Welcome to the cookie policy of Strumenta Websites. This policy will help you understand what cookies and tracking technologies we use, how we use them and what your rights are in relation to it.
Latest update: June 11, 2025
Introduction
This document informs Users about the technologies that help Strumenta Websites 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 Strumenta Websites.
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 Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
Strumenta Websites 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.
Owner and Data Controller
Strumenta S.R.L.
Corso Giuseppe Siccardi 11 bis - 10122 Torino (Italy)
IT11817320010
Owner contact email: info@strumenta.com
How Strumenta Websites uses Trackers
Necessary
Strumenta Websites 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 by third parties
Cloudflare
Company: Cloudflare, Inc.
Place of processing: United States
Personal Data processed: Trackers +1
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Strumenta Websites, i.e., communication between Strumenta Websites and the User's browser, while also allowing analytical data from Strumenta Websites to be collected.
Personal Data processed:
Trackers
various types of Data as specified in the privacy policy of the service
Strumenta Websites uses Trackers to measure traffic and analyze User behavior to improve the Service.
Trackers managed by third parties
Google Analytics (Universal Analytics) with anonymized IP
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Cookies +1
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Strumenta Websites, 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.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Strumenta Websites 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 Strumenta Websites.
Strumenta Websites participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Strumenta Websites uses iubenda (identification number 123) as a Consent Management Platform.
Trackers managed by third parties
ConvertKit
Company: ConvertKit LLC
Place of processing: USA
Personal Data processed: Cookies +3
ConvertKit is an email address management and message sending service provided by ConvertKit LLC.
LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on Strumenta Websites. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of Strumenta Websites.
How to manage preferences and provide or withdraw consent on Strumenta Websites
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 Strumenta Websites.
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 Strumenta Websites 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.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Strumenta Websites (or third-party services employed in Strumenta Websites), which can include: the IP addresses or domain names of the computers utilized by the Users who use Strumenta Websites, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Strumenta Websites who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
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, including the security measures concerning the operation and use of Strumenta Websites. The Data Controller, unless otherwise specified, is the Owner of Strumenta Websites.
Strumenta Websites (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Strumenta Websites as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to Strumenta Websites, if not stated otherwise within this document.
