Privacy Policy
This Privacy Policy explains how SOTTILE SRL collects, uses, and shares information when you visit this website or interact with our wellness education services. Our company is registered in Italy and provides structured wellness education for participants located across Canada. We use plain, transparent language and avoid medical claims or health promises. If you have questions, contact us using the details in the Contact section below.
Effective Date: January 15, 2026 • Last Updated: January 15, 2026
Who We Are
Legal entity: SOTTILE SRL
Registered office: Viale Cassala, 30, Navigli District, 20143 Milano, Italy
Primary contact email: [email protected]
Phone: +39 02 8342 7610
Service scope: educational programs delivered online to participants across Canada. We do not offer medical services, diagnosis, or therapy.
1) Cookie Categories 🍪
Cookies are small files stored on your device. We use them to operate the site, measure performance, and deliver advertising where consent is given. We group cookies into exactly three categories:
Essential Cookies
Purpose: core site functionality, security, and session management. Examples: session_id, csrf_token, cookie_consent_status. Consent required: no. Retention: session duration or up to 12 months for preference storage.
Analytics Cookies
Purpose: measuring traffic, user behavior, and site performance using Google Analytics 4. Examples: _ga, _ga_XXXXXXX, _gid, _gat. Consent required: yes. Retention: up to 14 months.
Marketing / Advertising Cookies
Purpose: remarketing, personalized ad delivery, and conversion tracking. Consent required: yes. Retention: up to 540 days (Google Ads default).
2) Marketing Cookies — Required Sub-Disclosures
a) 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."
b) 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."
c) 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."
d) YouTube and Display Network: "Advertisements may appear across Google services including YouTube, Gmail, and the Google Display Network."
e) Tracking technologies — list all that apply: "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"
f) Advertising measurement: "We use conversion tracking to understand which advertisements lead to actions on our website — such as form submissions, calls, or purchases. This allows us to measure campaign effectiveness and allocate budget appropriately. Conversion data may be shared with Google Ads and Meta."
g) Technologies in use — list explicitly: "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)"
h) Opt-out from personalized advertising
You may opt out of personalized advertising at any time using the following industry tools. These addresses are provided for your convenience:
- 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 ads.
i) Cookie preference management: Manage cookie preferences to accept or reject Analytics and Marketing categories at any time.
3) Consent Requirements
Consent banner: Our banner offers three choices: "Accept All", "Reject Non-Essential", and "Manage Preferences". Analytics and marketing cookies remain off until you accept. Your choice is stored in localStorage for 12 months. You can dismiss the banner without accepting. A link to this page appears on the banner.
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."
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."
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."
4) Data Sharing with Advertising Partners
We share certain data with advertising partners for campaign delivery and measurement. Recipients and categories 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. Transfers to Google and Meta may rely on Standard Contractual Clauses where applicable. Data is processed for ad targeting and measurement only and is not resold to unaffiliated third parties. Google and Meta may use the data across their platforms under their policies.
5) 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.
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.
6) Google Services and Advertising
This website uses the following Google services:
- Google Analytics 4: collects anonymized usage data, device info, 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 after clicking one of our ads. Used only for measuring campaign performance.
- Google Remarketing: allows us to show ads to previous visitors across Google's network. Remarketing lists are not created from sensitive categories.
- Google Tag Manager: deploys tracking tags. GTM does not collect personal data on its own.
Google's advertising products are governed by: https://policies.google.com/technologies/ads
7) Meta Advertising Services
This website uses the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram. The pixel may record page views, time on site, conversion events such as form submissions, and custom audience membership for retargeting.
We do not use the Meta Pixel to collect sensitive personal data or to target users based on special-category attributes. Meta acts as an independent data controller for pixel-derived data processed on its platforms.
Refer to Meta's Data Policy: https://www.facebook.com/privacy/policy. Manage your ad preferences on Meta platforms: https://www.facebook.com/adpreferences/
8) Prohibited Content Self-Declaration
This website does not promote or sell prohibited product or service categories including weapons, controlled substances, counterfeit goods, unlicensed gambling, or adult content. We do not make misleading health or financial claims. All advertising through Google Ads and Meta Ads follows their policies.
9) Landing Page Integrity Statement
The content of this website accurately represents the programs and services we promote. There is no bait-and-switch. Users who arrive from paid advertisements see the same content as all other visitors. We do not use cloaking, automatic redirects, or content changes by traffic source.
10) 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 learn that data was collected from someone under 16 without verifiable parental consent, we will delete it promptly. Contact us if you believe a minor has provided data.
11) 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 may rely on Standard Contractual Clauses approved by the European Commission. You can request a copy by contacting us.
12) Your Rights (GDPR Articles 15 to 22)
If you are located in the EEA or UK, you can exercise the following rights:
- Access: request a copy of data we hold about you.
- Rectification: correct inaccurate or incomplete data.
- Erasure: request deletion where applicable.
- Restriction: limit how we process your data.
- Portability: receive your data in a machine-readable format.
- Objection: object to processing based on legitimate interest.
- Withdraw consent: revoke consent at any time without penalty.
To exercise a right, email us at [email protected]. We respond within 30 days. Supervisory authorities: EU users may visit https://edpb.europa.eu and UK users may visit https://ico.org.uk for guidance or to lodge a complaint.
13) What Data We Collect
- Full name
- Email address
- Phone number
- IP address
- Browser type and version
- Device type and operating system
- Cookies and tracking identifiers
- Usage data such as pages visited, time on site, and click paths
- Form submission content
- Conversion events such as form submissions, calls, or purchases
14) Legal Basis for Processing
Contact form data: consent (Art. 6.1.a) and contract performance (Art. 6.1.b).
Analytics data: consent (Art. 6.1.a).
Marketing and remarketing data: consent (Art. 6.1.a).
Security and fraud prevention: legitimate interest (Art. 6.1.f).
15) Retention Periods
- Contact form submissions: 2 years
- Analytics data (GA4): 14 months
- Marketing cookies (Google Ads): up to 540 days
- Email communications: duration of relationship plus 1 year
- Server logs: 90 days
- Cookie consent records: 3 years for audit purposes
16) Policy Metadata
Last Updated: January 15, 2026
Effective Date: January 15, 2026
We will notify users of material changes via a homepage banner at least 14 days before the update takes effect.
Security and Storage
We apply reasonable technical and organizational measures to protect data against unauthorized access, accidental loss, or misuse. Access to personal data is limited to personnel and service providers who need it to operate the site and deliver requested services. While no method is perfectly secure, we work to maintain a safe environment for visitors and learners.
Contact and Complaints
Data controller: SOTTILE SRL
Registered office: Viale Cassala, 30, Navigli District, 20143 Milano, Italy
Email: [email protected] • Phone: +39 02 8342 7610
For any privacy questions, requests, or complaints, contact us by email. If we cannot resolve your concern, you may contact your local data protection authority as listed above.
Scope Clarification and Educational Nature
Our website and programs are educational. We do not provide medical advice, diagnosis, treatment, therapy, or psychological services. Any routines or practices discussed are general education. Always follow professional guidance from licensed practitioners for health questions. Use of our site is voluntary. Your participation, pace, and personal decisions remain your responsibility.