Large Call to Action Headline
EXTENDED COOKIE POLICY
EXTENDED COOKIE POLICY
Accademia Musicale Europea β Cultural Association
Version: 1.0 | Last updated: June 23, 2026
This document has been drafted in accordance with Article 13 of EU Regulation 2016/679 (GDPR), Legislative Decree 196/2003 as amended by Legislative Decree 101/2018, and the Guidelines on cookies and other tracking tools issued by the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) on June 10, 2021.
EXTENDED COOKIE NOTICE
This Cookie Policy supplements the general Privacy Notice of Accademia Musicale Europea (version 1.0, dated April 30, 2026, updated June 23, 2026) and the brief cookie banner displayed on the landing page of www.operacareerintelligence.com. It provides complete and detailed information about the use of cookies and tracking technologies on this website.
DATA CONTROLLER
The Data Controller for personal data collected through this website, including data collected via cookies, is:
Accademia Musicale Europea Non-profit cultural association Registered office: Via Francesco Caracciolo 4 β 00192 Rome (RM), Italy Tax identification number: 97487550580 Legal representative: Prof.ssa Simonetta Marchitelli
Privacy contact: π§ amministrazione@accademiamusicaleeuropea.org
For any request regarding the processing of your personal data, including requests related to cookies, please write to the email address above with the subject line: "Privacy Request β Cookies".
β οΈ Important notice: The email addresses legal@trebsolutions.it and accademiamusicaleuropea@gmail.com referenced in previous versions of this document are no longer valid for privacy-related communications concerning Accademia Musicale Europea. The only official address for privacy requests is: amministrazione@accademiamusicaleeuropea.org
Applicable data protection law grants you the following rights. You may exercise any of them at any time, free of charge, by writing to the Data Controller at the address above.
Copia tabella
Right Legal basis What you can do
Access Art. 15 GDPR Find out whether we process your data and obtain a copy
Rectification Art. 16 GDPR Correct inaccurate or incomplete data
Erasure Art. 17 GDPR Request deletion of your data
Restriction Art. 18 GDPR Temporarily suspend processing
Portability Art. 20 GDPR Receive your data in a readable format and transfer it
Objection Art. 21 GDPR Object to processing based on legitimate interest
No automated decision-making Art. 22 GDPR Not be subject to solely automated decisions
Withdrawal of consent Art. 7(3) GDPR Withdraw consent at any time
Complaint to the supervisory authority Art. 77 GDPR Lodge a complaint with the data protection authority
Supervisory authority: Garante per la Protezione dei Dati Personali β www.garanteprivacy.it β Piazza Venezia 11, 00187 Rome, Italy.
TABLE OF CONTENTS
What cookies are
Types of cookies used on this website
Data provision and consent management
Security measures for data protection
Disclosure of data to third parties
Transfer of data outside the EU
How to manage, modify, or disable cookies
1. WHAT COOKIES ARE
Cookies are small text files that a browser automatically saves on the user's device (computer, tablet, or smartphone) during website navigation. They allow the website to collect and store information about the browsing session and user preferences, improving the experience on subsequent visits.
Cookies are stored by the browser on the specific device in use. Depending on the user's settings, they may be deleted when the browser is closed or retained for a defined period of time.
Technologies treated as equivalent to cookies: In this document, the term "cookie" is used broadly and includes similar tracking technologies, such as:
Web beacons / transparent GIFs: small invisible images embedded in web pages or emails, used to monitor user behaviour;
HTML5 Local Storage and Session Storage: local storage mechanisms introduced with the HTML5 standard, which can be used to collect information about service usage;
Tracking pixels: code fragments that detect specific user actions on a web page;
Fingerprinting: a technique that identifies a device based on its technical characteristics, without the use of cookies in the strict sense.
First-party and third-party cookies:
Cookies are "first-party" when they are set directly by the website the user is visiting (in this case, by the Data Controller);
They are "third-party" when they are set by a domain other than the website being visited - for example, by social media platforms, analytics systems, or external advertising networks.
The use of third-party cookies is governed by the rules established by the respective providers. To manage or disable such cookies, users should review the privacy policies and instructions published on each third party's website.
Cookie duration:
Session cookies: deleted automatically when the browser is closed;
Persistent cookies: remain stored on the device after the browser is closed, for a period defined by the server at the time of creation. In some cases a specific expiry date is set; in others, cookies remain active until the user deletes them manually.
β οΈ Warning: Disabling certain cookies, including equivalent tracking technologies, may affect the full usability of this website or limit access to some services. The Data Controller cannot guarantee complete website functionality if strictly necessary technical cookies are blocked.
2. TYPES OF COOKIES USED ON THIS WEBSITE
In accordance with the Guidelines on cookies and other tracking tools issued by the Italian Data Protection Authority on June 10, 2021, and the updated EDPB Guidelines, cookies used on this website are classified as follows.
2.1 Strictly necessary technical cookies
(No consent required β Art. 6(1)(f) GDPR / Legitimate interest)
These cookies are essential for the website to function correctly and for the user to access the requested services. Without them, some or all website features may be unavailable. Because they are strictly necessary, they are installed automatically upon access to the website, without requiring prior consent.
This category includes:
Session cookies: maintain an active session during navigation;
Security cookies: protect the website from fraudulent activity and ensure browsing integrity;
Functional cookies: store the status of essential technical preferences, such as the acceptance or rejection of the cookie banner, so it is not displayed again on subsequent visits.
The technical cookie used to record consent expressed through the banner is itself a first-party technical cookie. If the user deletes this cookie, the consent record will be lost and the banner will be displayed again on the next visit.
Users may block or remove technical cookies by changing their browser settings, as described in Section 7. However, doing so may prevent access to certain areas of the website or the use of specific services.
2.2 Preference (functional) cookies
(Consent required β Art. 6(1)(a) GDPR)
Preference cookies allow the website to remember choices made by the user during navigation - for example, selected language, display settings, or regional preferences - improving the experience on subsequent visits. Although not strictly technical, these cookies are not used for profiling or marketing purposes.
2.3 Analytical / statistical cookies
(Differentiated treatment depending on origin)
Statistical cookies help the Data Controller understand how visitors interact with the website, by collecting aggregate information on page usage, including number of visits, pages viewed, and navigation paths.
In accordance with the Italian Data Protection Authority's Guidelines of June 10, 2021:
First-party analytical cookies (installed directly by the Data Controller, with no data transmission to third parties): do not require user consent, provided data is collected and used in aggregate, anonymised form;
Third-party analytical cookies (installed by external providers, such as Google Analytics): require explicit user consent, even when configured with IP masking and without cross-profiling functions.
2.4 Social buttons and social plugins
(Consent required for third-party cookies β Art. 6(1)(a) GDPR)
This website may contain social buttons - icons or links directing users to the Data Controller's official accounts on major social networks, such as Facebook, Instagram, YouTube, and LinkedIn.
Important: The social buttons on this website are configured as simple links to the Data Controller's social accounts. In this configuration, no third-party cookies are installed when the page is loaded.
Should interactive social plugins be integrated in the future, such as a Facebook "Like" button with direct platform code loading, this would result in third-party cookies being installed. Users will be notified in advance through the banner and this Cookie Policy, and explicit consent will be requested.
2.5 Marketing and profiling cookies
(Explicit consent mandatory β Art. 6(1)(a) GDPR)
Marketing cookies are used to track user behaviour across websites in order to deliver personalised advertising content relevant to the user's interests, and to measure the effectiveness of promotional campaigns.
These cookies are installed or activated only upon explicit user consent, expressed through the cookie banner at the time of the user's first visit to the website.
This category includes, where activated:
Tracking pixels from advertising platforms, such as Meta Pixel / Facebook Pixel;
Retargeting cookies for displaying personalised advertisements;
Email marketing platform cookies for tracking opens and clicks in promotional communications.
β οΈ Note for users: You can view the updated list of active individual cookies, including the provider name, specific purpose, duration, and category, directly within the cookie management banner on the website's landing page, or through the "Manage cookie preferences" link in the website footer.
3. DATA PROVISION AND CONSENT MANAGEMENT
Consent on first access
In accordance with the Italian Data Protection Authority's Guidelines of June 10, 2021, and the EDPB Guidelines 05/2020 on consent, the cookie banner on the website's landing page ensures:
At the first level (immediately visible), both the "Accept all cookies" button and the "Reject all cookies" (or "Use only necessary cookies") button are present, with equal visual prominence and accessibility;
Access to a second level with granular selection by cookie category (preferences, analytics, marketing), via a "Customise" button or equivalent;
No non-technical cookies are set before the user has expressed consent (no "cookie wall");
No dark patterns, meaning no manipulative design techniques such as pre-ticked boxes, persuasive language, or visual asymmetry between accept and reject options.
With the exception of strictly necessary technical cookies
The provision of data through non-technical cookies depends entirely on the user's choice. Users may:
Reject all non-technical cookies by clicking "Reject all" or "Use only necessary cookies" in the banner on first access;
Customise their preferences by individually selecting which cookie categories to accept or reject;
Withdraw or modify consent already given at any time, by accessing the cookie banner settings through the "Manage cookie preferences" link in the website footer, or by changing browser settings as described in Section 7.
Consent records
The Data Controller maintains a cookie consent log as required by Article 7 GDPR, to demonstrate that consent was validly obtained. For each user, the log records the date and time of consent, the cookie categories accepted or rejected, and the version of the banner and notice displayed.
4. SECURITY MEASURES FOR DATA PROTECTION
The Data Controller implements appropriate technical and organisational measures, pursuant to Article 32 GDPR, to protect personal data collected through cookies from unauthorised access, loss, destruction, accidental disclosure, or unlawful processing.
These measures include, but are not limited to:
Use of HTTPS/TLS protocol for secure data transmission;
Access to data restricted to authorised personnel trained in data processing procedures;
Internal procedures for managing data breaches, pursuant to Articles 33 and 34 GDPR;
Periodic review of the adequacy of security measures in place.
Users are advised to take appropriate precautions on their own devices, including keeping the operating system updated, using antivirus software, and managing credentials securely, in order to contribute to the protection of their personal data.
5. DISCLOSURE OF DATA TO THIRD PARTIES
Data collected through cookies may be disclosed, to the extent strictly necessary, to parties involved in the technical and operational management of the website. These parties are appointed as Data Processors pursuant to Article 28 GDPR, through the execution of a Data Processing Agreement (DPA).
The main parties that may access the data include:
Party Role Location GDPR compliance Systeme.io Email marketing, landing pages, funnels, CRM France (EU) Subject to GDPR β DPA available
[www.tophost.it] Hosting and server management
Authorised technical personnel Website maintenance and development Italy (EU) Written instructions pursuant to Art. 29 GDPR
Data is not sold or transferred to third parties for their own commercial purposes.
6. TRANSFER OF DATA OUTSIDE THE EU
Users' personal data is processed primarily within the European Union or the European Economic Area (EEA).
Where the use of third-party cookies, particularly analytics or marketing tools provided by companies based or operating servers outside the EEA, requires the transfer of data to third countries, such transfer will take place exclusively in compliance with Chapter V of the GDPR (Articles 44β49) and, in particular, on the basis of one of the following safeguards:
Adequacy decisions issued by the European Commission, such as the EU-US Data Privacy Framework for transfers to the United States, where applicable;
Standard Contractual Clauses (SCCs) adopted by the European Commission by Decision of June 4, 2021;
Binding Corporate Rules (BCRs) adopted by the provider;
Appropriate safeguards pursuant to Article 46 GDPR.
The Data Controller is committed to informing users transparently of any actual transfer outside the EEA, specifying the destination country and the applicable safeguard.
7. HOW TO MANAGE, MODIFY, OR DISABLE COOKIES
Users have several options for managing their cookie preferences.
7.1 Through the website banner and settings
Consent may be modified or withdrawn at any time by accessing the cookie banner settings through the "Manage cookie preferences" link in the website footer. The Data Controller ensures that withdrawing consent is always as straightforward as giving it, in accordance with Article 7(3) GDPR and EDPB Guidelines 05/2020.
7.2 Through browser settings
Cookies may be managed, blocked, or deleted directly through the settings of the browser in use. Official guidance is available at the following links:
Browser Official instructions
Google Chrome https://support.google.com/chrome/answer/95647
Mozilla Firefox https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
Microsoft Edge https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
Opera https://help.opera.com/en/latest/web-preferences/#cookies
Safari (Mac/iOS) https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
7.3 Through third-party tools
For cookies installed by third-party providers, such as social platforms, analytics systems, or advertising networks, users may manage their preferences by:
Visiting the provider's specific opt-out link, where available;
Following the instructions in the provider's privacy policy;
Contacting the third-party provider directly.
7.4 Do Not Track option
Some browsers offer a "Do Not Track" (DNT) option, which allows users to signal their preference not to be tracked. However, as there is currently no legally binding standard for the interpretation of the DNT signal, not all websites and third-party providers are required to honour it. The Data Controller will take this signal into account in the context of consent management, but cannot guarantee its application by all third-party cookie providers active on the website.
FINAL INFORMATION
Updates to this Cookie Policy: This Cookie Policy may be updated periodically to reflect technical, operational, or regulatory changes. The updated version will always be available on this page, with the date of revision indicated. In the event of material changes, the Data Controller will display the cookie banner again to existing users and, where necessary, request renewed consent.
Applicable legal framework:
EU Regulation 2016/679 (GDPR)
Legislative Decree 196/2003, as amended by Legislative Decree 101/2018
Italian Data Protection Authority Guidelines on cookies and other tracking tools, June 10, 2021
EDPB Guidelines 05/2020 on consent
EDPB Guidelines 02/2023 on dark patterns
EDPB Guidelines 01/2020 on data processing
Accademia Musicale Europea Via Francesco Caracciolo 4 β 00192 Rome (RM), Italy
Tax ID: 97487550580
π§ amministrazione@accademiamusicaleeuropea.org
π www.operacareerintelligence.com
Document v1.0 β Last updated: June 23, 2026