Cookie Policy

Last updated: {{DATE}}

This Cookie Policy describes the types of cookies and similar technologies (hereinafter, for brevity, "cookies") used by this website, the purposes for which they are used, and how the user can manage their preferences. It is drafted in accordance with Regulation (EU) 2016/679 ("GDPR"), Italian Legislative Decree 196/2003 (the "Privacy Code", as amended by Legislative Decree 101/2018), and the Guidelines on cookies and other tracking tools issued by the Italian Data Protection Authority (Garante per la protezione dei dati personali, 10 June 2021).

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1. Data Controller

The Data Controller is:

• VisionFlow — {{LEGAL_NAME}}
• Registered office: {{REGISTERED_ADDRESS}} — Milan, Italy
• VAT no. (P.IVA): {{VAT}}
• E-mail: hello@visionflow.video
• Phone: {{PHONE}}

For any question regarding this Cookie Policy or the processing of personal data, you may write to the e-mail address above.

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2. What cookies and similar technologies are

Cookies are small text files that websites store on the user's device (computer, tablet, smartphone) during browsing. The same rules apply to other similar technologies that allow information to be stored on or read from the device, including:

• the browser's local storage and session storage (local memory areas of the browser);
• pixels/web beacons, identifiers, and fingerprinting techniques.

Depending on their purpose, these tools are divided into technical cookies (necessary for the site to function) and profiling/tracking cookies (which monitor the user and analyse their behaviour). The latter may be installed only with the user's prior consent.

Cookies may also be first-party (set directly by this site) or third-party (set by domains other than the site's).

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3. Current state of the site: a "cookie-light" site

We want to be transparent: this site uses analytics cookies (Google Analytics 4 and Yandex Metrica) — but only after your consent. No profiling or marketing cookies are present.

The only item stored on the user's device is a strictly technical local storage entry called vf-consent, which remembers the choice made in relation to the cookie notice so that it is not shown again on every visit. In addition, the site's multilingual system may store a language preference (a technical cookie/entry) in order to display the interface in the language chosen by the user.

None of these tools collects data for profiling purposes, none tracks browsing across other sites, and none requires consent, as they are strictly necessary to provide the service.

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4. Categories of cookies and technologies

4.1 Technical / necessary cookies (no consent required)

These are essential for the site to function correctly and to deliver the services requested by the user. They do not require consent, in accordance with Art. 122 of the Privacy Code and the Garante's Guidelines. This category includes:

• storing the cookie choice (vf-consent);
• the interface language preference;
• any technical cookies/entries needed for security and browsing stability.

Only cookies/technologies in this category are active on this site.

4.2 Analytics / statistical cookies (active after consent)

These are used to collect information, in aggregate form, about the number of visitors and how they use the site.

• Under the Garante's Guidelines, analytics tools may be treated as technical cookies (and therefore not require consent) only if suitably anonymised — for example, by masking significant portions of the IP address, without cross-referencing other data and without transmission to third parties who use it for their own purposes.
• Analytics tools that are not anonymised, or comparable to profiling, require prior consent.

Two analytics tools operate on this site — Google Analytics 4 and Yandex Metrica. Both are non-anonymised and therefore require prior consent: their scripts load only after "Accept" is pressed. Declining does not restrict use of the site in any way. Further details in the Google and Yandex privacy policies.

4.3 Profiling / marketing cookies (currently NOT active)

These are used to build user profiles and deliver advertising in line with the user's preferences, including on other sites. They always require the user's prior, free, specific, and revocable consent.

No profiling or marketing cookie is active on this site (no Meta/Facebook pixel, no advertising platform, no remarketing). Analytics cookies are described in section 4.2.

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5. Cookies and technologies actually used on this site

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6. The banner and consent management

On entering the site, a short cookie notice may be shown. Because the site uses only technical/necessary tools, no cookie requiring consent is installed; the notice is for information purposes and the user's choice is recorded in the vf-consent entry.

In line with the Garante's Guidelines, should non-technical cookies be introduced in the future, the banner will:

• present the accept and reject buttons with equal prominence;
• allow the user to close it without giving consent (closing via the "X" is equivalent to refusal);
• not use "scroll" mechanisms or pre-ticked boxes as consent;
• allow a granular choice by category.

How to change or withdraw the choice. The user may change or withdraw their preferences at any time, as easily as they were given:

• by deleting the vf-consent entry and cookies via the browser settings (see § 7), which will cause the notice to reappear;
• or, where available, via the dedicated "Cookie preferences" link/panel on the site.

Withdrawal of consent does not affect the lawfulness of processing based on consent given before its withdrawal.

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7. Managing cookies in your browser

The user can manage, restrict, or disable cookies and clear local storage directly from their browser settings. Below are references to the official guides:

• Google Chrome: Settings → Privacy and security → Cookies and other site data
• Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
• Microsoft Edge: Settings → Cookies and site permissions
• Apple Safari: Preferences → Privacy
• Safari iOS / Chrome Android: Device settings → browser section

Disabling technical/necessary cookies may impair some site functions (e.g. remembering the language or the choice on the notice).

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8. Third-party services and providers

The site currently does not integrate any third-party services that install tracking cookies (no social plugins, no embedded maps, no third-party video embeds with tracking, no advertising platforms).

The only providers processing data on the Controller's behalf, as data processors, are:

• the hosting provider (VPS) — {{HOSTING_PROVIDER, e.g. Beget}} — which handles server access logs for technical and security purposes;
• the e-mail (SMTP) service used to deliver to the Controller the messages sent through the contact form.

These providers do not set tracking cookies through the site.

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9. Data transfers to countries outside the EU/EEA

The hosting infrastructure and/or the e-mail service may involve a transfer or processing of data outside the European Union / European Economic Area. In such cases, the Controller ensures that the transfer takes place in compliance with Arts. 44 et seq. of the GDPR, through appropriate safeguards pursuant to Art. 46 (e.g. Standard Contractual Clauses — SCCs approved by the European Commission) and/or any adequacy decisions.

Details and a copy of the applicable safeguards: {{TRANSFER_DETAILS_AND_SCC_SAFEGUARDS}}.

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10. Where to find the Privacy Policy

The processing of personal data collected through the site (in particular through the contact form: name, e-mail, project type, budget, timeline, message, and consent) is described in detail in the Privacy Policy, available on this site: {{PRIVACY_POLICY_URL}}.

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11. Data subject rights and complaints

The user may exercise at any time the rights set out in Arts. 15–22 of the GDPR (access, rectification, erasure, restriction, objection, portability) by writing to hello@visionflow.video.

If the user believes that the processing infringes the applicable law, they have the right to lodge a complaint with the competent supervisory authority:

• Garante per la protezione dei dati personali (Italian Data Protection Authority) — Piazza Venezia 11, 00187 Rome, Italy — www.garanteprivacy.it

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12. Changes to this Cookie Policy

The Controller reserves the right to update this Cookie Policy to reflect legal or technical changes (for example, the possible introduction of new tools). Changes will be published on this page together with the last updated date. If non-technical cookies are introduced, prior consent will be requested before they are activated.

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13. Contact

For any request concerning cookies and personal data:

• VisionFlow — {{LEGAL_NAME}}
• E-mail: hello@visionflow.video
• {{REGISTERED_ADDRESS}} — Milan, Italy