COOKIE POLICY

WHO WE ARE AND HOW TO CONTACT US

This section contains information on who we are, how to contact us for any need, and the main contents of this policy (what data we collect, why we use it, how long we keep it and what rights you can exercise).

This website (https://conversion-m.com; hereinafter, “Website”) is owned by Conversion Media S.r.l., with registered office at Via Bagutta, n. 13, Milan – 20121 (Italy), VAT no. 10430480961 (hereinafter, the “Company”).

Since cookies and/or other similar tracking tools (e.g. pixels, tags, etc.) are used on the Website for various purposes, with this cookie policy (hereinafter, “Policy”), pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter, “Regulation”) and art. 122 of Legislative Decree 196/2003 (hereinafter, “Privacy Code” and, together with the Regulation, “Applicable Law”), we explain what cookies are and how they are used on the Website, how we collect data referring to the users who browse the Website (hereinafter, “Users”) and for which purposes they are collected.

Some tracking tools (so-called first-party) are conveyed and controlled directly by the Company (or by parties acting on behalf of the Company): through these tools, certain personal data concerning the User are collected and processed by the Company. Other tracking tools (so-called third-party) are instead conveyed and controlled by parties other than the Company, as better explained below: this Policy therefore contains links to the policies published by these third parties.

Users are informed that this Website, as well as the services offered by the Controller, are intended for persons who have reached eighteen years of age. The Company therefore does not intentionally collect personal data relating to persons under 18 years of age. Upon request, the Company will promptly delete all personal data inadvertently collected relating to persons under 18 years of age.

The Company attaches the utmost importance to the right to the protection of the personal data of Users who, for any information regarding this Policy or for the exercise of the rights guaranteed to them by law, may contact the Company at any time: (i) by sending a registered letter with return receipt to the registered office of the Company; or (ii) by sending an email to: [email protected].

Users may also contact the Data Protection Officer (DPO) of the Company, Shibumi S.r.l., in the person of Lapo Curini Galletti, reachable at the following email address: [email protected].

WHAT COOKIES ARE AND WHAT THEY ARE FOR

This section briefly explains what cookies are and what their purposes of use may be.

Cookies are small text files that the sites visited send directly to the terminal used to access the site (usually to the browser), where they are stored to be then retransmitted to the same sites on the user's next visit (so-called first-party cookies). While browsing a website, the user may also receive on their terminal cookies from sites or web servers other than the one being visited (so-called third-party cookies); this happens because the visited website may contain elements such as, for example, images, maps, sounds, specific links to web pages of other domains that reside on servers other than the one on which the requested page is located. In other words, these are cookies set by a website other than the one currently being visited.

Cookies may have a duration limited to a single browsing session on the browser (so-called session cookies) and, in this case, they are automatically deactivated when the browser is closed; or they may have a predetermined expiry and, in this case, they will remain stored and active until that expiry date, continuing to collect information during different browsing sessions on the browser (so-called permanent cookies).

Cookies are used for various functions. Some are necessary to allow the User to browse the Website and use its functionalities (so-called technical cookies). The other tracking tools, which do not have merely technical purposes, are commonly referred to as profiling cookies. Among these, however, we can distinguish those used to obtain statistical information, in aggregate form or not, on the number of Users who access the Website and on how the Website is used (so-called analytics cookies) and others that are, finally, used to track a consumer profile and show the User advertisements on the Website that may be of interest to them, as they are consistent with their tastes and consumption habits (so-called profiling cookies).

TECHNICAL TRACKING TOOLS

In this section, we explain how technical tracking tools are used on the Website.

Technical tracking tools are used on the Website to allow safe, fast and efficient exploration of the Website and to provide Users with the requested services (so-called navigation cookies). Navigation cookies are normally session cookies and, therefore, once the browser is closed, they are automatically deactivated.

Other technical tracking tools are useful to allow the User to store some of their preferences (for example, the language or country of origin) without having to reset them during subsequent visits (so-called functionality cookies). For this reason, functionality tracking tools are often persistent, as they remain stored on the User's device even after the browser is closed, until their expiry date or until the User decides to delete them.

The following technical cookies are currently used on the Website:

Furthermore, as provided by Applicable Law, prior consent of the User is not required for the installation of the tools referred to in this section. Of course, the User is free to block the installation of these tools by changing the browser settings. However, it is hereby noted that, by blocking the installation of technical cookies or, subsequently, deleting them, the possibility of accessing the Website, using it in whole or in part, enabling or disabling certain functions or receiving certain services may be wholly or partly compromised.

On the contrary, prior consent of the User is required for the installation of cookies and/or other tracking tools that do not have a technical purpose. For this reason, when accessing the Website, a dedicated banner is prominently displayed (also called Consent Management Platform; hereinafter, “CMP”) which informs the User that, subject to consent, cookies that do not have a technical purpose are used on the Website and that by pressing the dedicated button provided therein, consent to the use of cookies can be given.

Should the User express their consent to the installation of tracking tools in this way, the Company will keep track of the consent given through a dedicated technical cookie or through other technical methods related to the use of the CMP, which allow the documentation of the User's choices to always be kept up to date and to transmit these updated choices also to all third parties that convey cookies and/or other tracking tools on the Website. The Company may therefore process, for this purpose, metadata relating to the granular choices made by the User, which constitute personal data as they are attributable to the User accessing the Website: such metadata includes any expression of consent, the detail of the granular purposes for which the User has given consent, as well as any choice of the user to continue browsing while maintaining the default settings by pressing the relevant button provided by the CMP.

Once a preference is expressed by the User, the Company will keep track of the choices made, in line with what is required by Applicable Law, and will not display the CMP to the User again during subsequent visits to the Website. Should the Company use a technical cookie or other methods to demonstrate that consent has been obtained, and the User deletes this technical cookie or other tool used for this purpose from the browser, the trace of the preferences given may be lost and, therefore, during your subsequent visit to the Website the CMP may be displayed again.

NON-TECHNICAL TRACKING TOOLS

In this section, we explain how tracking tools that do not have a merely technical purpose are used on the Website, distinguishing between those used by us and those used by third parties.

Tracking tools that do not have a technical purpose are used on the Website to:

• collect statistical information, in aggregate form or not, on the number of Users who access the Website and on how they visit the Website (analytics cookies);
• create a profile of the User, based on the preferences and tastes expressed by them while browsing the Internet, and show them advertising messages consistent with their profile. In this way, the advertising messages that they will see on the Website may be of greater interest to them (profiling cookies).

Of course, the User is free not to give consent for the installation of tracking tools that do not have a technical purpose, as well as to object to their use at any time, without the possibility of visiting the Website and enjoying its contents being in any way compromised. If the User decides to deactivate behavioural advertising, it does not mean that they will no longer receive advertising on the Website: the banners they will see on the Website may not reflect their interests or preferences on the browser they are currently using.

FIRST-PARTY TRACKING TOOLS

Some of the tracking tools that do not have a technical purpose are installed directly by the Company or are tools through which the Company collects information and personal data as data controller or, in some cases, joint controller together with the provider of such tracking tools (as specifically indicated by the provider within the privacy policy reported in the table in this section).

Below is the list of first-party tracking tools, not having a technical purpose, used on the Website, with details on each of them as well as the methods by which it is possible to object to their use:

THIRD-PARTY TRACKING TOOLS

On the Website, some tracking tools that do not have a technical purpose are installed by third parties (third-party cookies). In the following table you can find the list of third-party tracking tools that do not have a technical purpose currently used on the Website, with an indication of the link to the information pages created by their developers (also containing information on the methods to object to their installation, so-called opt-out, and on the related retention periods):

HOW TO MANAGE TRACKING TOOLS AND OBJECT TO THEIR USE

This section explains the different ways to manage cookies and/or other tracking tools.

There are several options for managing, disabling and deleting cookies. You can change the browser settings, following the instructions provided by the manufacturer of the browser used by the User: Edge; Chrome; Firefox; Safari; Opera.

Users are informed that, by indiscriminately blocking the receipt of all cookies, including technical ones, without providing a specific exception for the Website, they may no longer be able to browse the Website or use its functionalities in whole or in part. Furthermore, by deleting all cookies from the browser, technical cookies may also be removed and, therefore, the User may remove the preferences set using the Website.

To manage, disable and delete the tracking tools used on the Website, it is also possible to use the interactive tools provided in the tables above or the website of Your Online Choices. This is a tool managed by the non-profit association EDAA, which provides information based on profiling cookies and allows Internet users to easily object (opt-out) to the installation of the main profiling cookies installed by advertising operators and used on websites. Before using this tool, we recommend that you carefully read the relevant information, the frequently asked questions and the related conditions.

Users are informed that, although Your Online Choices brings together many of the most important companies in the advertising world that use cookies, some of the third parties that install tracking tools through the Website may not have joined Your Online Choices. Therefore, the use of Your Online Choices does not guarantee that third-party tracking tools will not be received while browsing the Website. Furthermore, by deleting all cookies from your browser, the technical cookies released by Your Online Choices to remember the choices may also be deleted, making third-party cookies active again.

Finally, it is always possible to use the CMP implemented on the Website to give or withdraw consent by following the relevant instructions.

PROCESSING METHODS AND DATA RETENTION PERIODS

This section explains how we process the data and how long we keep it.

As highlighted in the introduction to this policy, it is possible that the Company collects and processes some of your personal data through the tracking tools that it conveys directly on the Website or that are conveyed by parties distinct from the Company that nevertheless act on behalf of the Company, on the basis of a specific deed of appointment as data processor pursuant to art. 28 of the Regulation (first-party cookies). With respect to the data collected through these tools, the Company acts as data controller and will process the data collected only with electronic tools, in a fully automated manner and without human intervention.

The personal data collected by the Company through the tracking tools referred to above will be kept for the time strictly necessary to fulfil the primary purposes illustrated in this Policy or, in any case, as necessary for the protection of the rights of both the interests and the Users and the Company.

As regards, instead, the duration of the tools indicated above and the retention periods of the data collected by third parties, we ask the User to refer to the policies indicated in the tables included in this Policy.

SCOPE OF DATA COMMUNICATION AND TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

This section explains to whom the data may be communicated (internal and external parties, partners, suppliers, etc.) and whether they are transferred outside the European Union, and with what guarantees.

The personal data of Data Subjects may be accessed by:

• the directors, employees and/or collaborators of the Controller, who may carry out maintenance work on the IT systems that host the personal data collected. These parties, who have been instructed accordingly by the Controller pursuant to art. 29 of the Regulation, will process the data of Data Subjects exclusively for the purposes indicated in this Policy and in compliance with the provisions of the law;
• parties external to the Controller's organization, other than those indicated above, who may process personal data on behalf of the Controller as data processors pursuant to art. 28 of the Regulation, such as, by way of example, providers of servers and IT systems, parties specialized in online advertising or measurement, etc., acting as data processors pursuant to art. 28 of the Regulation;
• competent public Authorities.

The User's personal data may be transferred outside the European Union to be stored on the servers of the providers of the services used on the Website and/or of the technological services entrusted by the Controller to third parties, in accordance with arts. 45 (Transfers on the basis of an adequacy decision) and 46 (Transfers subject to appropriate safeguards) of the Regulation. Where the Company acts as data controller, in the latter case, this will be done through the signing of the appropriate Standard Contractual Clauses and verification of the security measures applied by the providers to protect the personal data entrusted to them.

Specifically, for the provision of the Google Analytics service (referred to in the paragraph “FIRST-PARTY TRACKING TOOLS”), the Company's provider, Google Ireland Limited, may transfer the pseudonymous personal data of the Website Users outside the EEA, on the basis of the so-called Standard Contractual Clauses or an Adequacy Decision: in particular, towards the United States, the data will be transferred on the basis of the certification adopted by Google LLC (further information is provided by Google at the following link). In consideration of the scope of the processing, the nature of the data processed and the risks of the processing carried out by the provider, the Company has deemed suitable the additional security measures that the provider guarantees to adopt to protect the personal data processed on behalf of the Company.

It should be noted that some of the third parties indicated in the tables in this Policy and/or in the CMP may – as autonomous controllers of the data collected through third-party cookies – collect, through tracking tools installed on this Website, personal data relating to the User from a location situated outside European territory and, therefore, it is recommended to carefully read their policies reported above for further details.

RIGHTS OF USERS

This section provides a clear summary of data protection rights: access, rectification, erasure, restriction, objection, portability, withdrawal of consent and the right to lodge a complaint with the Italian Data Protection Authority.

Users may exercise the rights guaranteed to them by Applicable Law through the contacts indicated above.

In particular, pursuant to Applicable Law, Users are informed that they have:

• the right to withdraw consent at any time, where the processing is based on their consent, without affecting the lawfulness of the processing based on consent before withdrawal. To withdraw the consent given for the use of cookies and/or other tracking tools that do not have a technical purpose, it is possible to use the CMP by following the relevant instructions;
• the right of access to personal data;
• the right to data portability;
• where one of the cases provided for by law applies, the right to restriction of the processing of personal data;
• the right to rectification (to obtain from the Company the rectification of inaccurate personal data concerning the User);
• the right to the integration of incomplete personal data (also by providing a supplementary declaration);
• the right to the erasure of personal data concerning them where one of the reasons provided for by law applies;
• the right to object to the processing of personal data for direct marketing purposes including profiling to the extent that it is related to such direct marketing;
• where they consider that the processing concerning them infringes the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State where they habitually reside, where they work or where the alleged infringement occurred). The Italian supervisory authority is the Garante per la protezione dei dati personali, with offices at Piazza Venezia, n. 11, 00187 - Rome (RM). The list of the other supervisory authorities of the other Member States can be found on the website of the European Data Protection Board.

UPDATING THE POLICY AND LINKS

This Policy – v. no. 1 of 19/06/2026 – may be subject to changes in the future, for example due to the entry into force of new personal data protection legislation, clarifications or indications provided by the Italian Data Protection Authority or other competent bodies, or decisions of the Controller. We therefore invite the User to consult it periodically: in any case, the purposes for which the data are processed will never be changed without first informing the User and, when required by law, obtaining their consent.

The Company is not responsible for updating all the links displayed in this Policy; therefore, whenever a link is not working and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referenced by such link.