Cookie Policy
This Cookie Policy explains how the nuvami.it website (the «site») uses cookies and similar technologies: which cookies are set, for what purposes and durations, on what legal bases, and how you can manage or withdraw your choices. It is provided under Art. 122 of the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended), Regulation (EU) 2016/679 (the «GDPR»), and the cookie guidelines of the Italian Data Protection Authority (Garante) (decision of 10 June 2021, no. 231). For completeness, §5 also describes a mechanism that uses no cookies: the campaign labels in App Store links.
1. What this Cookie Policy is
A cookie is set only after your browser requests a page of the site. This Cookie Policy tells you which cookies we use and puts you fully in control of the non-essential ones: on the site the third-party analytics cookies are activated only if you consent, and you can change your mind at any time (see §7).
The data controller for the data collected through the site is Aleksei Konoplia (a natural person), the developer of Nuvami. For any request about your data or to exercise your rights, contact privacy@nuvami.it. No Data Protection Officer (DPO) has been appointed, as one is not required under Art. 37 GDPR; the address above is the single contact point for privacy matters. For the processing of app data (account, pet health data, in-app advertising, product analytics) the Privacy Policy applies.
2. What cookies are
Cookies are small text files that the sites you visit send to your device, where they are stored and sent back to those same sites on your next visit. Alongside cookies, similar technologies (e.g. identifiers stored by the browser) may be used in the same way. They are classified:
- by purpose: technical cookies — necessary for the site to work or for a feature you explicitly requested — and analytics/profiling cookies, which require your consent;
- by party: first-party, set by
nuvami.it, and third-party, set by a different domain (in our case Google); - by duration: session cookies, deleted when you close the browser, and persistent cookies, which remain until the stated expiry or until you remove them.
The site uses no advertising profiling cookies and shows no advertising.
3. Technical and functional cookies (no consent)
These cookies are first-party and technical or functional in nature. Under Art. 122 of the Code they do not require your consent, as they are strictly necessary to deliver the service or functional in remembering an interface choice of yours (e.g. the language you chose or having dismissed a prompt). They are always set.
| Name | Purpose | Duration | Category |
|---|---|---|---|
nuvami_cookie_consent | Stores your cookie choice (accepted / rejected) | 1 year | Technical (necessary) |
nuvami_lang | Remembers the language you chose for the site | 1 year | Functional / preferences |
nuvami_lang_prompt | Remembers that you dismissed the language-switch prompt | 1 year | Functional / preferences |
The nuvami_cookie_consent cookie exists precisely to remember your decision about analytics cookies: for this reason it is exempt from consent and is set even if you reject analytics.
4. Third-party analytics cookies — Google Analytics 4 (with consent)
To understand how the site is used, we collect aggregate statistics via Google Analytics 4 (GA4), a third-party tool provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), with possible processing by Google LLC (USA). Measurement ID: G-GKXG82E41K. For this analytics, Google acts as a processor on our behalf, under Google's Data Processing Terms.
Technically, the _ga and _ga_GKXG82E41K cookies are first-party (set on the nuvami.it domain), but we treat them here as consent-based cookies because they serve the analytics purpose of a third party (Google), which receives and processes the data: they therefore still require your consent under Art. 122.
How consent works (prior blocking). GA4 cookies are set and the Google Analytics script is loaded only after your explicit consent («Accept» in the banner). Before your choice, or if you choose «Reject», no analytics cookie is set and the GA script is not loaded. The banner complies with the Garante's guidelines: the «Accept» and «Reject» buttons carry equal weight, there are no pre-ticked boxes, scrolling the page does not amount to consent, and there are no cookie walls — you can browse the site even if you reject. Your choice is saved in the technical nuvami_cookie_consent cookie (see §3).
| Name | Provider | Purpose | Duration | Category |
|---|---|---|---|---|
_ga | Distinguishes users (statistical client identifier) | 2 years | Analytics / statistics | |
_ga_GKXG82E41K | Maintains the session state for GA4 | 2 years | Analytics / statistics |
Characteristics of this analytics processing:
- Aggregate statistics only: we measure page views, traffic sources, scrolling and clicks on the App Store buttons. No advertising, no profiling, no «Google Signals» and no cross-device tracking are enabled.
- No IP storage: GA4 does not record or retain your IP address; it is used transiently only for approximate geolocation and then discarded.
- Data retention in GA4: 14 months.
- Transfer outside the EU (USA): data may also be processed in the United States on the basis of appropriate safeguards — the EU-US Data Privacy Framework, to which Google is certified, and, additionally, the Standard Contractual Clauses (SCC) (see §8).
- Legal basis: your consent (Art. 122 of the Code and Art. 6(1)(a) GDPR).
For how Google processes this data, see Google's Privacy Policy and how Google uses data.
5. App Store links and campaign attribution (no cookies)
The buttons that lead to the App Store from the site's presentation pages (the home page and its language versions) carry two campaign labels in the link address — pt (the code Apple assigns to us as the developer, which appears in all our campaign links) and ct (the campaign name: it says which of our materials a click came from; from the buttons on these pages it is currently always web) — plus the technical parameter mt, which is part of the link format Apple generates. These are not cookies and not personal identifiers: they describe the link you clicked, not you. The labels themselves neither read nor store anything on your device: they only travel in the address your browser opens.
What they are for. These labels let Apple give us aggregate per-campaign statistics only — for example how many app installs come from the website. We receive no individual data and cannot trace it back to a person; moreover, as stated by Apple, these statistics cover only users who, in their device settings, have agreed to share data with developers.
This mechanism works regardless of your cookie choice, precisely because it uses no cookies: the label travels in the link address at the moment you open it. If you prefer not to send it, you can search for «Nuvami» directly in the App Store instead of using the buttons on the site. The click on the button may also be counted by Google Analytics 4, but only if you have consented: that is a separate, cookie-based processing, described in §4.
From the moment you open the link, your data is processed by Apple as an independent controller, under Apple's Privacy Policy.
6. Legal basis
- Technical and functional cookies (§3): no consent required. They are exempt under Art. 122 of the Code, being strictly necessary to deliver the service or to provide a feature you explicitly requested (Art. 6(1)(f) GDPR as a legitimate interest in the site's operation, where relevant).
- Third-party analytics cookies — GA4 (§4): consent (Art. 122 of the Code and Art. 6(1)(a) GDPR), which can be withdrawn at any time as easily as it was given.
- Campaign labels in App Store links (§5): they are fixed values written into the link address, identical for every visitor; they are not cookies and, on our side, they involve neither storing information on your device nor accessing information already stored there. We therefore consider that Art. 122 of the Code does not apply. From Apple we receive aggregate statistics only: for this purpose we do not process data that could identify you.
7. How to manage or withdraw consent
You can change or withdraw your consent to analytics cookies at any time:
- «Cookie» button in the site footer: you will find it at the bottom of the site's pages; clicking it reopens the banner so you can change your choice. On withdrawal, analytics cookies stop being set.
- Browser settings: you can block or delete existing cookies from your browser's settings (in the Chrome, Safari, Firefox and Edge guides under «cookies» or «privacy»). Deleting
nuvami_cookie_consentwill cause the banner to be shown again on your next visit. - Disabling Google Analytics: you can install the Google Analytics opt-out browser add-on provided by Google.
Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
8. Transfers outside the EU
The technical and functional cookies (§3) are first-party and involve no transfers. Data collected via Google Analytics 4 (§4) may also be processed by Google outside the European Union, in particular in the United States. Where this happens, the transfer is based on appropriate GDPR safeguards: the EU-US Data Privacy Framework — to which Google is certified — and, additionally, the Standard Contractual Clauses (SCC) approved by the European Commission. For details see Google's Privacy Policy.
9. Your rights
Under Arts. 15–22 GDPR you have the right to access your data, to have it rectified or erased, to restrict processing, to object to processing and to data portability, as well as to withdraw at any time the consent you gave (Art. 7 GDPR), without this affecting the lawfulness of processing prior to the withdrawal.
To exercise these rights, write to privacy@nuvami.it. For data collected via Google Analytics you may also contact Google, following its Privacy Policy.
10. Complaint to the Garante
If you believe the processing of your data through cookies infringes the GDPR or applicable law, you may contact us (privacy@nuvami.it) and you have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or with the supervisory authority of your country of residence.
11. Changes to this Cookie Policy
We may update this Cookie Policy, for example if the cookies used or their purposes change. The current version is always published at this address, with the «last updated» date at the top. For changes that affect consent-based cookies, we will ask for your consent again through the banner. Your choice is valid for 12 months: within that period we will not show the banner again, unless you delete the cookie or the cookies used change.