano Tech srl
   Via dei Due Macelli, 60
   00187 Roma.

It is important for you to know that you have the right to receive prompt and clear answers to your questions and requests concerning the protection of your personal data.

F. For What Purposes Will Your Personal Data Be Processed and Which Cookies Will Be Used?

Your personal data will be processed for various reasons, in connection with the cookies installed through the website. The categories of cookies used and their purposes are listed below:

1. Technical Cookies: These are essential for the website to function and to optimise the user’s browsing experience. They can be divided into:
   • Browsing Cookies: These cookies store browsing preferences and optimise the user’s browsing experience.
   • Analytics Cookies: These collect aggregated information on how users browse in order to analyse the use of the website. Some of these may belong to third parties.
   • Functionality Cookies: These are used to enable specific website features, improving the quality of the service offered. Some of these may belong to third parties.

   Since these cookies are essential for the website to function, the user’s prior consent is not required for their installation. Their use is based on the legitimate interest of the Data Controller and the Joint Controllers.

2. Profiling Cookies: These cookies are used to create user profiles in order to send advertising messages in line with the preferences expressed while browsing. The user’s consent is required to use these cookies. The legal basis for their use is the consent given by the user.

It is important to note that, while some services using cookies may not require the user’s consent, there are third parties that may use additional tracking mechanisms, even without the knowledge of the Data Controller or the Joint Controllers. We therefore recommend consulting the privacy policies of these third parties to fully understand their practices and how to refuse consent.

In general, it is always good practice to be aware of and informed about the cookies and privacy policies of the websites you visit.

Advertising

These services allow User Data to be used for the purpose of delivering commercial communications. Such communications are displayed within this Application in the form of advertising banners and other promotional formats, linked, where possible, to the User’s interests.

Please note that not all Personal Data collected is used for these purposes. Details of the Data and the conditions of use are set out in the following paragraphs.

Some of the services mentioned may use Tracking Tools to recognise the User, or may adopt behavioural retargeting techniques. The latter aims to display advertisements tailored to the User’s interests and behaviour, including those observed outside this Application. For further details, please consult the privacy policies of the services concerned.

In general, services of this kind offer the option to opt out of tracking. In addition to the opt-out options provided by the services mentioned in this document, the User is invited to consult the section “How to opt out of interest-based advertising” for further guidance.

Adasta (Adasta Media Advertising)
Adasta is an advertising service provided by Adasta Media Advertising srl
Personal Data processed: Cookies and Usage Data.

Place of processing: Italy – Privacy Policy.

Ad+ (AdPlus)
Ad+ is an advertising service provided by AdPlus
Personal Data processed: Cookies and Usage Data.

Place of processing: Canada – Privacy Policy.

AdKaora (AdKaora Srl)
AdKaora is an advertising service provided by AdKaora srl
Personal Data processed: Cookies and Usage Data.

Place of processing: Italy – Privacy Policy.

Amazon Mobile Ads (Amazon)
Amazon Mobile Ads is an advertising service provided by Amazon.
Personal Data processed: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Criteo (Criteo SA)
Criteo is an advertising service provided by Criteo SA.
Personal Data processed: Cookies and Usage Data.

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

Google Ad Manager

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google AdSense (Google Ireland Limited)
Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the “DoubleClick” Cookie, which tracks the use of this Application and the User’s behaviour in relation to the advertisements, products and services offered.
Users may decide at any time to disable all DoubleClick cookies by going to: Ad Settings. To understand how Google uses data, please consult Google’s partner policy.
Personal Data processed: Cookies and Usage Data.

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

Epeex (Mgid Ltd)
Epeex is an advertising service provided by Mgid ltd.
Personal Data processed: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

Liquid (Sky Media)
Liquid is an advertising service provided by Sky Media
Personal Data processed: Cookies and Usage Data.

Place of processing: United Kingdom – Privacy Policy – Opt out.

Nativery (Nativery srl)
Nativery is an advertising service provided by Nativery srl.
Personal Data processed: Cookies and Usage Data.

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

Ogury (Ogury Ltd)
Ogury is an advertising service provided by Ogury Ltd.
Personal Data processed: Cookies and Usage Data.

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

Outbrain (Outbrain Inc.)
Outbrain is an advertising service provided by Outbrain Inc.
Personal Data processed: Cookies and various types of Data as specified in the service’s privacy policy.

Place of processing: United States – Privacy Policy – Opt Out.

PubMatic (PubMatic, Inc.)
PubMatic is an advertising service provided by PubMatic, Inc.
Personal Data processed: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Rubicon Project (The Rubicon Project, Inc.)
Rubicon Project is an advertising service provided by The Rubicon Project, Inc.
Personal Data processed: Cookies and Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

SeedTag (Seedtag Advertising SL)
SeedTag is an advertising service provided by Seedtag Advertising SL
Personal Data processed: Cookies and Usage Data.

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

Teads (Teads SA)
Teads is an advertising service provided by Teads SA.
Personal Data processed: Cookies and Usage Data.

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

Vidoomy (Vidoomy Media SL)
Vidoomy is an advertising service provided by Vidoomy Media sl.
Personal Data processed: Cookies and Usage Data.

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

Viralize (ShowHeroes a socio Unico srl)
Viralize is an advertising service provided by ShowHeroes a socio Unico srl
Personal Data processed: Cookies and Usage Data.

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

Backend Hosting Services

Hosting and backend infrastructure services are essential to ensure the optimal functioning of this Application. They host the Data and files required for this Application to run, facilitate their distribution and provide ready-to-use infrastructure to implement specific features of this Application.

Please note that some of the services mentioned may operate on geographically distributed servers. This may make it difficult to determine the exact location where Personal Data is stored.

OVH Cloud
OVH is a hosting service provided by OVH Hosting
Personal Data processed: Cookies and Usage Data.

Place of processing: Canada – Privacy Policy.

Contabo GmbH
Contabo is a hosting service provided by Contabo GmbH
Personal Data processed: Cookies and Usage Data.

Place of processing: Germany – Privacy Policy.

Ionos Group SE
Ionos is a hosting service provided by Ionos Group SE
Personal Data processed: Cookies and Usage Data.

Place of processing: Germany – Privacy Policy.

Analytics

The services described in this section enable the Data Controller to monitor and analyse traffic data and to track User behaviour.

ComScore Analytics (ComScore, Inc.) ComScore is an analytics service provided by ComScore, Inc. Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Google Analytics (Google Ireland Limited) Google Analytics, provided by Google Ireland Limited, is a web analytics tool. Google uses the Personal Data collected to track and examine the use of this Application, compile reports and share them with other services developed by Google. Google may also use this Personal Data to contextualise and personalise the ads of its own advertising network. Personal Data collected: Cookies and Usage Data.

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

Displaying Content from External Platforms

These services make it possible to view content hosted on third-party platforms directly within the pages of this Application and to interact with such content. Please note that these services may collect traffic data relating to the pages on which they are installed, even if users do not actually use them.

Vimeo Video (Vimeo, LLC) Vimeo is a video content display service provided by Vimeo, LLC that allows this Application to embed videos directly in its pages. Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Google Maps Widget (Google Ireland Limited) Google Maps is a map display service provided by Google Ireland Limited that allows this Application to integrate maps into its pages. Personal Data collected: Cookies and Usage Data.

Place of processing: Ireland – Privacy Policy.

Instagram Widget (Meta Platforms, Inc.) Instagram, operated by Meta Platforms, Inc., is an image display service that allows this Application to integrate such visual content into its pages. Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Spotify Widget (Spotify AB) Spotify, provided by Spotify AB, is an audio content streaming service that allows this Application to embed audio tracks directly in its pages. Personal Data collected: Cookies and Usage Data.

Place of processing: Sweden – Privacy Policy.

YouTube Video Widget (Google Ireland Limited) YouTube, operated by Google Ireland Limited, is a video content display service that allows this Application to embed videos directly in its pages. Personal Data collected: Cookies and Usage Data.

Place of processing: Ireland – Privacy Policy.

G. How Can I Control the Installation of Cookies?

Managing and controlling cookies is essential to protecting your privacy online. Here is how you can do it:

1. Browser Settings: Most browsers offer options to manage, view and delete the cookies stored on your device. Here is how to access the cookie settings in some of the most popular browsers:
   • Google Chrome
   • Mozilla Firefox
   • Apple Safari
   • Microsoft Windows Explorer
2. Third-Party Tools: If you wish to object to tracking by third-party services, in addition to your browser settings, you can consult the third party’s privacy policy and use any opt-out options provided.
3. Read the Privacy Policy: If you have doubts or questions about how a third party may use cookies, we recommend reading its privacy policy.
4. Contact Us: If you have specific questions about the use of cookies on this website, or if you would like further information not covered by this Cookie Policy, you can contact us using the details provided in Section I.

Please remember that disabling cookies completely may impair some features of the website. It is therefore advisable to choose your settings and desired tracking levels carefully.

H. How Long Will Your Personal Data Be Processed?

The retention period for personal data is closely linked to the purpose for which it was collected. The guiding principle is that personal data must not be kept for longer than is necessary to achieve the purposes for which it was collected.

The General Data Protection Regulation (GDPR) clearly states that data must be “kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed”.

However, there are exceptions to this principle. For example, data may be stored for longer periods if it is processed solely for:

• Archiving purposes in the public interest.
• Scientific or historical research.
• Statistical purposes.

Even in these cases, however, appropriate measures are required to protect the rights and freedoms of data subjects, as provided for by the GDPR.

In practical terms, this means that the Data Controller will retain your personal data only for as long as strictly necessary. If the processing of data is based on your consent, for example for marketing or profiling purposes, the data will be retained until you decide to withdraw that consent.

It is always good practice for users to regularly consult the privacy and cookie policies of the websites they visit and to make informed decisions about the retention and use of their personal data.

I. How to Withdraw Your Consent:

1. Advertising Preferences Panel: Many websites offer an advertising preferences panel in which you can manage and withdraw your consent to specific types of data processing, such as interest-based advertising.
2. Direct Contact: You can contact the Data Controller, the Joint Controllers, or any third parties with whom you have previously shared your data directly. When contacting these entities, you will need to clearly state that you are withdrawing your consent to the processing of your personal data.
3. Online Methods: Some websites may have online forms or specific sections dedicated to consent management. Visit the website’s privacy section to check whether such options are available.
4. Email: Many marketing emails include an “unsubscribe” or “update your preferences” link. By using these links, you can often withdraw your consent to specific communications.

Once you have withdrawn your consent, the entity should no longer process your personal data for the purposes to which you previously consented. However, withdrawing consent does not affect the lawfulness of any processing carried out before the withdrawal. If you believe that your rights have not been respected, you also have the right to lodge a complaint with the competent supervisory authority in your country.

The text above sets out in detail the rights of individuals in relation to the processing of their personal data under the European Union’s General Data Protection Regulation (GDPR).

In summary, these are the main rights identified:

1. Right of access: You can request information on the processing of your personal data, its purposes, the categories of data processed, the recipients of the data and other related information.
2. Right to rectification: You have the right to correct or complete inaccurate or incomplete personal data.
3. Right to erasure (“right to be forgotten”): You can request the erasure of your personal data in certain circumstances.
4. Right to restriction of processing: In some situations, you can request that the processing of your personal data be restricted.
5. Right to data portability: You have the right to receive your personal data in a standard format and to transfer it to another controller.
6. Right to object: You can object to the processing of your personal data for certain purposes, such as direct marketing.

Finally, it is important to note that you also have the right to lodge a complaint with a supervisory authority, such as the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), if you believe that your rights have been infringed.

To exercise these rights, you can contact the Data Controller or the Joint Controllers using the methods set out in a specific section (Section E) of this Notice. Reference is also made to a DPO (Data Protection Officer) and to the importance of contacting this figure for further information or clarification.

The Data Controller is not responsible for updating all the links shown in this notice; therefore, whenever a link is not working and/or up to date, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by that link.