Cookies policy

Given the information set out in the Privacy Policy, this Cookie Policy explains the types and purposes of cookies used by the site available at www.evolutionpeople.it (hereinafter the “Website”) and provides the Users with the necessary information to manage their preferences regarding the use of cookies.

Data Controller

The Data Controller is Evolution People S.r.l., Via Mauro Macchi 50, 20124 Milan, phone no. 0287196562, email finance@evolutionpeople.it (the “Controller” or “EP”).

Browsing data

The IT systems and procedures used by Website automatically collect, during their ordinary use, certain data and personal data of the User, including environmental variables. This category of data includes, by way of example:

  • IP addresses of the computers used by Users;
  • Number of accesses;
  • Visited web pages;
  • Date and time of access;
  • The URL visited by the User before accessing the Websit;
  • Type of browser;
  • Operating system used.

Unless otherwise specified herein, the simple use of the Website and its sections does not imply the processing of personal data of the User. 

What are Cookies?

The Website uses technical, analytic and profiling cookies, also provided by third parties, in order to ensure the proper functioning and optimization of the Website’s performance, as well as for profiling and marketing purposes, as better described in this Cookie Policy.

Cookies are text strings that the websites visited by the User (“publisher” or “first party”) or other websites or web servers (“third parties”) place and store – directly in case of publishers and indirectly in case of third parties – in the terminal of the User.

The same objectives can also be achieved by means of other tools (so-called “passive identifiers”), which allow the data processing similarly to cookies. The Website does not use tracking tools other than the cookies indicated in this Cookie Policy. 

Cookies have different characteristics depending on their duration and can be classed on the basis of their duration or for the identity of their provider. From this perspective it is possible to distinguish between: 

  • persistent cookies, namely cookies that remain stored, until their expiration, on the User’s/visitor’s device. They are used to facilitate navigation and the correct use of the Website, to facilitate access to services requiring authentication, for statistical purposes, to know which areas of the site have been visited, as well as, in some cases, for the optimization of the management of pages and advertising spaces or to deliver content and advertising in line with the Users’ preferences and choices.
  • session cookie, namely cookies that are not stored permanently on the User’s device and disappear when the browser is closed. They are used to transmit the session identifiers necessary to allow safe and efficient navigation on the website. 
  • first-party cookies, namely cookies generated and managed directly by the Website manager. They can be either persistent or session cookies.
  • third-party cookies, namely cookies generated and managed by third parties other than the Controller and unrelated to the Website. They can be either persistent or session cookies.

Moreover, cookies can be classed on the basis of the purposes of processing performed by each cookie. In this perspective, it is possible to distinguish between:  

  • Technical cookie, namely cookies used for the sole purpose of “carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contracting party or user to provide that service” (see Section 122 (1) of the Privacy Code). Technical cookies are necessary and improve the usability of the Website, by enabling basic functions such as page navigation and access to protected areas of the site. The Website cannot properly work without these cookies.
  • statistical cookies or (“analytics”), namely cookies aimed at collecting information, in aggregate form, on the Users of the Website. Statistical cookies can be classed as technical cookies if: (i) they are only used to produce aggregated statistics and in relation to a single site or mobile application; (ii) at least the fourth component of the IP address is appropriately masked to third parties (iii) third parties refrain from combining analytics cookies, so minimized, with other identifiers (such as customers’ files or statistics of visits to other sites) or from transmitting them to other third parties (without prejudice to the possibility for third parties to produce statistics with data relating to multiple domains, websites or apps that can be traced back to the same publisher or business group). The Controller will have the right to autonomously carry out mere statistical processing of the data relating to the Website and/or other domains, websites and apps managed by or referable to the same, also by using data in clear text in compliance with any authorized purposes.
  • profiling cookies (or non-technical), namely cookies used to trace specific actions or recurring behavioural patterns of the User in the use of offered functionalities and collect information which can be referred to specific, identified or identifiable individuals for the purpose of grouping different profiles in homogeneous, multi-sized clusters; so that it will be possible to modulate the offering of services by providing increasingly customized services and to send targeted advertising messages  (i.e. messages that are in line with the preferences expressed by the user while browsing the web).

Cookies used by the Website and purposes

The Website uses the technical, statistical (similar to technical) and profiling cookies, as better described below: 

 

Typology of Cookies Cookie name Origin  Purpose Duration
Technical _gid Google Site analysis 1 day
Technical _ga Google Site analysis  2 days
Technical  _gat_gtag_UA_43829808_1 Google Save and track conversions 1 hour
Technical __hssrc Hubspot It is used to determine if the user of a page restarts the browser. Shows the value “1” if stored End of session
Profiling Hubspotutk Hubspot Marketing. 

It keeps track of the user’s identity. It is transmitted to HubSpot when filling out a form and is used during the deduplication of contacts. Contains the identifier of the user (GUID).

13 months
Profiling __hstc Hubspot Marketing

It is Hubspot’s main tracking cookie. It contains the domain, the initial (the first visit), the last and current (this visit) timestamp, the user token and the session number.

13 months

 

In relation to third-party statistical cookies, the Controller adopts appropriate tools to reduce the identification power, also by masking material portions of IP addresses that are processed, in compliance with the “Cookie guidelines and other tracking tools” adopted by the Privacy Authority on 10 June 2021. The use of these statistical third-party cookies, moreover, is subject to contractual obligations that commit third-party providers to use them exclusively for the provision of the service, to store them separately and not to “enrich” or “match” them with other available information. In any case, the Controller does not allow third-party suppliers to use cookies for purposes other than those described in this Cookie Policy.

In relation to Google Analytics’ cookies, the information collected by cookies as to use of the Website by Users will be transferred from the browser of the User to Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States, and stored on the company’s servers. The Google privacy policy, also in relation to the services of Google Analytics, which we invite you to read, are available at the following address: https://policies.google.com/privacy?hl=it

In relation to Hubspot cookies, the information collected by cookies as to use of the Website by Users will be transferred from the browser of the User to Hubspot Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA. The Hubspot privacy policy, also in relation to the services of Hubspot, which we invite you to read, are available at the following address:  https://legal.hubspot.com/privacy-policy

The profiling cookies listed above are used, only with the prior consent of the User, for marketing and commercial purposes, to provide the User with advertising –  also in a dynamic and evolved mode – consistent with the browsing choices made by the User also on other third-party sites. 

Legal basis of data processing

Legal basis for the processing of data collected by technical cookies and analytics (and similar)

Technical cookies are necessary and contribute to improve the user experience on the Website, by enabling its basic functions such as page navigation and access to the relevant protected areas. The Website cannot work properly without these cookies. The processing of data collected by technical cookies is based on the legitimate interest of the Controller and does not require the prior collecting of the User’s consent, as the Website could not work properly without such kind of data processing.

In relation to statistical cookies (or analytics), aimed at collecting information on Users, in aggregate form, and suitable to be classed as technical cookies in compliance with the “Cookie guidelines and other tracking tools” adopted by the Privacy Authority on 10 June 2021, the prior acquisition of the User’s consent is not necessary as no personal data of Users is disclosed or processed. 

Legal basis for the processing of data collected through non-technical cookies

Consent is optional in relation to all non-technical cookies. In such case, the refusal to grant consent will only prevent the processing of the relevant personal data and will only determine the impossibility for the Controller to provide a personalized service.

Users are free to grant or deny their consent as to the use of profiling cookies for promotional purposes through the appropriate banner displayed at the first access to the Website. 

In any case it is always possible to change the choices made in relation to the use of cookies for marketing and commercial purposes by visiting the following page [INSERIRE LINK DOVE POTER OPERARE SCELTE SUI COOKIES]:

Deleting cookies

Since cookies are normal text files, they can be accessed using text processing programs. In any case, each User can independently set his/her browser on his/her device so that it automatically accepts/rejects all cookies or displays a warning whenever a cookie is proposed, in order to evaluate whether to accept it or not. 

If the User sets the browser by refusing to activate cookies, the quality of the pages of the Website may decrease and the browsing experience may be less effective.

The instructions for the management of cookies of the main browsers are available at the following links:

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