This policy explains how CLeM Consulting srl, collects and processes personal data through the cookies used on this website https://www.clemconsultingsrl.com/ and to provide information as to the choices that any user of the Website can make in terms of controlling what cookies are installed when he/she accesses and browses the Website. Please note that this policy uses the term ‘cookies’ also to refer to similar technologies covered by the law (such as, for example, Local Shared Objects – commonly referred to as “flash cookies”, web beacons or bugs, including transparent clear gifs, etc.). The information gathered by means of such tools constitute data that, in certain cases, may allow the Company to identify the Users by associating such data with other information kept by third parties (such as, for example, the IP address, DNS and registration numbers of the computers used by people connecting to the Website). These data are used and processed only for statistical purposes. This document shall form, according to the applicable data protection legislation, including Regulation (EU) 2016/679 (the “GDPR”), an integral and substantial part of the Company’s Privacy Policy. We strongly recommend, therefore, to read such document as well.

What is a cookie

Cookies are small text files sent from the site to the interested party’s terminal (usually to the browser), where they are stored before being re-transmitted to the site at the next visit by the same user. A cookie cannot retrieve any other data from the user’s hard drive or transmit computer viruses or acquire email addresses. Each cookie is unique to the user’s web browser. Some of the functions of cookies can be delegated to other technologies. In this document, the term ‘cookie’ refers to both cookies, proper, and all similar technologies. Using cookies, it is possible to record information relating to your preferences, such as the pages you browse or download files from our site or other similar actions performed by browsing our site Using such technologies is not, therefore, prohibited by the law but they do require that people are properly informed about how they operate and the consequences deriving from their use, so to have the choice to refuse them, if feasible.

Different types of cookies

• Technical cookies: are used to browse or provide a service requested by the user. They are not used for other purposes and are normally installed directly by the owner or manager of the website. They can be divided into:
• Navigation or session cookies, which guarantee normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas); they are in fact necessary for the proper functioning of the site;
• Analytical cookies, similar to technical cookies when used directly by the site manager to collect information, in aggregate and anonymous form, on the number of users and how they visit the site, in order to improve the performance of the site;
• Functionality cookies, which allow the user to browse according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided. For the installation of these cookies, the prior consent of users is not required (more information in the paragraph on Managing cookies below).
• First and third-party cookies – Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user (the website displayed in the URL window), i.e. cookies set by https://www.clemconsultingsrl.com/. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits the Website and a separate company sets a cookie through it, this would be a third-party cookie.

Consent about cookies – Some cookies are strictly necessary for the correct functioning of Internet and the Website and do not require User’s consent, such as those ensuring that the content of a page loads quickly and effectively by distributing the workload across numerous computers or else those providing security. Other cookies are still reasonably necessary or important but they are not strictly essential and, therefore, require User’s consent.User’s consent is collected through different techniques implemented on this Website. One mechanism is the click of the specific box on the cookie banner highlighting the use of cookies and published on the landing page. Your consent to the use of cookies can be withdrawn any time even though the withdrawal of consent might have impacts on the functionality of the website.

Disabling and deleting Cookies – Most web browsers and devices are set to accept cookies by default. If the User prefers, he/she can usually choose to disable cookies by updating the browser or device settings to remove or reject cookies (e.g. cookies may be disabled by following the instructions provided by browser, which are usually located within the “Help,” “Preferences” or “Settings” menus). In case the User wishes to delete any cookies that are already on his/her device, reference should be made to the help, support, history or tools area on the Internet browser for instructions on how to do so. Please be aware that choosing to remove or reject cookies, or limiting the use of other similar technologies, could affect the access to the Website or its functionalities. To find out more about cookies, please see http://www.youronlinechoices.eu or www.allaboutcookies.org, both of which contain further information about cookies, how they work and the choices that can be made by the User.

Management of third part cookies – This site also acts as an intermediary for third-party cookies, used to provide additional services and features to visitors and to improve the use of the site, such as buttons for social media, or videos. This site has no control over third party cookies, entirely managed by third parties. As a result, the information on the use of these cookies and their purposes, as well as on the methods for disabling them, are provided directly by third parties. You can disable cookies on websites by downloading special software such as Ghostery (https://www.ghostery.com) for your browser and disabling the use of individual cookies. Or you can activate the “anonymous browsing” mode – this is a function that allows you to browse without leaving a trace in the browser of your browsing data. This function only allows you not to keep browsing data in the browser. Alternatively, you can disable / delete cookies by accessing the configuration panel of your browser. Instructions for disabling cookies through the browser can be found on the following web pages: Mozilla Firefox – Microsoft Internet Explorer – Microsoft Edge – Google Chrome – Opera – Apple Safari (if the technologies used by the site are compatible with the version of the browser used by the user, the publisher can set up a direct connection with the dedicated browser section settings themselves). In particular, this site uses analytical cookies from the following third parties:

Google Analytics – a Google analysis tool which, through the use of cookies (performance cookies), collects anonymous navigation data (IP truncated at the last octet) and exclusively aggregated for the purpose of examining the use of the site by users, compiling reports on the activities on the site and provide other information, including the number of visitors and the pages visited. Google may also transfer this information to third parties where this is required by law or where such third parties process the aforementioned information on behalf of Google. Google will not associate the IP address with any other data held by Google. The data transmitted to Google are stored on Google’s servers in the United States. On the basis of a specific agreement with Google, which is designated as the data processor, the latter undertakes to process the data based on the requests of the Data Controller (see at the bottom of the information), given through the software settings. Based on these settings, the advertising and data sharing options are disabled. Further information on Google Analytics cookies can be found on the Google Analytics Cookie Usage on Websites page. The user can selectively disable the collection of data by Google Analytics by installing the appropriate component provided by Google on their browser (opt out).

Plugin Social Network – This site also incorporates plugins and / or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when accessing the page, to safeguard user privacy. Eventually, cookies are set, if so provided by social networks, only when the user makes effective and voluntary use of the plugin. Please note that if the user browses while logged into the social network then he has already consented to the use of cookies conveyed through this site at the time of registration to the social network. The collection and use of information obtained through the plugin are governed by the respective privacy policies of the social networks, to which please refer.

Data retention – Personal data collected through the cookies will be kept in a format that allows User’s identification for no longer than 7 (seven) days, or in any case, within the time limits set forth by applicable laws and regulations, especially in connection with the need of checking computer crimes damaging the Website and/or to enforce or protect the Company’s rights (consistent with the retention periods and statutes of limitations provided for by the law), where necessary. When no longer necessary in accordance with the above, the data will be cancelled or anonymized.

Circulation of data – No information gathered on the Website by means of cookies will ever be either communicated or disseminated to unspecified recipients.

Data controller – The Data controller is CLeM Consulting Srl, a company duly incorporated under Italian law, with head office at Via del Campo 24/A, 20874, Busnago (MB), Italy. The Company shall be liable only for its own cookies, i.e. first-party cookies, while third-party cookies shall fall under the controllership of the related companies.

Policy updating – This cookie policy may be updated periodically, so the User is recommended to consult it each time he/she accesses the Website, in order to be properly informed about how and why the Company uses cookies.