Circularity Platform

Cookie Policy

This document contains information about the technologies that enable this platform to achieve the purposes described below. These technologies allow the Owner to collect and save information (for example through the use of Cookies) or to use resources (for example by running a script) on the User’s device when the latter interacts with this platform.

For simplicity, in this document these technologies are briefly defined as “Tracking Tools”, unless there is reason to differentiate.
For example, although Cookies can be used in both web and mobile browsers, it would be inappropriate to talk about Cookies in the context of applications for mobile devices, since these are Tracking Tools that require the presence of a browser. For this reason, within this document the term Cookie is used only to specifically indicate that particular type of Tracking Tool.

Some of the purposes for which Tracking Tools are used may also require the User’s consent. If consent is given, it can be freely revoked at any time by following the instructions contained in this document.

This Application uses Tracking Tools managed directly by the Owner (commonly called “first-party” Tracking Tools) and Tracking Tools that enable services provided by third parties (commonly called “third-party” Tracking Tools). Unless otherwise specified within this document, these third parties have access to their respective Tracking Tools.
Duration and expiry of Cookies and other similar Tracking Tools may vary depending on what is set by the Owner or by each third party supplier. Some of them expire at the end of the User’s browsing session.
In addition to what is specified in the description of each of the categories below, Users can obtain more detailed and updated information on the duration, as well as any other relevant information – such as the presence of other Tracking Tools – in the privacy policies of the respective third-party suppliers (via the links made available) or by contacting the Owner.

For further information regarding California consumers and their privacy rights, Users can consult the privacy policy.

Activities strictly necessary to guarantee the functioning of this Application and the provision of the Service

This Application uses Cookies commonly called “technical” or other similar Tracking Tools to carry out activities strictly necessary to guarantee the functioning or provision of the Service.

Third Party Tracking Tools

Tag management

This type of service is functional to the centralized management of tags or scripts used on this Application.
The use of these services involves the flow of User Data through them and, if applicable, their retention.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Usage Data and Tracking Tools.

Place of processing: Ireland – Privacy Policy.

SPAM protection

This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the processing of Data.
Use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.

Personal Data processed: clicks, usage data, keypress events, motion sensor events, touch events, mouse movements, scrolling position, responses to questions and Tracking Tools.

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

GRECAPTCHA: session duration
– rc::a: undefined
– rc::b: session duration
– rc::c: session duration

Other activities that involve the use of Tracking Tools

Simple interactions and functionality

This Application uses Tracking Tools to allow simple interactions and activate features that allow Users to access certain resources of the Service and simplify communication with the Owner.

User database management

This type of service allows the Owner to build user profiles starting from an email address, name or any other information that the User provides to this Application, as well as to track the User’s activities through statistical functions. This Personal Data may also be cross-referenced with publicly available information about the User (such as profiles on social networks) and used to build private profiles that the Owner can view and use to improve this Application.
Some of these services may also allow the scheduled sending of messages to the User, such as emails based on specific actions performed on this Application.

Pardot (Salesforce.com, inc.)

Pardot is a user database management service provided by Salesforce.com, inc. Pardot may use Tracking Tools to recognize Users and track their behavior, as well as to display personalized ads and content. Users can opt out of Oracle’s use of Tracking Tools for ad personalization by visiting the Salesforse Audience Studio opt-out page or by following the instructions provided by YourOnlineChoices and AdChoices.
Personal Data processed: Data communicated during use of the service, Usage data, email, device information and Tracking Tools.
Place of processing: United States – Privacy Policy – Opt out.

Salesforce Marketing Cloud (Salesforce.com, inc.)

Salesforce Marketing Cloud is a User database management service provided by salesforce.com, inc.
Personal Data processed: Tracking Tools.
Place of processing: United States – Privacy Policy.

Management of support and contact requests

This type of service allows this Application to manage support and contact requests received via email or through other tools, such as the contact form.
The Personal Data processed depends on the information provided by the User in the messages and on the tool used for communication (for example the email address).

Salesforce Service Cloud (Salesforce.com, inc.)

Salesforce Service Cloud is a contact and support request management service provided by salesforce.com, inc.
Personal Data processed: Data communicated during use of the service, Tracking Tools and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Improved experience

This Application uses Tracking Tools to provide a personalized user experience, allowing better management of personal settings and interaction with external networks and platforms.

Interaction with social networks and external platforms

This type of service allows you to interact with social networks, or other external platforms, directly from the pages of this Application.
The interactions and information acquired by this Application are in any case subject to the User’s privacy settings relating to each social network.
This type of service may still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out of the respective services to ensure that the data processed on this Application is not linked to the User’s profile.

Linkedin social button and widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are interaction services with the LinkedIn social network, provided by LinkedIn Corporation.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: United States – Privacy Policy.
Storage duration:

AnalyticsSyncHistory: 1 month
– JSESSIONID: session duration
– UserMatchHistory: 1 month
– cookie: 1 year
– bscookie: 1 year
– lang: duration of the session
– lidc: 1 day
– lissc: 1 year
– lms_ads: 1 month
– lms_analytics: 1 month

Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

Google Fonts

Google Fonts is a character style visualization service managed by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, which allows this Application to integrate such content within its pages.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Measurement

This Application uses Tracking Tools to measure traffic and analyze User behavior with the aim of improving the Service.

Management of data collection and online surveys

This type of service allows this Application to manage the creation, implementation, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse the Data of the Users who respond.
The Personal Data collected depends on the information requested and provided by Users in the corresponding online form.

These services can be integrated with a wide range of third-party services to allow the Owner to carry out subsequent actions with the processed Data – for example, contact management, sending messages, statistics, advertising and payment processing.

Typeform (TYPEFORM S.L)

Typeform is a form builder and data collection platform provided by TYPEFORM S.L.
Personal Data processed: Tracking Tools.
Place of processing: Spain – Privacy Policy.

Heat mapping and session recording

Heat mapping services are used to identify the areas of this Application with which Users interact most frequently, in order to detect which of them attract the most interest. These services allow you to monitor and analyze traffic data and serve to keep track of the User’s behavior.
Some of these services may record your sessions and make them available for you to view later.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User’s behavior.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its advertising network.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: Ireland – Privacy Policy – Opt Out.
Storage duration:

AMP_TOKEN: 1 hour
_ga: 2 years
_gac*: 3 months
_gat: 1 minute
_gid: 1 day

Google Analytics 4

Google Analytics is a statistics service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its advertising network.
In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To find out more, you can consult the official Google documentation.
Personal Data processed: Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Storage duration:

_ga: 2 years
_ga_*: 2 years

Google Analytics Demographics and Interest Reports

Google Analytics Demographics and Interest Reporting is an advertising reporting feature that makes Demographic and Interest Data available within Google Analytics for this Application (Demographic Data means age and gender Data) .
Users can choose not to use Google cookies by visiting Google’s Ad Settings.
Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example) and Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Storage duration:

FDI: 2 years

gcl*: 3 months
– test_cookie: 15 minutes

Facebook Ads Conversion Tracking (Facebook Pixel)

Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Data Controller manages the processing of Data, which connects data from the network Meta ads with actions performed within this Application. The Facebook pixel tracks conversions that can be attributed to Facebook, Instagram and Audience Network ads.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Storage duration:

fbp: 3 months
fr: 3 months

Meta Events Manager (Meta Platforms Ireland Limited)

Meta Events Manager is a statistics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can provide the Owner with information on traffic and interactions on this Application.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: Ireland – Privacy Policy.
Storage duration:

fbp: 3 months

Targeting and Advertising

This Application uses Tracking Tools to provide personalized commercial content based on User behavior and to manage, disseminate and track advertisements.

User database management

Pardot (Salesforce.com, inc.)

Advertising

This type of service allows the User’s Data to be used for commercial communication purposes. These communications are shown on this Application in the form of banners and other forms of advertising, also in relation to the User’s interests.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below.
Some of the services indicated below may use Tracking Tools to identify the User or use the behavioral retargeting technique, i.e. display personalized advertisements based on the User’s interests and behavior, also detected outside of this Application. For more information on this matter, we suggest you check the privacy policies of the respective services.
Generally, services of this type offer the possibility of deactivating such tracking. In addition to any opt-out feature provided by any of the services listed in this document, you can read more about how to opt-out of interest-based advertising in the “How to opt-out of interest-based advertising” section in this document.

Google Ads Lookalike Audiences

Similar Audience Segments is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, which uses Google Ads Remarketing Data to show advertisements to Users with behavioral similar to those of other Users who are already on the remarketing list due to their previous use of this Application.
Based on this Data, personalized ads will be shown to Users suggested by Google Ads Similar Audiences.

Users who do not want to be included in similar audiences can opt out and disable the use of Advertising Trackers by visiting: Google Ads Settings.
To understand Google’s use of Data, please review Google’s partner policies.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Storage duration:

AID: 2 years
ANID: 2 years
Conversion: 3 months
DSID: 14 days
FCNEC: 1 year
FLC: 10 seconds
FPAU: 3 months
FPGCLAW: 3 months
FPGCLDC: 3 months
FPGCLGB: 3 months
FDI: 2 years
NID: 6 months
RUL: 1 year
TAID: 14 days
_gads: 2 years __gsas: 2 years _gac: 3 months
gac_gb: 3 months
_gcl_au: 3 months
_gcl_aw: 3 months
_gcl_dc: 3 months
_gcl_gb: 3 months
_gcl_gf: 3 months
_gcl_ha: 3 months
id: 2 years
test_cookie: 15 minutes

LinkedIn Ads

LinkedIn Ads is an advertising service provided by LinkedIn Ireland Unlimited Company or by LinkedIn Corporation, depending on how the Data Controller manages the processing of Data.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: Ireland – Privacy Policy – Opt out; United States – Privacy Policy – Opt out.
Storage duration:

GAID: not defined
IDFA: Not defined
UserMatchHistory: 1 month
gcl*: 3 months
_guid: 3 months
aam_uuid: 1 month
li_fat_id: 1 month
li_giant: 7 days
li_sugr: 3 months
lms_ads: 1 month
oribi_cookie_test: session duration
oribi_session: 2 hours
oribi_user_guid: 7 months

Salesforce (Salesforce.com, inc.)

Salesforce is an advertising service provided by Salesforce.com, inc.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out.
Storage duration:

all_user_segments: undefined
cc: not defined
e_: not defined
fp: not defined
fp_id: undefined
fp_salt: undefined
geo: not defined
iab_cs: undefined
iab_gdpr: undefined
iab_two_cs: undefined
iab_two_gdpr: undefined
kuid: not defined
optout: undefined
org_user_id: undefined
rec: undefined
rt_: undefined
segs*: undefined
tech: not defined
tmp_trust_cookie_attempt: undefined
umr: not defined
user: undefined
user_segments: undefined

Remarketing and behavioral targeting

This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the User’s past use of this Application.
This activity is facilitated by tracking Usage Data and the use of Tracking Tools to collect information which is then transferred to partners who manage remarketing and behavioral targeting activities.
Some services offer a remarketing option based on email lists.
Generally, services of this type offer the possibility of deactivating such tracking. In addition to any opt-out feature provided by any of the services listed in this document, you can read more about how to opt-out of interest-based advertising in the “How to opt-out of interest-based advertising” section in this document.

Google Ads Remarketing (Google LLC)

Remarketing Google Ads is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
To understand Google’s use of Data, please review Google’s partner policies.
Users can opt out of using Google Tracking Tools for ad personalization by visiting Google’s Ad Settings.
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out.
Storage duration:

AID: 2 years
ANID: 2 years
Conversion: 3 months
DSID: 14 days
FCNEC: 1 year
FLC: 10 seconds
FPAU: 3 months
FPGCLAW: 3 months
FPGCLDC: 3 months
FPGCLGB: 3 months
FDI: 2 years
NID: 6 months
RUL: 1 year
TAID: 14 days
_gads: 2 years
__gsas: 2 years
_gac: 3 months
gac_gb: 3 months
_gcl_au: 3 months
_gcl_aw: 3 months
_gcl_dc: 3 months
_gcl_gb: 3 months
_gcl_gf: 3 months
_gcl_ha: 3 months
id: 2 years
test_cookie: 15 minutes

Facebook Remarketing

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the processing of Data, which connects the activity of this Application with the Facebook advertising network .
Personal Data processed: Usage Data and Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Storage duration:

_fbp: 3 mesi

How to manage preferences and give or withdraw consent

There are various ways to manage your Tracking Tools preferences and to give or withdraw consent, where necessary:
Users can manage Tracker preferences directly through their device settings – for example, they can prevent the use or storage of Trackers.
In addition, whenever the use of Tracking Tools depends on consent, the User can give or withdraw such consent by setting their preferences in the cookie policy or by updating these preferences via the tracking settings widget, if present.
Thanks to specific browser or device functions, it is also possible to remove previously saved Tracking Tools.
Other Tracking Tools present in the browser’s local memory can be removed by deleting the browsing history.
Regarding third-party Tracking Tools, Users can manage preferences and withdraw consent by visiting the relevant opt-out link (if available), using the tools described in the third party’s privacy policy or by contacting them directly.

Locate the Tracking Tools settings

Users can, for example, find information on how to manage Cookies in some of the most popular browsers at the following addresses:

Users can also manage some Trackers for mobile applications by deactivating them through the appropriate device settings, such as mobile advertising settings or settings related to tracking in general (Users can consult their device settings to find the relevant one) .

How to opt out of interest-based advertising

Without prejudice to the foregoing, Users are informed of the possibility of using the information available on YourOnlineChoices (EU), Network Advertising Initiative (USA) and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. With these services it is possible to manage the tracking preferences of most advertising tools. The Owner, therefore, advises Users to use these resources in addition to the information provided in this document.

The Digital Advertising Alliance also provides an application called AppChoices that helps Users control behavioral advertising on mobile applications.

Consequences of refusal of consent

Users are free to decide whether or not to give consent. However, please note that Tracking Tools allow this Application to provide a better experience and enhanced functionality to Users (in line with the purposes outlined in this document). Therefore, in the absence of the User’s consent, the Owner may not be able to provide the relevant functions.

Data Controller

Circularity S.R.L – Via Giovanni Bensi, 12/5 20152, Milan, Italy
Owner’s email address: info@circularity.com
Since the use of third-party Trackers on this Application cannot be completely controlled by the Owner, any specific reference to third-party Trackers is to be considered indicative. To obtain complete information, Users are kindly invited to consult the privacy policy of the respective third-party services listed in this document.
Given the objective complexity of identifying tracking technologies, Users are invited to contact the Owner should they wish to receive further information regarding the use of such technologies on this Application.

Definitions and legal references

Personal Data (or Data)

Any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data

This is the information collected automatically through this Application (also by third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual who uses this Application who, unless otherwise specified, coincides with the interested party.

Interested

The natural person to whom the Personal Data refers.

Data Controller (or Manager)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Data Controller)

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 and the tools adopted, including security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool through which the Personal Data of Users is collected and processed.

Service

The Service provided by this Application as defined in the relative terms (if available) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to include all current member states of the European Union and the European Economic Area.

Cookies

Cookies are Tracking Tools that consist of small portions of data stored within the User’s browser.

Tracking Tool

Tracking Tool means any technology – e.g. Cookies, unique identifiers, web beacons, integrated scripts, e-tags and fingerprinting – which allows Users to be tracked, for example by collecting or saving information on the User’s device.

Legal references

This privacy information is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to this Application.