Cookie policy

1.Introduction and scope

This policy is provided pursuant to Art. 13 of Regulation (EU) 2016/679 (“GDPR”), Directive 2002/58/EC (“ePrivacy Directive”), Art. 122 of Legislative Decree 196/2003 (Italian Personal Data Protection Code, applicable to Italian users) and Law No. 171/2018 of the Republic of San Marino, and describes the use of cookies and similar technologies on the migastone.com website, in all its language versions (Italian, English, Spanish, French, German).

2.Controller and contacts

• Controller: Migastone International Srl, Via 28 Luglio 212, 47893 Borgo Maggiore, San Marino, COE SM28583, telephone (+378) 0549 888808, PEC migawin@pec.it
• Data Protection Officer (DPO): Ing. Antonio Mirizzi, Via Tommaso Fiore 82, Triggiano (BA), Italia, rpd@invictusaziende.it
• Representative in the European Union (Art. 27 GDPR): Walter Coslop, Via Ugo Bassi 11, 47822 Santarcangelo di Romagna (RN), Italia, w.coslop@migastone.com
• Support portal: ticket.migastone.com, by opening a new request

3.What cookies and similar technologies are

• Cookies: small text files that the websites visited send to the user’s browser, where they are stored and then sent back to the same websites on the next visit.
• Local storage: a browser storage area in which a website can save persistent information, readable only by the website that wrote it.
• Pixels and tracking scripts: snippets of code or invisible images that allow a third-party provider to detect a page visit or the completion of an action.

4.How consent works on this website

1. On the first visit a banner appears with three options: “Accept all” and “Reject”, equally prominent, and “Customize”, which allows the Statistics (Google Analytics 4) and Marketing (Meta Pixel) categories to be chosen separately.
2. Before a choice is made, no third-party tool is loaded and no cookie is set.
3. In the event of rejection, no statistics or marketing tool is loaded. If only one category is accepted, only the tool of that category is loaded.
4. Google Analytics 4 is configured with Google’s consent mode (Consent Mode v2): all consent signals start as denied and are updated according to the choice made. Advertising signals remain denied unless the Marketing category is also accepted.
5. The choice is stored in the user’s browser (local storage, key migastone-consent) and remains valid for 6 months, whether consent is given or refused, after which the banner is shown again. The choice also lapses if the browser’s browsing data is cleared.
6. The choice can be changed or withdrawn at any time via the “Manage cookies” link at the bottom of the page, which shows the banner again.

5.Technical tools (no consent required)

6.Tools subject to consent

The following tools are activated only after the user has accepted the respective category in the banner (“Accept all”, or “Customize”).

Google Analytics 4 (Statistics category)

• Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
• Nature: statistics service, loaded directly with the gtag.js script (ID G-CEKYCHJFEG), without Google Tag Manager.
• Purpose: statistics: aggregate measurement of visits and page views. The IP address is anonymized; Google signals and ad personalization are disabled unless the Marketing category is also accepted.

More information: policies.google.com/privacy

Meta Pixel (Marketing category)

• Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland (pixel ID 478462192345844)
• Purpose: marketing: measurement of the effectiveness of advertising campaigns (page views).

More information: facebook.com/privacy/policy; managing ad preferences: facebook.com/adpreferences

7.YouTube videos

Any YouTube videos on the website are not loaded when the page opens: the player is loaded only when the user clicks on the video, from the youtube-nocookie.com domain (YouTube’s privacy-enhanced mode). When the video is loaded, the browser connects to Google’s servers, which receive the user’s IP address and process the data according to Google’s own policy: policies.google.com/privacy.

8.Transfers of data to third countries

The providers of the tools subject to consent are based in Ireland but may transfer data to the United States. Google LLC and Meta Platforms, Inc. are listed as certified under the EU-US Data Privacy Framework (EU adequacy decision 2023/1795); in addition or as an alternative, the Standard Contractual Clauses (EU Decision 2021/914) apply.

9.How to manage or withdraw consent

1. On the website: the “Manage cookies” link at the bottom of the page (shows the banner again, where the categories can be changed or everything rejected). When a category is withdrawn, the corresponding tool is disabled and its first-party cookies are deleted.
2. For data protection requests: to the Controller by PEC (migawin@pec.it), to the DPO (rpd@invictusaziende.it), to the EU Representative (w.coslop@migastone.com) or through the support portal ticket.migastone.com.
3. From the browser: cookies can be blocked or deleted in the browser settings: Chrome · Firefox · Safari · Edge
4. Advertising opt-out tools: youronlinechoices.com/it
5. Information on cookies from the Italian Data Protection Authority (Garante per la protezione dei dati personali): garanteprivacy.it/cookie

10.Linked websites

Links to other websites, such as migamatch.com, ingegneriadellerelazioni.com and the support portal ticket.migastone.com, lead to services separate from this website: any cookies used by those services are governed by the policies published on each of them.

11.Data subject rights and complaints

Users have the rights set out in Arts. 15-22 GDPR (access, rectification, erasure, restriction, portability, objection, withdrawal of consent), which may be exercised by writing to the DPO (rpd@invictusaziende.it) or to the EU Representative (w.coslop@migastone.com), or through the support portal. Details are in the privacy policy.

This is without prejudice to the right to lodge a complaint with the supervisory authority of the EU Member State of habitual residence (for Italy: Garante per la protezione dei dati personali, garanteprivacy.it) or with the supervisory authority of the Republic of San Marino.

12.Updates to this policy

This policy may be updated to reflect changes to the tools used or to the law. Each version states its number and publication date; in the event of substantial changes (e.g. activation of new tracking tools), new consent will be requested.