Cookie policy

Cookie policy

Clonline.org Cookie Policy

Privacy Policy on the use of cookies pursuant to the Privacy Guarantor's "Guidelines on Cookies and other Tracking Tools" of 10 June, 2021, for those users of the web services of Comunione e Liberazione, accessible from the addresses on the domain it.clonline.org.

The Comunione e Liberazione website uses cookies and similar technologies to ensure the proper functioning of procedures and improve the user experience of online applications.

This document provides detailed information on the use of technologies to enable the Data Controller to collect and save information (e.g. cookies) or use resources on the User's device (e.g. by running a script) when the latter interacts with this Website. For the sake of simplicity, these technologies are hereinafter referred to as "Tracking Tools".

Some of the purposes for which tracking tools are used require the User's consent. The acquisition and withdrawal of consent are managed in accordance with this Privacy Policy through forms provided by the Data Controller, as described in detail in the section "Cookie Management".

The Comunione e Liberazione website uses tracking tools managed directly by the Data Controller ("first party tools") and tracking tools relating to services provided by third parties ("third-party tools") managed by the individual service providers.

Some cookies and tracking tools expire at the end of the User's browsing session. Others persist as deemed necessary by the Data Controller or each third-party provider.

With regard to third-party tracking tools, Users will find more detailed and updated information on the duration, plus other information - such as the presence of other tracking tools - in the privacy policies of the respective third-party providers (through the links provided).


Definitions


Personal Data (or Data)
Personal Data is any information that allows a natural person to be directly or indirectly identified.

Usage Data
This is collected directly and indirectly by this Website, partly through the use of third-party applications. The data relates to the User's computer environment, the sequence of pages consulted on this Website or other generic technical details (e.g. IP addresses, time of the request, status and details of the request, characteristics of the visitor's browser and operating system).

User
The individual who uses this Website and who is the same as the Data Subject unless otherwise specified.

Data Subject
The natural person to whom the Personal Data refer.

Data Processor (or Processor)
The natural person, legal entity, public administration or any other entity that processes Personal Data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Controller)
The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the tools employed, including the security measures relating to the operation and use of this Website.

The Data Controller, unless otherwise specified, is the Associazione Laicale Fraternità di Comunione e Liberazione, as identified at the bottom of this Privacy Policy, owner of this Website.

This Website (or this Application)
The hardware or software tool by which Users' Personal Data are collected and processed.

Service
The Service provided by this Website as defined in the terms and conditions (if any) on this website / application.

Cookies
Cookies are tracking tools that consist of small pieces of data stored inside the User's browser. The sites you visit send Cookies to your device which are stored (usually in your web browser) and then resent to the same websites on subsequent visits. Cookies can be divided into different categories depending on their characteristics and uses:

Technical Cookies and Other Technical Identifiers
These are defined by the Guarantor as used for the sole purpose of "ensuring the transmission of data 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 such service".

This first category of cookies is indispensable. If deactivated use of the services provided by the website is compromised.
According to the Guarantor, their installation does not require the user's consent, but they must be explicitly indicated in the Privacy Policy.

Analytical Cookies that can be Assimilated to Technical Cookies
According to the aforementioned Guarantor guidelines, our own or third-party analytical cookies can be assimilated to technical cookies and other identifiers only if:
  • they are only used to generate aggregate statistics and in relation to a single site or mobile application;
  • at least the fourth component of the IP address is masked for third parties;
  • the third party does not combine the minimised cookie analytics with other processing data (e.g. customer files or statistics on visits to other websites) or pass them on to other third parties. However, third parties are permitted to produce statistics with data from several domains, websites or apps that can be traced back to the same publisher or business.


This second category of cookies is used to monitor system activity or required to perform certain operations offered by this Website (e.g. improve the User's browsing experience).

Others Cookies, in particular Profiling Cookies and Analytical Cookies Not Assimilable To Technical Cookies
This third category concerns all cookies other than the technical or assimilated cookies defined above, including profiling cookies, which may also be used for promotional purposes.

They are only installed with the specific consent of the User, given in the manner described in the section "Cookie Management".

Some cookies (session cookies) remain active only until the browser is closed or until logout. Other cookies 'survive' when you close your browser and are available on subsequent visits. These cookies are called persistent and their duration is fixed by the server at the time of their creation. Browsing through the site it.clonline.org, you may interact with sites operated by third parties who may create or modify persistent and profiling cookies according to different rules.

Cookie Management
Technical cookies and analytical cookies assimilated by the Guarantor to technical cookies, as defined above, are automatically installed during navigation, regardless of the User's consent.

The User can disable these cookies by using the browser's settings. The total or partial disabling of cookies may compromise the use of this Website's functionalities, but will not prevent its navigation.

All other types of cookies are only installed if the User unequivocally expresses his or her specific consent.

Consent can be given by clicking on the cookie banner that opens when accessing the Website, or in the sections of the Website to which the banner refers, which are also accessible from a link at the bottom of each page.

In this banner and in these sections, each User can accept the installation of cookies other than technical cookies and cookies assimilated to technical cookies by the Guarantor.

As a default Website setting, if the User does not activate these cookies using the specific commands, cookies other than technical cookies or cookies assimilated to technical cookies will not be installed.

In the sections to which the banner or the link at the bottom of each page refers, the User will also find controls to modify his / her choices, revoke consent previously given to the installation of cookies or give consent to the installation of previously unauthorised cookies.

Expressing a preference on the banner is not a precondition for continued navigation.

The User may simply close the banner and continue browsing; in this case no cookies other than technical or analytical cookies assimilated to technical cookies will be installed.

The above does not apply to any interactions that the Website permits - at the User's free discretion - with external websites or platforms (social media networks, YouTube, etc.).

The User should be aware that the Controller has no control over and assumes no responsibility for such third-party sites and platforms, the cookies that they may use and install on the User's computer, and in general on compliance with Reg. (EU) 679/2016 or the Provision of the Guarantor by third-party operators of said sites.
The User accesses these sites and external content at his / her own risk and is responsible for checking the policies on personal data protection and cookies directly with the third-party operators of such sites and external platforms.

The fact that the Controller may borrow some information from the privacy policies of said third parties in this Policy does not imply any assumption of responsibility by the Controller regarding the reliability of the same or other information and does not in any way exempt the User from directly verifying it.

Cookies on external websites must be managed exclusively with the tools made available by the third-party operators or by using the User's browser settings to disable them, or in any case by following the instructions of the respective third-party operators.

Tracking Tools
A Tracking Tool is any technology (cookies, scripts, etc.) that allows users to be tracked by collecting or storing data on the User's device.

The following section of this Policy sets out in detail the cookies and third-party cookies installed by the Website and their characteristics.

Activities Strictly Necessary to the Functioning of this Website and the Provision of All Related Services


This Website uses cookies commonly referred to as 'technical' cookies or other similar tracking tools to perform activities strictly necessary to ensure operation and the provision of service.

Hosting and Backend Infrastructure
The purpose of these services is to host data and files that allow this Website to function, allow them to be distributed on the Internet and provide an infrastructure able to support the specific functions of this Website.

Some of the services listed below (if present) may operate on geographically dispersed servers, making it difficult to determine the actual location where the Personal Data is stored.

Hosting of the Main Website

This Website is hosted at the premises of Comunione e Liberazione in Milan.

Personal Data processed: Usage Data and Tracking Tool.

Legal basis for processing: legitimate interest.

Place of processing: Italy

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Period of data retention: 5 years

Hosting of the Web Browser and Tracce Magazine App
The applications relating to the Tracce magazine are distributed over several separate servers depending on the nature of the services.

The Web Browser component and the services on which the apps are based are hosted in Arezzo c/o Aruba Datacenter IT1 managed by Ximplia srl.

Personal Data processed: Usage Data and Tracking Tool, User ID codes for retrieving purchases of Tracce magazine content.

Legal basis for processing: legitimate interest.

Place of processing: Italy

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Period of data retention: 5 years

Hosting of the Newsletter System
The applications relating to the Newsletter system are hosted on a server managed by Uebba! srl and located at SUPERNAP Italia - Via Marche, 8/1027010 Siziano (Pavia), Italy

Personal Data processed: Usage Data and Tracking Tool, Personal Data (first name, last name and e-mail address).

Legal basis for processing: legitimate interest.

Place of processing: Italy

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Period of data retention: 5 years

Activities Involving the Use of Tracking Tools


Monitoring Interactions Between Users and this Website
This Website uses tracking tools to measure traffic, analyse the technical characteristics of the devices used and the User's behaviour with the sole purpose of constantly improving the service offered.

Tracking tools may also be used to enable simple interactions and activate functionalities that allow Users to access certain resources of the service and simplify or enable communication with the Controller.

Alerts
Alerts are intended for the User and linked to specific actions such as the change of website on the clonline.org platform (e.g. switching from the international site in English to the United Kingdom national site) or access to additional information. Such services require User Data to pass through them and, where appropriate, be retained.

Interaction with Newsletter Platforms

This type of service allows you to interact with third-party newsletter platforms (in particular Uebba! srl), directly from this Website, subscribe to newsletters and provide the details necessary for subsequent e-mail contact by Comunione e Liberazione editorial staff.

Where contact details are provided, even if Users do not use the service, the service may collect Usage Data relating to the communications. In addition, interactions between Users and the Website may be recorded.

Personal Data processed: data communicated during service registration, Usage Data, e-mail and Tracking Tool.

Legal basis for processing: consent.

Place of processing: Italy

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Period of data retention: details retained until independently revoked by the User or until the end of the purpose for which they were collected.

Tracking and Managing Behaviour
This type of service is used to track and manage the User's behaviour with respect to specific activities such as filling in forms and surveys published on the Website pages or downloading attachments to the web pages.
Such services may require User Data to pass through them and, where appropriate, be retained until the purpose for which it was collected is fulfilled.

Improving user experience
This Website may use tracking tools to help provide a personalised user experience aimed at constantly improving the personal settings and interaction with external networks and platforms.


Interaction with Social Media Networks and Display of Content Published on External Platforms


This type of service enables the management of interactions with external platforms (e.g. social media).

In particular, the content of one platform can be published/viewed on the other and vice versa. The pages of this Website may contain content hosted on external platforms and may allow interaction with them through special interfaces provided by the social media networks (widgets).

This type of integration may collect traffic data for the pages where the service is installed, even if Users do not explicitly use it (for example, when the web page contains a video published on YouTube, a map managed by Google Maps or a widget used to retrieve content from a social media network).

Interactions and data collected by this Website are governed by the User's privacy settings for each social media network. It is advisable to disconnect from the corresponding services to ensure that the data processed on this Website is not linked back to the User's profile on external platforms.

Twitter Buttons and Social Widgets (Twitter, Inc.)
The Twitter Tweet/Share button and Twitter social widgets are services for interacting with the social media platform Twitter, provided by Twitter, Inc.

Personal Data processed: Usage Data and Tracking Tool.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy of the third-party operator.

Facebook Button and Social Widgets (Facebook, Inc.)
The Like/Share on Facebook button and the Facebook widgets are services for interaction with the social media platform provided by Facebook, Inc.

Personal Data processed: Usage Data and Tracking Tool.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy of the third-party operator.

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Period of data retention: 3 months.

YouTube Video Widget
YouTube is a video content display service operated by Google Inc. that allows this Website to integrate such content within its pages.

Personal Data processed: cookies and Usage Data.

Place of processing: United States - Privacy Policy of the third-party operator; Ireland - Privacy Policy of the third-party operator.

Google Maps Widget
Google Maps is a map display service operated by Google Inc. that allows this Website to integrate such content within its pages.

Personal Data processed: cookies and Usage Data.

Place of processing: United States - Privacy Policy of the third-party operator; Ireland - Privacy Policy of the third-party operator.


Statistical Services


The services in this section allow the Data Controller to monitor, analyse, process and manage statistics anonymously and non-anonymously through the use of first- and third-party tracking tools.

Google Analytics with Anonymised IP
This Website integrates the Google Analytics service provided by Google Inc. which collects Personal Data to track and examine in detail user activity.

Google Analytics uses the data collected to produce various kinds of reports, share it with other services and, depending on the User's settings for those services, customise the User experience on the basis of the data collected (e.g. ads from the Google advertising network may be personalised thanks to the Personal Data collected by Google Analytics).

The integration of Google Analytics anonymises the Users' IP address to ensure maximum privacy. IP addresses are abbreviated during data collection and this takes place within the borders of the European Union member states or other countries that are members of the European Economic Area. IP addresses may be sent to Google's servers and abbreviated within the USA only in exceptional cases.

Personal Data processed: Usage Data and Tracking Tool.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy of the third-party operator - Opt Out; Ireland - Privacy Policy of the third-party operator - Opt Out.

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

User ID Extension for Google Analytics
Tracking by Google Analytics on this Website is performed by assigning a unique ID in such a way that does not allow personal identification of a User or a specific device. The Opt Out link provided below allows you to disable tracking by Google Analytics for the device you are using.

Personal Data processed: Tracking Tool.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy of the third-party operator - Opt Out; Ireland - Privacy Policy of the third-party operator - Opt Out.

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Google Ads Conversion Tracking
Depending on the User's settings, your actions on this Website may be linked to data from the Google Ads network through conversion tracking. Depending on where this Website is used, statistics may be provided by Google LLC or Google Ireland Limited.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy of the third-party operator; Ireland - Privacy Policy of the third-party operator.

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Facebook Ads Conversion Tracking
Facebook Ads conversion tracking (Facebook pixel) is a statistical service provided by Facebook, Inc. that links data from the Facebook ad network with actions on this Website. The Facebook pixel tracks conversions that can be attributed to Facebook Ads, Instagram and Audience Network.

Personal Data processed: Usage Data and Tracking Tool.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy of the third-party operator.

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Period of data retention: 90 days

Generation of Advertising Reports in Google Analytics
Depending on the User's settings, your actions within this Website may be analysed together with the behaviour and interests revealed by the recording of traffic data on your interaction with ads. In addition, if enabled, the data can also collect demographic data linked to age and gender.

Google Analytics on this Website has enabled advertising report generation functionality, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (application activity).

Users may opt out of Google cookies in Google's Ad Settings (https://adssettings.google.com/authenticated).

Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example), the tracking tool and various types of data as specified by the service's privacy policy.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy of the third-party operator - Opt Out; Ireland - Privacy Policy of the third-party operator - Opt Out.

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

Period of data retention: 3 years

Google Analytics Demographic and Interest Data Reports
Depending on the settings chosen by the User, interest data and demographic data relating to age and gender may be shown within Google Analytics for this Website. Users may opt out of Google cookies in Google's Ad Settings (https://adssettings.google.com/authenticated).

Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example) and Tracking Tool.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy of the third-party operator - Opt Out; Ireland - Privacy Policy of the third-party operator - Opt Out.

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.


Targeting and Advertising


Remarketing Google Ads and Google Analytics
Depending on the choices made by the User, the activity of this Website may be linked with the Google Ads advertising network and the DoubleClick cookie. The tracking activity performed by Google Analytics may also be used for advertising purposes.

In this case, depending on the location from which the User accesses this Website, the remarketing and behavioural targeting service (Remarketing Google Ads) will be provided by either Google LLC or Google Ireland Limited.

In addition to being able to opt out of cookies relating to advertising on this Website, Users can also opt out of the cookies used by Google to personalise advertisements in Google's Ads Settings.

Personal Data processed: Usage Data and Tracking Tool.

Legal basis for processing: consent.

Place of processing: United States - Privacy Policy - Opt Out; Ireland - Privacy Policy - Opt Out.

Legal basis for the transfer of Personal Data outside the EU: standard data protection clauses adopted by the European Commission.

How to Manage Preferences and Give or Withdraw Consent


Preferences relating to tracking tools can be set at various levels. Firstly, Users can set their devices to completely prevent the use or storage of tracking tools regardless of the website browsed. Depending on the device, this can be done directly from the operating system or browser options.

In addition, as indicated in the "Cookie Management" section above, the Website allows Users who so wish to consent to the use of tracking tools whose use is consent dependent. Users can give or withdraw this consent by setting their preferences from the banner or by clicking on the consent management link in the banner itself or at the bottom of every page. The tracking tools preference widget allows the User to learn more and choose from the available options.

Specific browser or device functions also allow you to remove any previously saved tracking tools (e.g. by deleting your browsing history).

Preferences regarding third-party tracking tools can be managed by Users:
  • if the third party is one of the Controller's suppliers, by using the methods described in the "Cookie Management" section above, or if the User so chooses using the tools described in the third party's privacy policy or by contacting them directly.
  • if the third party is the operator of an external site or content to which the Controller merely provides a link on the Website, using the tools described in the third party's privacy policy or by contacting them directly. It is possible to give or withdraw consent that may have been given initially in the manner indicated by the third party; the User is directly responsible for verifying this.


How to Manage Cookies in Popular Browsers
The following links provide information on how to manage cookies in some of the most popular browsers:


Users may in any case manage certain Mobile Tracking Tools via dedicated device settings (mobile advertising settings or tracking in general).

Advertising Industry Initiatives for Consent Management
In addition to the information provided in this policy, we recommend the use of third-party services that allow you to manage the tracking preferences of most advertising tools.

YourOnlineChoices (EU), Network Advertising Initiative (USA), Digital Advertising Alliance (USA), DAAC (Canada) and DDAI (Japan) contain a lot of information about cookies as well as the steps you can take to protect your privacy on the Internet.

Given that the use of third-party tracking tools on this Website cannot be fully controlled by the Controller and the Controller has only the information, representations and warranties that are provided by the third party, any reference to third-party tracking tools is purely indicative. For full information in addition to that provided here, Users are therefore advised to read the privacy policy of the third-party services mentioned in this document.

In view of the objective complexity of identifying tracking technologies, Users are invited to contact the Controller if they wish to receive further information on their use on this Website.

Data Controller


Fraternità di Comunione e Liberazione
Via De Notaries 50, Milan
Tel. 02.66595088
E-mail address: privacy@comunioneliberazione.org.

Legal framework
This Privacy Policy was drafted on the basis of current legislation, including Articles 13 and 14 of Regulation (EU) 2016/679, and the Guarantor's Provision no. 231 of 10 June 2021 for the protection of personal data

Unless otherwise specified, this privacy policy relates exclusively to this Website.

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