Privacy Policy

1. Who We Are

Massimo Dallaglio S.r.l. is the data controller responsible for your personal data. We are a photography education provider based in Italy, offering structured online courses to participants throughout Canada.

Legal Entity: Massimo Dallaglio S.r.l.
Registered Address: Via Modena, 16, 20090 Buccinasco, Milano, Italy
Contact Email: [email protected]
Phone: +39 02 4879 3624

2. Cookie Categories

This website uses cookies to improve functionality, measure performance, and deliver personalized advertising. Cookies are divided into three categories:

2.1 Essential Cookies

Purpose: Core site functionality, security, session management, and storing your cookie consent preferences.

Examples: session_id, csrf_token, cookie_consent_status

Consent Required: No. Essential cookies are activated automatically and cannot be disabled as they are necessary for the website to function properly.

Retention: Session duration or up to 12 months for preference storage.

2.2 Analytics Cookies

Purpose: Measuring traffic, user behavior, site performance, and understanding how visitors interact with our website.

Tools Used: Google Analytics 4

Examples: _ga, _ga_XXXXXXX, _gid, _gat

Consent Required: Yes. Analytics cookies are activated only after you accept them through the cookie consent banner.

Retention: Up to 14 months.

2.3 Marketing and Advertising Cookies

Purpose: Remarketing, personalized ad delivery, conversion tracking, and measuring the effectiveness of our advertising campaigns.

Consent Required: Yes. Marketing cookies are activated only after you accept them through the cookie consent banner.

Retention: Up to 540 days (Google Ads default retention period).

3. Marketing Cookies — Detailed Disclosures

This section provides comprehensive information about how we use marketing and advertising cookies, in full compliance with advertising platform policies and privacy regulations.

3.1 Third-Party Ad Serving

Third-party vendors, including Google, use cookies to serve ads based on a user's previous visits to this website and other sites on the internet. This allows us to show relevant advertisements to people who have expressed interest in photography education.

3.2 Advertising Partners

We may work with advertising partners such as Google and Meta to deliver advertisements tailored to your interests across various websites and platforms. These partners use cookies and similar technologies to recognize your device and deliver personalized ad experiences.

3.3 Remarketing

We may use remarketing services to advertise to previous visitors of our website. After visiting our site, you may see our ads on other websites, apps, or platforms you visit. This helps us stay connected with potential learners who have shown interest in our photography courses.

3.4 YouTube and Display Network

Advertisements may appear across Google services including YouTube, Gmail, and the Google Display Network. These ads may be shown to users who have previously visited our website or who match audience profiles similar to our existing learners.

3.5 Tracking Technologies

We use the following tracking technologies on this website:

• Cookies (first-party and third-party)
• Tracking pixels (Google Ads tag / gtag.js, Meta Pixel)
• Device identifiers (browser fingerprint, IP address)
• Conversion event tags

3.6 Advertising Measurement

We use conversion tracking to understand which advertisements lead to actions on our website — such as form submissions, calls, or course inquiries. This allows us to measure campaign effectiveness and allocate our advertising budget appropriately. Conversion data may be shared with Google Ads and Meta to optimize ad delivery and reporting.

3.7 Technologies in Use

Advertising and analytics technologies active on this site:

• Google Ads (gtag.js / Google Tag Manager)
• Google Analytics 4
• Google Remarketing Tag
• Meta Pixel (Facebook / Instagram)

3.8 Opt-Out from Personalized Advertising

You may opt out of personalized advertising at any time through the following channels:

• Google Ads Settings: https://adssettings.google.com
• Your Online Choices (EU): https://www.youronlinechoices.eu
• Network Advertising Initiative: https://optout.networkadvertising.org
• Digital Advertising Alliance: https://optout.aboutads.info

Opting out does not remove ads entirely — you will continue to see non-personalized advertisements that are not based on your browsing history or interests.

3.9 Cookie Preference Management

You can manage your cookie preferences at any time by clicking the "Manage Cookie Preferences" link in the website footer or by accessing the cookie consent panel. This allows you to accept or reject each category of cookies independently. Essential cookies remain active at all times as they are necessary for the website to function.

4. Consent Requirements

4.1 Cookie Consent Banner

When you first visit our website, you will see a cookie consent banner that provides three options:

• Accept All Cookies: Activates all cookie categories including analytics and marketing.
• Reject Non-Essential: Activates only essential cookies required for basic functionality.
• Manage Preferences: Opens a detailed panel where you can select which cookie categories to accept.

Analytics and marketing cookies are NOT activated until you explicitly accept them. The banner includes a direct link to this Privacy Policy so you can review our data practices before making a decision.

4.2 Consent Statement

By clicking "Accept All Cookies", you consent to the storing of cookies on your device for analytics and advertising purposes, including personalized advertising delivered by Google and Meta. You may withdraw consent at any time through the cookie preferences panel without affecting the lawfulness of processing that occurred before withdrawal.

4.3 EEA and UK Users

Users in the European Economic Area and the United Kingdom receive this consent notice in compliance with the General Data Protection Regulation (GDPR) and UK GDPR. Marketing and analytics cookies are activated solely after explicit, informed, freely given consent under GDPR Article 6(1)(a). Consent is recorded with a timestamp and may be audited upon request.

4.4 Withdrawal of Consent

You may withdraw consent at any time by clicking "Manage Cookie Preferences" in the website footer, or by clearing cookies via your browser settings. Withdrawal does not affect processing that occurred while consent was valid. After withdrawing consent, only essential cookies will remain active on your device.

5. Data Sharing with Advertising Partners

We share certain data with advertising partners for campaign delivery and measurement. Recipients and the data categories shared include:

• Google LLC: Cookie identifiers, conversion events, anonymized behavioral data, remarketing lists. Governed by Google's Privacy Policy: https://policies.google.com/privacy
• Meta Platforms, Inc.: Pixel events, conversion data, custom audiences. Governed by Meta's Data Policy: https://www.facebook.com/privacy/policy

We do not sell personal data. All transfers to Google and Meta operate under Standard Contractual Clauses where applicable. Data is processed for ad targeting and campaign measurement only — not resold to unaffiliated third parties.

Google and Meta may use this data across their own platforms in accordance with their respective policies. We encourage users to review those policies directly.

6. Lead Forms and Contact Requests

When you submit a contact form, request a quote, or register interest in our services, we collect the information you provide. This typically includes: full name, email address, phone number, and your message or inquiry.

Legal Basis: Consent (GDPR Art. 6.1.a) and, where a service relationship exists, performance of a contract (GDPR Art. 6.1.b).

Retention: Form submission data is retained for up to 2 years from the date of submission, unless a longer period is required by applicable law.

You may request deletion of your data at any time by contacting us at [email protected].

A link to this Privacy Policy appears adjacent to every submission button on this site. Submitting a form constitutes acknowledgment of this policy.

7. Google Services — Full Disclosure

This website uses the following Google services:

• Google Analytics 4: Collects anonymized usage data, device information, and behavioral signals. IP anonymization is enabled. Data retention is set to 14 months. Users may opt out via the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout
• Google Ads Conversion Tracking: Records when a user completes a defined action (form submission, call, inquiry) after clicking one of our ads. This data is used solely for measuring ad campaign performance.
• Google Remarketing: Allows us to show ads to previous visitors across Google's network. Remarketing lists are not created from sensitive data categories (health, finance, religion, sexual orientation).
• Google Tag Manager: Deploys tracking tags on our behalf. No personal data is collected by GTM itself; it acts as a container for the tags listed above.

Google's advertising products are governed by: https://policies.google.com/technologies/ads

8. Meta Advertising Services — Full Disclosure

This website uses the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram. The pixel may record:

• Page views and time on site
• Specific conversion events (form submissions, inquiries)
• Custom audience membership for retargeting purposes

We do not use the Meta Pixel to collect sensitive personal data, nor to target users based on health status, financial situation, religion, political views, sexual orientation, or any other special-category attribute prohibited under Meta's advertising policies.

Meta acts as an independent data controller for data collected via its Pixel and processed within its own platform. Refer to Meta's Data Policy: https://www.facebook.com/privacy/policy

To manage your ad preferences on Meta platforms, visit: https://www.facebook.com/adpreferences/

9. Prohibited Content Self-Declaration

This website does not promote, sell, or facilitate access to prohibited product or service categories including but not limited to: weapons, controlled substances, counterfeit goods, gambling services (unlicensed), adult content, or services that make misleading health or financial claims. All advertising conducted through Google Ads and Meta Ads complies with the respective platform policies in full.

10. Landing Page Integrity Statement

The content of this website accurately represents the products and services advertised. No bait-and-switch practices are employed. The experience delivered to users arriving from paid advertisements is identical to the experience for all other visitors. Cloaking, automatic redirects, and content variation by traffic source are not used on this website.

11. Children's Privacy

This website is not directed at individuals under the age of 16. We do not knowingly collect personal data from minors. If we discover that data has been collected from a person under 16 without verifiable parental consent, we will delete it promptly. Contact us at [email protected] if you believe we have received data from a minor.

12. International Data Transfers

Personal data collected through this website may be transferred to and processed in countries outside the European Economic Area, including the United States, where Google LLC and Meta Platforms, Inc. are based.

These transfers are conducted under Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for personal data. A copy of the applicable SCCs can be requested by contacting us directly at [email protected].

13. User Rights (GDPR Articles 15-22)

If you are located in the EEA or UK, you have the following rights:

• Access (Art. 15): Request a copy of data we hold about you
• Rectification (Art. 16): Correct inaccurate or incomplete data
• Erasure (Art. 17): Request deletion (right to be forgotten)
• Restriction (Art. 18): Limit how we process your data
• Portability (Art. 20): Receive your data in a structured, machine-readable format
• Objection (Art. 21): Object to processing based on legitimate interest
• Withdraw Consent (Art. 7.3): Revoke consent at any time without penalty

To exercise any right, email us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with your local supervisory authority:

• EU users: https://edpb.europa.eu
• UK users: https://ico.org.uk

14. What Data We Collect

We collect the following types of personal data:

• Full name
• Email address
• Phone number
• IP address
• Browser type and version
• Device type and operating system
• Cookies and tracking identifiers
• Usage data (pages visited, time on site, click paths)
• Form submission content
• Conversion events (form submits, calls, inquiries)

15. Legal Basis for Processing (GDPR Art. 6)

For each data type, we process your personal data based on the following legal grounds:

• Contact form data: Consent (Art. 6.1.a) and contract performance (Art. 6.1.b)
• Analytics data: Consent (Art. 6.1.a)
• Marketing/remarketing data: Consent (Art. 6.1.a)
• Security and fraud prevention: Legitimate interest (Art. 6.1.f)

16. Retention Periods

We retain personal data for the following periods:

• Contact form submissions: 2 years
• Analytics data (GA4): 14 months
• Marketing cookies (Google Ads): Up to 540 days
• Email communications: Duration of relationship + 1 year
• Server logs: 90 days
• Cookie consent records: 3 years (audit requirement)

17. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Changes will be notified via a homepage banner at least 14 days before they take effect. The "Last Updated" date at the top of this page indicates when the policy was last revised.

18. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

Massimo Dallaglio S.r.l.
Via Modena, 16
20090 Buccinasco, Milano
Italy

Email: [email protected]

Phone: +39 02 4879 3624