FREE LIFE 101
Cookie Policy
Cookies consist of portions of code installed in the browser that assist the Owner in providing the Service according to the purposes described. Some of the purposes for which Cookies are installed may also require the User's consent.
Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this document.

Technical Cookies and Cookies serving aggregated statistical purposes

• Activity strictly necessary for the functioning of the Service
This Website uses Cookies to save the User's session and to carry out other activities that are strictly necessary for the operation of this Website, for example in relation to the distribution of traffic.

• Activity regarding the saving of preferences, optimization, and statistics

This Website uses Cookies to save browsing preferences and to optimize the User's browsing experience. Among these Cookies are, for example, those used for the setting of language and currency preferences or for the management of first party statistics employed directly by the Owner of the site.

Other types of Cookies or third parties that install Cookies

Some of the services listed below collect statistics in an anonymized and aggregated form and may not require the consent of the User or may be managed directly by the Owner - depending on how they are described - without the help of third parties.
If any third party operated services are listed among the tools below, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policy of the listed services for detailed information.

• Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Ads conversion tracking (Google Inc.)
Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, 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.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Content commenting

Content commenting services allow Users to make and publish their comments on the contents of this Website.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Disqus (Disqus)
Disqus is a content commenting service provided by Big Heads Labs Inc.
Personal Data collected: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out.
• Infrastructure monitoring
This type of service allows this Website to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Website.
Pingdom (Pingdom AB)
Pingdom is a monitoring service provided by Pingdom AB.
Personal Data collected: Cookies and Usage Data.
Place of processing: Sweden – Privacy Policy.
• Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
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 collected: Cookies and Usage Data.
Place of processing: See the PayPal privacy policy – Privacy Policy.

• Remarketing and behavioral targeting

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data collected: Cookies and email address.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Website with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.

• Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Segment (Segment Inc.)
Segment is a tag management service provided by Segment.io, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

• User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.
Intercom (Intercom Inc.)
Intercom is a User database management service provided by Intercom Inc. Intercom can also be used as a medium for communications, either through email, or through messages within this Website.
Personal Data collected: Cookies, email address, Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

How to provide or withdraw consent to the installation of Cookies

In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing Cookies.
Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website.
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.
With regard to Cookies installed by third parties, Users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the means provided in the third party's privacy policy, or by contacting the third party.
Notwithstanding the above, the Owner informs that Users may follow the instructions provided on the subsequently linked initiatives by the EDAA (EU), 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.

Owner and Data Controller

FreeLife101 Investment Group

Owner contact email : [email protected]

Since the installation of third-party Cookies and other tracking systems through the services used within this Website cannot be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, the User is kindly requested to consult the privacy policy for the respective third-party services listed in this document.
Given the objective complexity surrounding the identification of technologies based on Cookies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of Cookies by this Website.

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 this Website (or third-party services employed in this Website), which can include: the FreeLife101addresses or domain names of the computers utilized by the Users who use this Website, 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 this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
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 this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website 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.
Cookies
Small sets of data stored in the User's device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Website, if not stated otherwise within this document.
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