Cookie Policy

Dear Visitor/Visitor (hereinafter, "You" or the "User"),

This Internet site (www.foolfarm.com; hereinafter, "Site") is owned by the company FoolFarm S.p.A. with registered office in Milan - Via Paolo Da Cannobio, No. 2, Tax Code/VAT No. 11331520962 and registration number with the Companies' Register of Milan MI2595513 (hereinafter, "We" or the "Company").

Since so-called cookies are used on our Site for different purposes, we want to explain with this policy what cookies are and how they are used on the Site. 

Some cookies (so-called own or first-party cookies) are conveyed and controlled directly by Us. Through these cookies, the Company collects and processes certain personal data about you. In this information notice, pursuant to Article 13 of the EU Regulation 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data (hereinafter, "Regulation") and Legislative Decree 196/2003 (hereinafter, "Privacy Code" and, together with the Regulation, "Applicable Legislation"), we explain how we collect this data, for what purposes and what your rights are.

Other cookies (so-called third-party cookies), are, however, conveyed and controlled by third parties, as will be better discussed below. On this notice you will find links to the notices published by these third parties, which please read carefully.

If you are not familiar with cookies, please read this policy and the Site's general privacy policy carefully so that you can be aware of your choices.

The Company takes into the utmost consideration the right to privacy and protection of personal data of its Users. For any information related to this cookie policy, Users may contact the Company at any time using the following methods:

• By sending a registered letter with return receipt to the Company's registered office in Milan, 20122, Via Paolo da Cannobio No. 2; 
• By sending an e-mail message to: 

You may also contact the Company's Data Protection Officer (DPO or DPO), whose contact information is below: e-mail address dpo@foolfarm.com.

1. What cookies are and what they are used for

Cookies are small text files that sites visited by the user send directly to the user's terminal (usually to the browser), where they are stored in order to be then retransmitted to the same sites on the next visit of the same user (so-called first-party own cookies). In the course of browsing a site, the user may also receive cookies from different sites or web servers on his terminal (so-called third-party cookies); this happens because on the website visited there may be 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, they are those cookies that are set by a website other than the one you are currently visiting.

Cookies can have a lifetime limited to a single browser session (so-called session cookies), and in that case they are automatically deactivated when the user closes the browser; or they can have a predetermined expiration date, and in that case, they will remain stored and active on your hard disk until that expiration date, continuing to collect information over the course of different browser sessions (so-called persistent cookies). 

Cookies are used for different functions. Some are necessary to enable you to browse the Site and take advantage of its features (so-called technical cookies). Others are used to obtain statistical information, in aggregate or otherwise, about the number of users accessing the Site and how the Site is being used (so-called tracking or analytics cookies ). Finally, others are used to draw a consumer profile of you and display advertisements on the Site that may be of interest to you, as they are consistent with your tastes and consumption habits (so-called profiling cookies).

To learn about these different categories of cookies in more detail, continue reading this policy. Learn how they work and what they are used for, and freely choose whether to consent to their use or prevent it. 

2. The technical tools 

1. Technical cookies

Technical cookies are used on the Site for the sole purpose of making it possible for you to navigate the Site and allow you to use its features. These are always first-party cookies, as they are directly conveyed by Us on the Site. 

Some technical cookies are essential to provide you with an optimal browsing experience or to allow you to authenticate yourself on the site, for example to make a purchase on the Site or enter your private area (so-called navigation cookies). Browsing cookies are normally session cookies and, therefore, once you close your browsing browser, they are deactivated automatically. 

Other technical cookies are useful to allow you to store some of your preferences (for example, your language or country of origin) without having to reset them during subsequent visits (so-called functionality cookies). For this reason, functionality cookies are often persistent cookies, in that they remain stored on your computer even after you close your browsing browser, until the expiration date set for them or until you have decided to delete them.

2. Saving User Preferences

As per the Applicable Regulations, your prior consent is not required for the installation of technical cookies, mentioned in paragraph B.1 above. You are, of course, free to block the installation of technical cookies by changing your browser settings (read paragraph E, no. 1 to learn how). Bear in mind, however, that by blocking the installation of technical cookies, or subsequently deleting them, your ability to access the Site, to use all or part of it, to enable or disable certain functions or to receive certain services may be wholly or partially impaired. 

3. Tracking or "analytics" cookies 

Analytics cookies are used on the Site to collect statistical information, in aggregate or otherwise, about the number of users accessing the Site and how they visit the Site. 

Third-party analytics cookies are installed on the Site only with your prior consent:

Cookie	Cookie category	Link to disclosure / Instructions on opt-out
Google Ireland Limited's "Google Analytics" service (hereinafter referred to as "Google Analytics" and "Google," respectively).	- analytics cookie - permanent - collected data owned by the Company- duration [...].	https://policies.google.com/privacy (information page) https://tools.google.com/dlpage/gaoptout?hl=it (opt-out): Google supports an optional browser add-on that, once installed and activated, disables measurement by Google Analytics for any site a user visits. Keep in mind that this add-on only disables measurement by Google Analytics.
[...]	[...]	[...]

You are, of course, free to withhold consent for the installation of analytics cookies as well as to object to their use at any time, without your ability to visit the Site and enjoy its content being impaired in any way. To find out how to do this, carefully read the third-party cookie policies by following the links in the table above. 

4. Profiling cookies 

Profiling cookies are used to create a profile of you as a user, based on the preferences and tastes you have expressed while browsing the Internet, and to make you display advertisements consistent with your profile. This allows the advertisements you display on our Site to be more interesting to you. 

You are, of course, free to withhold consent for the installation of profiling cookies as well as to object to their use at any time, without your ability to visit the Site and enjoy its content being impaired in any way. If you decide to disable behavioral advertising, it does not mean that you will no longer receive advertising on the Site. However, the banners you display on the Site may not reflect your interests or preferences on the browser you are currently using.

1. First-party profiling cookies

Some of the profiling cookies are either installed directly by the Company or are tools through which the Company collects data as a data controller or, in some cases, joint data controller together with the provider of such cookies (as specifically indicated by the provider of the cookie within the privacy policy set out in the table in this paragraph D.1).

Below is a list of the first-party profiling cookies used on the Site, including more details with respect to each one as well as the ways in which you can object to their installation: 

Cookie Name	Cookie category	More information - Opt-out
Google Ireland Limited's "Ad Manager 360" service (hereinafter referred to as "AdServer" and "Google," respectively).	- first-party-permanent profiling cookies	Google's AdServer profiling cookie allows the Company to collect data as a "data controller." Moreover, for the AdServer service offered by Google to the Company and used by the Company, Google declares itself to be the autonomous "data controller" of Users' personal data. Therefore, for the collection of data and for the processing resulting from the use of the Adserver, the Company has no control or power over the processing carried out by Google, as it is a mere user of the service (which is technically managed by Google).Users can object with respect to the use of the AdServer's profiling cookies, through the following link: https://adssettings.google.com/.For information about whether Google transfers Users' personal data abroad or the retention period of data processed in the context of the use of the AdServer, Users may refer to Google's privacy policy https://policies.google.com/privacy and/or the following link: https://support.google.com/admanager/answer/2839090?hl=en

The Company also informs Users that through the Google AdServer used by the Company may be enabled the use by advertisers or other third parties of cookies linked to advertising messages in order to collect information about the User's browsing activities. 

5. How to manage cookies and oppose their use

There are several options to manage, disable and delete cookies. 

1. Change your browser settings

Follow the instructions provided by the manufacturer of the browser you use to find out how to manage, disable, or delete all cookies:

• Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies 
• Chrome: https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies 
• Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie 
• Safari: https://support.apple.com/it-it/guide/safari/manage-cookies-and-website-data-sfri11471/ 
• Opera: https://help.opera.com/en/latest/web-preferences/

Make your choices carefully. By indiscriminately blocking the receipt of all cookies, including technical cookies, without providing a specific exception for the Site, you may, in fact, no longer be able to browse the Site or take advantage of some or all of its features. In addition, by deleting all cookies from your browser, technical cookies may also be removed and, therefore, you may be able to remove preferences you have set using the Site.

2. Use interactive tools provided by third parties

To disable first-party profiling cookies, i.e., those installed directly by Us, you can simply use the interactive button(s) highlighted in Section D of this policy. Your choice to object to the use of these cookies will have no effect on your ability to browse the Site and use its features, and can be revoked by you at any time anyway by using the same interactive button. 

To disable third-party cookies, please consult the information pages of third parties that install analytics cookies (see paragraph C above) or profiling cookies (see paragraph D above) to learn about the tools available to you to manage, disable and delete cookies and, more generally, to object to their use. Remember that by disabling third-party cookies, (i) you object to their use not only on the Site but on all Internet sites on which such cookies are used and (ii) your ability to browse the Site and use its features will not be affected in any way. 

3. Use the Internet site www.youronlinechoices.eu/it/

Your Online Choices is a website operated by the non-profit association European Interactive Digital Advertising Alliance (EDAA), the Italian version of which can be reached at www.youronlinechoices.eu/it/, which provides information on behavioral advertising based on profiling cookies(http://www.youronlinechoices.com/it/a-proposito) and allows Internet users to easily oppose (opt-out) the installation of the main profiling cookies installed by advertisers and used on Internet sites(http://www.youronlinechoices.com/it/le-tue-scelte). Before using this tool, we recommend that you carefully read the Your Online Choices Terms of Service(http://www.youronlinechoices.com/it/condizioni-generali-di-servizio), Frequently Asked Questions (FAQ)(http://www.youronlinechoices.com/it/faqs), and User Guide(http://www.youronlinechoices.com/it/help). 

Consciously use Your Online Choices. Although, in fact, Your Online Choices brings together many of the world's leading advertising companies that use cookies, some of the third parties that install cookies through the Site may not have joined Your Online Choices. Therefore, using Your Online Choices does not guarantee that you will receive third-party cookies by browsing the Site. Remember, too, that if you delete all cookies from your browser, the technical cookies issued by Your Online Choices to remember your choices may also be deleted, making the third-party cookies active again. 

6. Method of processing and data retention time

As highlighted in the preamble of this policy, it is possible that the Company collects and processes some of your personal data through cookies that it conveys directly on the Site or cookies conveyed by third parties acting on behalf of the Company on the basis of a specific act of appointment as data controller under Article 28 of the Regulations(first-party cookies). The Company acts as the controller of this data, in accordance with the provisions of the Applicable Regulations. We will process your data only by electronic means, in a fully automated manner and without human intermediation. Therefore, our employees will never access the content of your personal data obtained through cookies, which means that they will never be able to access and/or have PII(Personally Identifiable Information), that is, information from which you can be directly identified. 

Some of our employees and/or collaborators, appointed by Us as data processors in accordance with Article 29 of the Regulations, may carry out maintenance work on the computer systems that house your data, without ever being able to access their actual content. 

Personal data may be stored in servers operated by third parties (e.g., computer system providers) or may be managed by parties specializing in online advertising, who act as data controllers, pursuant to Article 28 of the Regulations, on the basis of an appropriate appointment in writing by the Company. 

Your personal information will not be disclosed to third party data controllers or disseminated.

Your personal data, collected by the Company by means of the technical cookies referred to in paragraph B above, will be retained for as long as is strictly necessary to fulfill the primary purposes outlined in this policy, or otherwise as necessary to protect the rights of both Users' and the Company's interests.

Regarding, however, the duration of the cookies themselves, including third-party cookies, and the retention times of the data collected by the third parties, please refer to the tables included in this policy.

7. Transfers of personal data to a third country

Please note that, subject to the conditions and safeguards set out in the Regulations, your data may be transferred to countries outside the European Economic Area (so-called EEA). Such countries may not offer a level of privacy and personal data protection comparable to that guaranteed by the Applicable Regulations; where the Company will act as data controller we will take data security into the utmost consideration and, therefore, we will proceed in handling such transfers with all due care and guarantees in accordance with the Applicable Regulations and, in particular, in accordance with Articles 45(Transfer on the basis of an adequacy decision) and 46(Transfer subject to adequate safeguards) of the Regulations. 

Specifically, for the provision of the Google Analytics service (referred to in paragraph C above), the Company's provider, Google Ireland Limited, may transfer pseudonymous personal data of Users of the Site outside the EEA, on the basis of the so-called. Standard Contractual Clauses and, in particular, to the United States, taking additional measures for this purpose to ensure that the transfer takes place in accordance with the Regulation itself. More information about the additional security measures applied by Google Ireland Limited for transfers of personal data outside the European Union can be found within the following resources made available by the provider itself: "Regarding international data transfers in Google Analytics" (referred to at the link: https://support.google.com/analytics/answer/11609059) and "Safeguards for international data transfers with Google's advertising and analytics products" (referred to at the link: https://services.google.com/fh/files/misc/safeguards_for_international_data_transfers.pdf). In view 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 considered the additional security measures that the provider guarantees to take to protect the personal data processed on behalf of the Company to be appropriate.

Please note that some of the third parties listed in the tables in this policy may - as autonomous data controllers - process personal data collected by means of the cookies installed on this Site from a location outside the European territory and, therefore, you are advised to carefully read their disclosures above for more details on this matter.

8. Your Rights

To exercise your rights, or obtain any further information or clarification in relation to this cookie policy, please contact the Company by the following means:

• By sending a registered letter with return receipt to the Company's registered office in Milan, Via Paolo da Cannobio no. 2; 
• By sending an e-mail message to: 

You may also contact the Company's Data Protection Officer (DPO or DPO), whose contact information is below: e-mail address dpo@foolfarm.com.

Pursuant to the Applicable Regulations, Users have:

1. The right to withdraw consent at any time if the processing is based on their consent;
2. The right of access to personal data;
3. (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used, machine-readable format), the right to restriction of processing of personal data, the right to rectification, and the right to erasure ("right to be forgotten");
4. the right to object:
   1. in whole or in part, for legitimate reasons to the processing of personal data concerning them, even if relevant to the purpose of collection;
   2. in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
5. should they believe that the processing that concerns them violates the Regulation, theright to lodge a complaint with a Supervisory Authority (in the Member State in which they habitually reside, in the Member State in which they work, or in the Member State in which the alleged violation occurred). The Italian Supervisory Authority is the Garante per la protezione dei dati personali, based in Piazza Venezia, n. 11, 00186 - Rome (RM)(http://www.garanteprivacy.it/).

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The Company is not responsible for updating all links displayed in this cookie policy; therefore, whenever a link is not working and/or updated, Users acknowledge and agree that they should always refer to the document and/or section of the websites referred to by that link.