Cookie Policy

1.Introduction and scope

This notice is provided pursuant to Art. 13 of Regulation (EU) 2016/679 (“GDPR”), Directive 2002/58/EC (the “ePrivacy Directive”), Art. 122 of Italian Legislative Decree 196/2003 (the Italian Privacy 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 www.migamatch.com (the MigaMATCH AIRA marketing and information site), in all its language versions (Italian, English, Spanish, French, German).

This notice supplements the Privacy Notice of the MigaMATCH AIRA platform, available at auto.migamatch.com/privacy, which governs the processing carried out on the platform (registration, matching, etc.). This notice instead applies to all visitors of www.migamatch.com, including non-registered ones.

2.Data controller and contacts

• Controller: Migastone International S.r.l. — Via 28 Luglio, 212 — 47893 Borgo Maggiore, Republic of San Marino — COE SM28583
• Email for privacy requests: privacy@migamatch.com
• Data Protection Officer (DPO): Ing. Antonio Mirizzi — rpd@invictusaziende.it
• Representative in the European Union (Art. 27 GDPR): Walter Coslop — w.coslop@migastone.com

3.What cookies and similar technologies are

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

4.How consent works on this site

1. On the first visit a banner appears with two equally prominent options: “Accept” and “Reject”.
2. Before a choice is made, no tracking tool is activated and no cookie is set.
3. If you reject, no tracking tool is activated.
4. Your choice is stored in your browser (local storage, key migamatch-consent) and remains valid for 6 months — whether you accepted or rejected — after which the banner is shown again. The choice also lapses if you clear your browser data.
5. You can change or withdraw your choice at any time via the “Manage cookie preferences” 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 selects “Accept” in the banner.

Google Tag Manager

• Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
• Nature: tag management system (container GTM-MGZXJFHF). The Google Tag Manager script does not itself set profiling cookies.
• As of the date of this notice, the container does not activate any additional tag. Any future activation of tags will entail an update of this notice and, where necessary, a new consent request.
• More information: policies.google.com/privacy

Meta Pixel

• Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland (pixel ID 838485425972882)
• Purpose: marketing — measuring the effectiveness of advertising campaigns and conversions (page views; a “Lead” event when signing up for an event through the site’s forms).

More information: facebook.com/privacy/policy — advertising preferences: facebook.com/adpreferences

7.Conversion measurement for event sign-ups

When you sign up for an event through the site’s forms, and only with your prior consent given via the banner, the site transmits to the Controller’s systems, for advertising conversion measurement (Meta Conversions API):

• the values of the _fbp and _fbc cookies;
• any click identifiers present in the referring URL (fbclid, gclid, gbraid, wbraid);
• the address of the page from which the sign-up was made.

Without consent, none of these identifiers is collected or transmitted.

8.Data transfers to third countries

The providers listed in section 6 are based in Ireland but may transfer data to the United States. Google LLC and Meta Platforms, Inc. are certified under the EU-US Data Privacy Framework (EU adequacy Decision 2023/1795); in addition or alternatively, the Standard Contractual Clauses (EU Decision 2021/914) apply. For further details on the safeguards adopted by the Controller, see the “Extra-EU data transfers” section of the platform Privacy Notice.

9.How to manage or withdraw consent

1. On the site: the “Manage cookie preferences” link at the bottom of the page (shows the banner again).
2. By email: writing to privacy@migamatch.com (the contact point for all privacy matters).
3. Data deletion: auto.migamatch.com/elimina-dati
4. From the browser: you can block or delete cookies from your browser settings — Chrome · Firefox · Safari · Edge
5. Advertising opt-out tools: youronlinechoices.com

10.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 can be exercised by writing to privacy@migamatch.com, to the DPO (rpd@invictusaziende.it) or to the EU Representative (w.coslop@migastone.com). For the full list of rights and how to exercise them, see sections 13-14 of the platform Privacy Notice.

You also retain the right to lodge a complaint with the supervisory authority of your EU member state of habitual residence (for Italy: the Garante per la protezione dei dati personali — garanteprivacy.it) or with the supervisory authority of the Republic of San Marino.

11.Updates to this notice

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