Cookie Policy

1 – Information about the website’s cookie policy 

  1. This section contains information relating to the cookie policy of the website, owned by Alf Investment Strategy BV, with regard to the use of cookies by the user. 
    2. This document is an integral part of the Privacy Policy of the website and the information it contains to interested parties pursuant to the General Data Protection Regulation, EU Regulation No. 679/2016, the Personal Data Protection Code, D.Lgs. of 30 June 1993, n. 196 e s.m.i., and the “Cookie Guidelines and other tracking tools – 10 June 2021”, G.U. n. 163 of 9 July 2021. 
    3. The information is provided exclusively for the cookies present within the site and not for cookies on external sites reachable through links within the site itself. 
    4.The cookie policy may be periodically updated, so it is advisable to consult this document every time you access the site, in order to be properly informed about how and why cookies are used. 

2 – Data controller 
1. The controller shall be the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data. He also handles security profiles. 
2. With regard to this website, the data controller is: Alf Investment Strategy BV, and for any clarification or exercise of your rights, you can contact him at the following email address: 

3 – Cookies 
1. The use of cookies takes place in compliance with the relevant European legislation (Directive 2009/136/EC amended Directive 2002/58/EC “E Privacy) and national (Provision Guarantor for the protection of personal data 8 May 2014 and subsequent clarifications as well as Cookie Guidelines and other tracking tools of 10 June 2021 n.231). 

4 – Types of Cookies 
1. The website uses cookies to make the user’s browsing experience easier and more intuitive: cookies are small strings of text used to store certain information that may concern the user, its preferences or the Internet access device (computer, tablet or mobile phone) and are mainly used to adapt the operation of the site to user expectations, offering a more personalized browsing experience and memorizing the choices made previously. 
2. A cookie consists of a reduced set of data transferred to the user’s browser from a web server and can only be read by the server that made the transfer. It is not executable code and does not transmit viruses. 
3. Cookies do not record any personal information and any identifiable data will not be stored. If you wish, you can prevent the storage of some or all cookies. However, in this case the use of the site and the services offered may be compromised. To proceed without changing the options related to cookies, simply continue browsing. 
4. This website may use, even in combination with each other, the following types of cookies classified according to the indications of the Data Protection Authority and the opinions issued in the European context by the Working Group pursuant to art. 29 of the GDPR: 
• Session, are cookies that are not stored persistently on the user’s computer and are deleted when the browser is closed, are strictly limited to the transmission of session identifiers necessary to allow the safe and efficient exploration of the site avoiding the use of other computer techniques potentially detrimental to the confidentiality of users’ navigation. 
• Persistent cookies are cookies that remain stored on your computer’s hard drive until they expire or are deleted by users/visitors. Through persistent cookies, visitors who access the site (or any other users who use the same computer) are automatically recognized with each visit. Visitors can set their computer’s browser to accept/reject all cookies or display a warning whenever a cookie is proposed, in order to be able to decide whether or not to accept it. The user can, however, change the default configuration and disable cookies (ie block them permanently), setting the highest level of protection. 
• Technical, are the cookies used to authenticate, to take advantage of multimedia content such as flash player or to allow the choice of the language of navigation. In general, it is therefore not necessary to obtain the prior and informed consent of the user. This also includes cookies used to analyze statistically the accesses/ visits to the site only if used exclusively for statistical purposes and through the collection of information in aggregate form. 
• Profiling and marketing cookies. Their use on users’ terminals is prohibited if they have not been properly informed beforehand and have not given a valid consent in accordance with the opt-in technique. These types of cookies are, in turn, grouped according to the functions they perform in: 
a) Analitycs. are cookies used to collect and analyse statistical information on visits/visits to the website. In some cases, associated with other information such as credentials entered for access to restricted areas (your email address and password), can be used to profile the user (personal habits, sites visited, content downloaded, types of interactions made, etc. ). 
b) Widgets fall into this category all those graphic components of a user interface of a program, which is intended to facilitate the user in interaction with the program itself. By way of example are widgets cookies facebook, twitter. 
c) Advertsing, this category includes cookies used to advertise within a site. Google, Tradedoubler fall into this category. 

5 – Technical cookies 
1. Technical cookies are those used for the sole purpose of “to transmit a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide that service” (cf. art. 122, paragraph 1, of the Privacy Code). 
2. Technical cookies do not require the prior consent of the user. They are used to enable the operation of the site and/or to provide the User with a service or function that the User has expressly requested. Cookies guarantee, therefore, the normal navigation and use of the Sites, allowing, also, to save the preferences expressed by the User and to optimize, thus, its navigation. The Sites use technical cookies both before and third party. 
3. The technical cookies actually used by the site, or that could be used by the site, are divided into: 
• “user input” cookies: session cookies used to keep track of the data provided by the user by filling in the appropriate online forms (for example, the forms present during the purchase process for entering the shipping or billing address) or, as in the case of the shopping cart, to remember the items that the user has selected and placed in the cart, by clicking on the appropriate button; 
• authentication cookies: cookies used to identify the user after logging in and allow him to authenticate himself and access the content and/or functionality for which this log-in is necessary (eg: purchase, access to the Personal Area); 
• other functionality cookies: cookies that serve to activate specific functionality of the Sites and to store the choices made by the User regarding the display of the pages of the Sites; 
• “Cookie Consent”: cookie that documents the manifestation of the User’s consent to the installation of profiling cookies through the fulfillment of one of the actions described in the banner/ short information, recognizes the User at the second access to the site so as not to ask again for consent to the installation of cookies and has a duration of 12 months. 

6 – Third party cookies 
1. In relation to the origin, the cookies sent to the browser directly from the site you are visiting and those of third parties sent to the computer from other sites and not from the one you are visiting. 
2. Permanent cookies are often third-party cookies. Most third-party cookies consist of tracking cookies used to identify online behavior, understand interests and then customize advertising proposals for users. 

7 – Analytical cookies 
1. Analytical cookies shall be used to collect statistical information, whether aggregated or not, on the number of users accessing a service. 
2. Analytical cookies are developed directly by and are used to collect aggregate information for analysis purposes for the site itself. 
3. This type of cookies does not require the prior consent of the user as it can be assimilated to technical cookies. 

8 – Profiling cookies 
1. Profiling cookies are those that create user-related profiles and are used to send advertising messages in line with the preferences expressed by the same in the context of web browsing. 
2. Profiling cookies are used to create a user profile, based on the preferences and tastes of the user who manifests while browsing the Internet, and to display advertising messages consistent with his profile. In this way the advertising messages that the user will see will be those of greatest interest. 
3. When these types of cookies are used, the user must give explicit consent, which will appear in the banner as soon as the user enters the site. 
3. Article 22 of Regulation (EU) 2016/679 and Article 122 of the Data Protection Code will apply, and Article 231 of 10 June 2021 of the Italian Data Protection Authority will apply. 

9 – How to disable cookies 
1. When you first visit our Site, you can accept all cookies by clicking on the “OK” button or the “X” (closing) button on the banner or on any element of the web page external to the banner itself. 
2. In any other case and every subsequent visit to the Site, by clicking on the “Cookie Policy” link at the bottom of the homepage of our Site, you can access this information and deny consent to the installation of cookies. 
3. You can disable cookies depending on the browser you are using. Since most browsers are programmed in such a way that they accept cookies automatically, the user can choose not to receive them, especially in cases where the third party involved has not correctly provided the possibility of opt-inout, accessing the browser settings and disabling their use, according to the procedures described at the following addresses: Microsoft Windows Explorer: https:/// 
Google Chrome: https:/// 
Mozilla Firefox: https:/// 
Apple Safari: https:/// 
4. If your browser is not present, you can refer to the cookie information provided by your browser. If you are using a mobile phone, see the mobile phone handbook for more information. 
5. As a result of disabling cookies through the browser settings, we remind you of the need to ensure, always through the same, the elimination of those already present before the disabling itself. 
6. The deactivation of third-party cookies is also possible through the methods made available directly by the third-party data controller for such processing, as indicated at the links in the paragraph “third-party cookies”. 
7. For information on cookies stored on your terminal and to deactivate them individually, please refer to 
8. Once on the site, by accessing the area “Your choices” you can: view the list of third-party companies, our partners, that install cookies on our site (Company); check the presence and activity status of the cookie installed (Status) and manage consent selectively (On/Off). By expanding the dedicated voice (Info) to each company you can access more information about the company and reach via link the specific information on privacy and cookies. 

10 – Social network interaction 
1. This site also incorporates plugins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when accessing the page, to safeguard the privacy of users. Eventually cookies are set, if so required by social networks, only when the user makes effective and voluntary use of the plugin. Please note that if the user navigates having logged in to the social network then he has already consented to the use of cookies transmitted through this site at the time of registration to the social network. 
2. This type of service allows interactions with social networks, or with other external platforms, directly from the pages of 
3. The interactions and information acquired by are in any case subject to the User’s privacy settings related to each social network. In the event that an interaction service with social networks is installed, it is possible that, even if users do not use the service, the same collects traffic data related to the pages in which it is installed. 
Linkedin social button and widget (LinkedIn Corporation). The LinkedIn button and social widgets are interaction services with the Linkedin social network, provided by LinkedIn Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy: 
Like button and social widgets of Facebook (Facebook, Inc.) The “Like” button and social widgets of Facebook are interaction services with the social network Facebook, provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy: https:/// 
Tweet button and social widgets of Twitter (Twitter, Inc.) The Tweet button and social widgets of Twitter are interaction services with the social network Twitter, provided by Twitter, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy: 
+1 button and Google+ social widgets (Google Inc.) The +1 button and Google+ social widgets are social interaction services provided by Google Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy: 
Pin It button and Pinterest social widgets (Pinterest Inc.) Pin It button and Pinterest social widgets are interaction services with the Pinterest social network, provided by Pinterest Inc.Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy: https:/// 
Instagram Social Button and Widgets (Instagram, Inc.)  
The button and social widgets of Instagram are interaction services with the social network Instagram, provided by Instagram, Inc. Personal Data collected: Cookies and Usage Data Place of processing: USA – Privacy Policy: https:/// 

  1. Rights of the user
    1. In line with the provisions of the GDPR, in relation to the processing of your personal data, you have the right to ask the Data Controller: 
    • Access: You may request confirmation that a processing of data concerning you is in progress or not, in addition to further clarifications regarding the information referred to in this statement; 
    • Correction: You can ask to correct or supplement the data you have provided, if inaccurate or incomplete; 
    • Cancellation: you can request that your data be deleted, if they are no longer necessary for our purposes, in case of withdrawal of consent or opposition to processing, in case of unlawful processing, or there is a legal obligation to cancel or refer to persons under the age of 16; 
  • Limitation: you may request that your data be processed only for the purpose of storage, with exclusions of other processing, for the period necessary for the rectification of your data, in case of unlawful processing for which you oppose deletion, where he must exercise his rights in court and the data stored by the Data Controller may be useful to him and, finally, in the event of opposition to the processing and a check is underway on the prevalence of the legitimate reasons of the Data Controller with respect to its own;
  • Revocation: you can revoke your consent at any time, if this is the basis for processing. The withdrawal of consent, however, does not affect the lawfulness of the processing based on the consent made before the revocation itself.
  1. You may at any time request Alf Investment Strategy BV to exercise these rights by contacting us at:
  2. The user has the right to lodge a complaint against the Italian supervisory authority: “Garante per la Protezione dei Dati Personali” if you believe that your rights have been violated by and/or a third party or if you do not find the response to your requests satisfactory.