1. Introduction and data controller
The website Convergo – www.convergo.it uses technical cookies, which are necessary for the operation and security of the site, and, only if the user gives consent, Google Analytics statistics cookies. It does not use profiling or marketing cookies.
This Cookie Policy is drawn up pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR), Article 122 of Legislative Decree 196/2003 (Italian Privacy Code) and the Italian Data Protection Authority’s cookie guidelines of 10 June 2021.
Data controller: GBSAPRI S.p.A. a Socio Unico, with registered office at Viale Erminio Spalla 9, 00142 Rome, VAT no. 18242091009, Tax Code 12079170150, email dpo@convergo.it.
2. What cookies are
Cookies are small text files that the websites you visit save on your device so that they can be read again on later visits. They fall into three broad categories:
- Technical cookies: they are used to make the site work, to ensure its security or to provide a service requested by the user. They do not require consent.
- Statistics cookies: they are used to understand how the site is used, for example which pages are visited and for how long. They require the user’s prior consent.
- Profiling and marketing cookies: they are used to track browsing and to build profiles in order to send targeted advertising. They require the user’s prior consent.
Cookies may be “first-party”, if set by the site being visited, or “third-party”, if set by other domains.
3. Cookies used by this site
The site uses two technical cookies and, only with the user’s consent, two Google Analytics statistics cookies. The first technical cookie, __cf_bm, is set by Cloudflare through the site’s hosting infrastructure (Kinsta) and through the service that provides the accessibility tool (Elementor). It is used to distinguish human visitors from automated bots and to protect the site from malicious traffic. The second, cookiez-user-consent, remembers the choice made by the user in the cookie banner, so that the banner is not shown again at every visit. The two statistics cookies, _ga and _ga_RPPZG5CB3G, are set by Google Analytics (a service of Google Ireland Limited) and are used to measure, in aggregate form, how the site is used. They are installed only after the “Statistics” category is accepted in the cookie banner.
| Name | Domain | Type | Purpose | Duration |
|---|---|---|---|---|
| __cf_bm | convergo.it, .convergo.it | Technical, third party | Security: bot management (Cloudflare Bot Management) | 30 minutes |
| __cf_bm | elementor.com, .elementor.com | Technical, third party | Security: bot management (Cloudflare Bot Management) | 30 minutes |
| cookiez-user-consent | convergo.it | Technical, first party | Preferences: remembers the choice made in the cookie banner | 6 months |
| _ga | .convergo.it | Statistics, third party (Google) | Statistics: tells visitors apart in a pseudonymous way, to count visits and users | 2 years (the Chrome browser limits it to 400 days) |
| _ga_RPPZG5CB3G | .convergo.it | Statistics, third party (Google) | Statistics: remembers the state of the browsing session | 2 years (the Chrome browser limits it to 400 days) |
The __cf_bm cookie contains an encrypted identifier associated with the session. It is not used to track the user across different sites or for advertising purposes, and it is deleted automatically after 30 minutes.
The cookiez-user-consent cookie contains the choice made in the banner and a random code identifying that choice. It is not used to track the user or for advertising purposes, and it is deleted after 6 months or when the user clears cookies from their browser.
The _ga and _ga_RPPZG5CB3G cookies contain random codes that identify the browser, not the user’s name or e-mail address. The information collected is sent to Google and used only to produce statistics on how the site is used. Google Analytics does not record or keep IP addresses; Google Signals and the collection of user-provided data are switched off, and the site is not linked to Google Ads. User-level and event-level data are kept for 14 months and then deleted automatically.
4. Legal basis and consent
For technical cookies, the user’s consent is not required (Article 122(1) of the Italian Privacy Code). The legal basis is the Controller’s legitimate interest in ensuring the security and proper functioning of the site (Article 6(1)(f) GDPR).
For Google Analytics statistics cookies, the legal basis is the user’s consent (Article 6(1)(a) GDPR and Article 122 of the Italian Privacy Code), collected through the cookie banner. Until the user accepts, the cookies are not installed and Google receives no data. Users may refuse with no consequence for their use of the site, and may withdraw or change their consent at any time from “Cookie preferences”, the cookie-shaped icon at the bottom right of every page.
If in the future the site introduces profiling cookies or marketing cookies, these will be installed only after obtaining consent through the cookie banner, and this notice will be updated.
5. Third parties and data transfers
The __cf_bm cookie is managed by Cloudflare, Inc. (USA), the provider of the content delivery and security network used by the site’s hosting. Cloudflare adheres to the EU-U.S. Data Privacy Framework, which constitutes an adequate safeguard for the transfer of data to the United States.
The statistics cookies are managed by Google Ireland Limited (Gordon House, Barrow Street, Dublin, Ireland), which may transfer data to Google LLC in the United States. Google LLC adheres to the EU-U.S. Data Privacy Framework, which constitutes an adequate safeguard for the transfer of data to the United States.
For more information:
- Cloudflare privacy policy
- Cloudflare cookies
- Elementor privacy policy
- Google privacy policy
- How Google Analytics safeguards data
6. How to manage or disable cookies
Statistics cookies are managed from “Cookie preferences”, the cookie-shaped icon at the bottom right of every page: from there users can accept or refuse them, or change their choice whenever they wish. Google also provides a browser add-on to switch off Google Analytics on all sites.
Users can block or delete cookies from their browser settings. However, disabling technical cookies may prevent access to the site or its proper functioning, for example by triggering anti-bot checks.
7. Rights of the data subject
Users may at any time exercise the rights provided for in Articles 15-22 GDPR: access, rectification, erasure, restriction, objection to processing and data portability. Requests must be sent to privacy@convergo.it.
Users also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).
For information on other data processing carried out through the site, please refer to the Privacy Policy.
8. Updates
This Cookie Policy may be amended following changes to the site or to the legislation. The date of the last update is shown at the top of the document.