Privacy Policy

1. Introduction

F.G. SRL ("we," "us," or "our"), located at Via Amerigo Vespucci, 18, 20124 Milano, Italy, operates this website to provide meditation and mindfulness education programs for participants throughout Canada. We are committed to protecting and respecting your privacy.

This Privacy Policy describes what personal data we collect, why we collect it, how we process it, and your rights regarding your data. By using our website or submitting information through our forms, you acknowledge that you have read and understood this Privacy Policy.

If you have questions about this policy, you can contact us at [email protected].

2. What Data We Collect

We may collect and process the following categories 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 (including selected program, preferred learning format, and your message)
• Conversion events (form submissions, calls, page visits related to program inquiries)

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

We process personal data only when we have a valid legal basis to do so. The specific legal bases for each data type are:

• Contact form data: consent (Art. 6.1.a) and performance of a contract or pre-contractual steps (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)

4. Cookie Categories

We divide cookies used on this website into three categories:

5. Marketing Cookies: Detailed Disclosures

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.

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.

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.

YouTube and Display Network: Advertisements may appear across Google services including YouTube, Gmail, and the Google Display Network.

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

Advertising measurement: We use conversion tracking to understand which advertisements lead to actions on our website, such as form submissions or program inquiries. This allows us to measure campaign effectiveness and allocate budget appropriately. Conversion data may be shared with Google Ads and Meta.

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)

Opt-out from personalized advertising: You may opt out of personalized advertising at any time:

• 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.

Cookie preference management: You can manage your cookie preferences at any time by clicking the Manage cookie preferences link, also available in our website footer.

6. Consent

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.

Our cookie consent banner offers three options: "Accept All," "Reject Non-Essential," and "Manage Preferences." Analytics and marketing cookies are not activated until you accept them. Your consent choice is stored in your browser's local storage for 12 months. The banner can be dismissed by rejecting non-essential cookies, in which case only essential cookies remain active.

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.

7. 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 and is 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.

8. Lead Forms and Contact Requests

When you submit a contact form, request information about a program, or register interest in our meditation and mindfulness education services, we collect the information you provide. This typically includes: full name, email address, phone number, selected program, preferred learning format, 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.

9. Google Services and Advertising

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 (such as a form submission or program 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

10. 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 and time on site
• Specific conversion events (form submissions, program 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/

11. Retention Periods

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected. Specific retention periods by category:

12. Your Rights (GDPR Articles 15-22)

If you are located in the EEA or UK, you have the following rights regarding your personal data:

• 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 of your data ("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 of these rights, 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:

• Italy (Garante per la Protezione dei Dati Personali): https://www.garanteprivacy.it
• EU users: https://edpb.europa.eu
• UK users: https://ico.org.uk

13. 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].

14. 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.

15. 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.

16. Landing Page Integrity Statement

The content of this website accurately represents the meditation and mindfulness education programs 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.

17. How We Protect Your Data

We take reasonable technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• HTTPS encryption across all pages of this website
• Secure form processing with server-side validation
• Restricted access to personal data on a need-to-know basis
• Regular security reviews of our website infrastructure
• Spam protection measures on all contact forms

While we strive to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your information.

18. Third-Party Links

Our website may contain links to external websites operated by third parties. We have no control over and are not responsible for the content, privacy policies, or practices of those third-party sites. We encourage you to review the privacy policies of any external websites you visit. Links to third-party sites do not imply endorsement by F.G. SRL.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the "Last Updated" date at the top of this page.

Significant changes will be notified via a homepage banner a minimum of 14 days before taking effect. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

20. Contact Information

If you have questions, concerns, or requests related to this Privacy Policy or your personal data, please contact us: