Cookie Policy of Leam Roma
This document informs Users about the technologies that help Leam Roma to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with Leam Roma.
For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
Leam Roma uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information — such as the presence of other Trackers — in the linked privacy policies of the respective third-party providers or by contacting the Owner.
How Leam Roma uses Trackers
Necessary
Leam Roma uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.
Trackers managed directly by the Owner
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Preference Cookies (Leam Roma)
Preference Cookies store the User preferences detected on Leam Roma in the local domain such as, for example, their timezone and region.
Personal Data processed: Tracker.
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localStorage (Leam Roma)
localStorage allows Leam Roma to store and access data right in the User's browser with no expiration date.
Personal Data processed: Tracker.
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sessionStorage (Leam Roma)
sessionStorage allows Leam Roma to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
Personal Data processed: Tracker.
Trackers managed by third parties
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Google reCAPTCHA (Google LLC)
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, Tracker and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Trackers duration:
- _GRECAPTCHA: duration of the session
- rc::a: indefinite
- rc::b: duration of the session
- rc::c: duration of the session
- rc::f: indefinite
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iubenda Cookie Solution (iubenda srl)
The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on Leam Roma.
Personal Data processed: Tracker.
Place of processing: Italy – Privacy Policy.
Trackers duration:
- _iub_cs-*: 1 year
- _iub_cs-*-granular: 1 year
- euconsent-v2: 12 months
- usprivacy: 1 year
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iubenda Consent Solution (iubenda srl)
The iubenda Consent Solution allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.
Personal Data processed: Data communicated while using the service and Tracker.
Place of processing: Italy – Privacy Policy.
Trackers duration:
- ConS JS library localStorage (IUB_DATA): indefinite
- cookie _iub_previous_preference_id: 2 years
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Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
In order to understand Google's use of Data, consult their partner policy and their Business Data page.
Personal Data processed: Trackers and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Functionality
Leam Roma uses Trackers to enable basic interactions and functionalities, allowing Users to access selected features of the Service and facilitating the User's communication with the Owner.
Trackers managed by third parties
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Segment (Segment Inc.)
Segment is a tag management service provided by Segment.io, Inc.
Personal Data processed: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
Trackers duration:
- __storejs__: indefinite
- __tld__: duration of the session
- ajs%3Acookies: duration of the session
- ajs%3Atest: duration of the session
- ajs_anonymous_id: 1 year
- ajs_group_id: 1 year
- ajs_group_properties: indefinite
- ajs_user_id: 1 year
- ajs_user_traits: indefinite
- seg_first_url: 1 year
- seg_first_utm: 1 year
- segmentio*: indefinite
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Smartsupp (Smartsupp.com, s.r.o.)
The Smartsupp Widget is a service for interacting with the Smartsupp live chat and session recording platform provided by Smartsupp.com, s.r.o.
Personal Data processed: Data communicated while using the service, Tracker, Usage Data, various types of Data as specified in the privacy policy of the service and Videos.
Place of processing: Czech Republic – Privacy Policy.
Trackers duration:
- __ssupp.visits: 7 months
- ssupp.vid: 7 months
Experience
Leam Roma uses Trackers to improve the quality of the user experience and enable interactions with external content, networks and platforms.
Trackers managed by third parties
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PayPal button and widgets (PayPal Inc.)
The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.
Personal Data processed: Cookies and Usage Data.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Trackers duration:
- LANG: 8 hours
- akavpau_ppsd: duration of the session
- ts: duration of the session
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Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows Leam Roma to incorporate content of this kind on its pages.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy.
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Google Site Search (Google LLC)
Google Site Search is a search engine embedding service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Leam Roma to incorporate content of this kind on its pages.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Google Site Search with AdSense (Google LLC)
Google Site Search is a search engine embedding service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Leam Roma to incorporate content of this kind on its pages.
Google Site Search may display AdSense advertisements. For details of which data are collected, please refer to the privacy policy of this service.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Trackers duration:
- google_auto_fc_cmp_setting: indefinite
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Google Maps widget (Google LLC)
Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Leam Roma to incorporate content of this kind on its pages.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Measurement
Leam Roma uses Trackers to measure traffic and analyze User behavior to improve the Service.
Trackers managed directly by the Owner
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Analytics collected directly (Leam Roma)
Leam Roma uses an internal analytics system that does not involve third parties.
Personal Data processed: Cookies and Usage Data.
Trackers duration:
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Matomo (Leam Roma)
Matomo is an analytics software used by Leam Roma to analyze data directly without the help of third parties.
Personal Data processed: Cookies and Usage Data.
Trackers duration:
- _pk_cvar*: 30 minutes
- _pk_id*: 2 years
- _pk_ref*: 7 months
- _pk_ses*: 30 minutes
- _pk_testcookie*: duration of the session
Trackers managed by third parties
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Google Analytics (Universal Analytics) (Google Inc.)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Leam Roma, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Trackers duration:
- AMP_TOKEN: 1 hour
- _ga: 2 years
- _gac*: 3 months
- _gat: 1 minute
- _gid: 1 day
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Google Analytics Demographics and Interests reports (Google LLC)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for Leam Roma (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt Out.
Trackers duration:
- IDE: 2 years
- _gcl_*: 3 months
- test_cookie: 15 minutes
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Meta Events Manager (Meta Platforms Ireland Limited)
Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on Leam Roma.
Personal Data processed: Trackers and Usage Data.
Place of processing: Ireland – Privacy Policy.
Trackers duration:
- _fbp: 3 months
- lastExternalReferrer: duration of the session
- lastExternalReferrerTime: duration of the session
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Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of Leam Roma, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult their partner policy and their Business Data page.
Personal Data processed: number of Users, session statistics, Trackers and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Trackers duration:
- _ga: 2 years
- _ga_*: 2 years
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Google Optimize (Google LLC)
Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Trackers duration:
- _gaexp: 3 months
- _opt_awcid: 1 day
- _opt_awgid: 1 day
- _opt_awkid: 1 day
- _opt_awmid: 1 day
- _opt_expid: 10 seconds
- _opt_utmc: 1 day
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Smartlook (Smartsupp.com, s.r.o.)
Smartlook is a session recording and heat mapping service provided by Smartsupp.com, s.r.o.
Personal Data processed: Trackers, Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: Czech Republic – Privacy Policy.
Marketing
Leam Roma uses Trackers to deliver personalized ads or marketing content, and to measure their performance.
Some of the advertising services used by the Owner adhere to the IAB Transparency and Consent Framework, an initiative that facilitates responsible privacy practices across the digital advertising industry - providing Users with enhanced transparency and control over how their data are used for advertising tracking purposes. Users can customize their advertising preferences at any time by accessing the advertising preferences panel from within the cookie notice or via the relevant link on Leam Roma.
Leam Roma participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Leam Roma uses iubenda (identification number 123) as a Consent Management Platform.
Trackers managed by third parties
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Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Leam Roma with the Facebook advertising network.
Personal Data processed: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Trackers duration:
- _fbp: 3 months
- datr: 2 years
- lastExternalReferrer: duration of the session
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Google Ad Manager Audience Extension (Google LLC)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that tracks the visitors of Leam Roma and allows selected advertising partners to display targeted ads across the web to them.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Trackers duration:
- Conversion: 3 months
- DSID: 14 days
- FCNEC: 1 year
- FLC: 10 seconds
- FPAU: 3 months
- FPGCLAW: 3 months
- FPGCLDC: 3 months
- FPGCLGB: 3 months
- GCL_AW_P: 3 months
- GED_PLAYLIST_ACTIVITY: duration of the session
- IDE: 2 years
- NID: 6 months
- RUL: 1 year
- __gads: 2 years
- __gpi: 2 years
- __gpi_optout: 2 years
- __gsas: 2 years
- _gac_: 3 months
- _gac_gb_: 3 months
- _gcl_ag: 3 months
- _gcl_au: 3 months
- _gcl_aw: 3 months
- _gcl_dc: 3 months
- _gcl_gb: 3 months
- _gcl_gf: 3 months
- _gcl_gs: 3 months
- _gcl_ha: 3 months
- ar_debug: 3 months
- id: 2 years
- receive-cookie-deprecation: 6 months
- test_cookie: 15 minutes
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Google Signals (Google LLC)
Leam Roma uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from Leam Roma with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors.
If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
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Facebook Custom Audience (Meta Platforms, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of Leam Roma with the Facebook advertising network.
Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: email address and Tracker.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Trackers duration:
- _fbp: 3 months
- lastExternalReferrer: duration of the session
- lastExternalReferrerTime: duration of the session
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Rakuten Advertising Remarketing (Rakuten Marketing LLC)
Rakuten Advertising Remarketing is a remarketing and behavioral targeting service provided by Rakuten Marketing LLC or by Rakuten Marketing LLC dba Rakuten Advertising, depending on how the Owner manages the Data processing, that connects the activity of Leam Roma with the Rakuten advertising network.
Personal Data processed: Tracker, Universally unique identifier (UUID) and Usage Data.
Place of processing: United States – Privacy Policy – Opt out; European Union – Privacy Policy – Opt out.
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Remarketing with Google Analytics (Google LLC)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Trackers duration:
- test_cookie: 15 minutes
- IDE: 2 years
- _gcl_*: 3 months
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Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Leam Roma with the Google Ads advertising network and the DoubleClick Cookie.
In order to understand Google's use of Data, consult Google's partner policy.
Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Trackers duration:
- Conversion: 3 months
- DSID: 14 days
- FCNEC: 1 year
- FLC: 10 seconds
- FPAU: 3 months
- FPGCLAW: 3 months
- FPGCLDC: 3 months
- FPGCLGB: 3 months
- GCL_AW_P: 3 months
- GED_PLAYLIST_ACTIVITY: duration of the session
- IDE: 2 years
- NID: 6 months
- RUL: 1 year
- __gads: 2 years
- __gpi: 2 years
- __gpi_optout: 2 years
- __gsas: 2 years
- _gac_: 3 months
- _gac_gb_: 3 months
- _gcl_ag: 3 months
- _gcl_au: 3 months
- _gcl_aw: 3 months
- _gcl_dc: 3 months
- _gcl_gb: 3 months
- _gcl_gf: 3 months
- _gcl_gs: 3 months
- _gcl_ha: 3 months
- ar_debug: 3 months
- id: 2 years
- receive-cookie-deprecation: 6 months
- test_cookie: 15 minutes
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Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on Leam Roma. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers and Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Trackers duration:
- _fbc: 3 months
- _fbp: 3 months
- fr: 3 months
- lastExternalReferrer: duration of the session
- lastExternalReferrerTime: duration of the session
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Google Ads conversion tracking (Google LLC)
Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on Leam Roma.
Personal Data processed: Trackers and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Trackers duration:
- IDE: 2 years
- test_cookie: 15 minutes
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LinkShare (Rakuten Marketing LLC)
LinkShare is a commercial affiliation service provided by Rakuten Marketing LLC.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy.
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Rakuten Advertising Affiliate (Rakuten Marketing LLC dba Rakuten Advertising)
Rakuten Advertising Affiliate is a banner commercial affiliation service provided by Rakuten Marketing LLC dba Rakuten Advertising.
Personal Data processed: Tracker, Universally unique identifier (UUID) and Usage Data.
Place of processing: European Union – Privacy Policy – Opt out.
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Brevo marketing automation (SendinBlue SAS)
Brevo marketing automation is a User database management service provided by SendinBlue SAS.
Personal Data processed: email address, Trackers and Usage Data.
Place of processing: France – Privacy Policy.
Trackers duration:
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Brevo email (SendinBlue SAS)
Brevo email is an email address management and message-sending service provided by SendinBlue SAS.
Personal Data processed: email address, Trackers and Usage Data.
Place of processing: France – Privacy Policy.
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Brevo SMS (SendinBlue SAS)
Brevo SMS is a phone numbers management and communication service provided by SendinBlue SAS.
Personal Data processed: phone number, Trackers and Usage Data.
Place of processing: France – Privacy Policy.
How to manage preferences and provide or withdraw consent on Leam Roma
Whenever the use of Trackers is based on consent, users can provide or withdraw such consent by setting or updating their preferences via the relevant privacy choices panel available on Leam Roma.
With regard to any third-party Trackers, Users can manage their preferences via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.
How to control or delete Cookies and similar technologies via your device settings
Users may use their own browser settings to:
- See what Cookies or other similar technologies have been set on the device;
- Block Cookies or similar technologies;
- Clear Cookies or similar technologies from the browser.
The browser settings, however, do not allow granular control of consent by category.
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:
Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).
How to opt out of interest-based advertising
Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU and UK), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Consequences of denying the use of Trackers
Users are free to decide whether or not to allow the use of Trackers. However, please note that Trackers help Leam Roma to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, if the User chooses to block the use of Trackers, the Owner may be unable to provide related features.
Owner and Data Controller
Leam S.r.l. - VAT number IT00951371004
Via Appia Nuova, 26
00183 Rome (Italy)
Owner contact email: info@leam.com
Since the use of third-party Trackers through Leam Roma cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.
Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by Leam Roma.