Notice on the use of cookies and similar technologies on the website www.jinni.srl
This page explains what cookies are, why the website www.jinni.srl currently sets none at all, how the anonymous visit statistics work (they use no cookies), and how you can still manage cookies from your browser.
1. Introduction and legal framework
This notice describes the use of cookies and other tracking technologies (for example local storage, pixels, web beacons) on the website www.jinni.srl, in both its Italian and English versions. It supplements the website’s Privacy Policy, to which you are referred for any other information on the processing of personal data.
This notice does not cover other websites, pages or online services reachable through external links on the site; please refer to their own notices.
This notice is provided pursuant to:
- Regulation (EU) 2016/679 (the “GDPR”);
- Italian Legislative Decree 196/2003 (the “Italian Data Protection Code”), as amended by Legislative Decree 101/2018, and in particular Article 122;
- Directive 2002/58/EC (the “ePrivacy Directive”);
- the “Guidelines on cookies and other tracking tools” issued by the Italian Data Protection Authority (Garante per la protezione dei dati personali) on 10 June 2021.
2. Who is the Data Controller?
Jinni Srl
Via Mosè Bianchi, 71, 20149 Milano MI, Italy
Email: privacy@jinni.srl
VAT number: 09316480962
Data Protection Officer (DPO): Arianna Crepaldi – dpo@jinni.srl
3. What are cookies?
Cookies are small text files that the websites you visit send to your device, where they are stored and then sent back to the same websites on your next visit. Similar technologies (for example local storage, session storage, pixels or fingerprinting) make it possible to store information on the device or to access it.
Under the Italian Data Protection Authority’s Guidelines of 10 June 2021, the following categories are distinguished:
- technical cookies and tools: necessary for the website to function or to provide a service explicitly requested by the user (for example session, security or language-preference cookies). They do not require the user’s consent, only information;
- analytics cookies: treated as technical cookies, and therefore not requiring consent, only if used to produce aggregated statistics, with reduced identifying power and without being combined with other information; otherwise, they require consent;
- profiling cookies and third-party tracking tools: used to build user profiles or for advertising purposes. They require the user’s prior consent.
4. Which cookies does this website use?
The website www.jinni.srl is a static website designed according to the principles of privacy by design and privacy by default. In particular:
- No cookies. At present the website sets no cookies at all on the user’s device, whether first-party or third-party (technical check carried out on the website: no cookies are set by the pages, the server or the form service).
- Cookieless anonymous statistics. For visit statistics the website uses Umami, installed on the Controller’s server, which sets no cookies and stores nothing on the user’s device (see section 5).
- No third-party analytics or marketing tools. The website does not use Google Analytics, Google Tag Manager, Brevo/Sendinblue tracking scripts, the Facebook/Meta pixel or any other profiling or advertising tools.
- No embedded third-party content. The website does not embed videos, maps, social plugins or other third-party content. Links to Jinni’s social media profiles (LinkedIn, Facebook, Instagram) and to the kamzan.com website are plain links: no data is sent to those platforms until you click the link and visit the relevant website, which is subject to its own notices.
- Locally hosted fonts. Typefaces are hosted directly on the website’s servers: no requests are made to external services such as Google Fonts.
- Contact forms. Submitting the contact forms does not set any cookies. The forms’ anti-spam system is a hidden field that people never fill in: it uses no cookies and no browser storage.
- Browser local storage. The website does not use the browser’s local storage or session storage.
Should it become necessary in the future to use technical cookies (for example for security purposes or to store preferences), they will be listed on this page; as technical tools, they will not require the user’s consent.
5. Visit statistics
To understand, in aggregated form, how the website is used, we use Umami, installed on our own server (the same one that hosts the website), with no involvement of third parties.
- No cookies, nothing stored on your device. Umami sets no cookies and uses no local storage or session storage: to tell one visit from another it computes a temporary identifier on the server that changes every day, so it cannot recognize you over time or follow you across websites.
- Aggregated data only. It collects only aggregated metrics: pages viewed, referring website (referrer), device type, browser language and language of the page viewed.
- IP address not stored. The IP address is used only on the spot to compute the temporary identifier and to derive the approximate country and city of the visit; it is not saved.
- No third parties. The Umami script is served from the website’s own domain, so no request is sent to third-party domains. The statistics can be viewed only by Jinni staff.
- Heatmaps. On a few pages only – the home page, the “AI software development” page, the “Kamzan Ecosystem” page and the “Write to team Jinni” contact page, in every language of the website – Umami also records where people click and how far they scroll the page, as anonymous coordinates, to build aggregated maps of how those pages are used. It does not record what you type into forms, does not capture your screen (session recording is disabled) and stores nothing on your device.
Since it produces only anonymous, aggregated statistics, without storing information on the user’s device and without combining them with other information, this tool is among those that, under the Italian Data Protection Authority’s Guidelines of 10 June 2021, do not require consent. The related processing is based on the Controller’s legitimate interest (Art. 6(1)(f) GDPR), as described in the Privacy Policy.
6. Why is there no cookie banner?
Since the website uses no cookies or other tracking tools subject to consent, and the visit statistics are anonymous, aggregated and cookieless (see section 5), there is no consent banner: there would be nothing to authorize. This is a deliberate privacy by design choice. The consent management system previously used (My Agile Privacy®) has been removed together with the third-party tools that made it necessary.
Should tools requiring consent be introduced in the future (for example embedded third-party content or marketing tools), they will be activated only after the user has expressed their preferences through a banner compliant with the Italian Data Protection Authority’s Guidelines, and this notice will be updated accordingly.
7. How to manage or delete cookies in your browser
Even though the website sets no cookies, you can block or delete cookies at any time through your browser settings. Indicative paths for the main browsers:
- Google Chrome: Settings → Privacy and security → Third-party cookies / Delete browsing data
- Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
- Safari: Settings (Preferences) → Privacy → Manage Website Data
- Microsoft Edge: Settings → Cookies and site permissions
If you use a different browser, please consult the support section of its manufacturer’s official website.
8. What are your rights?
With regard to any personal data processed through the website, you may exercise the rights provided for by Articles 15-22 GDPR (access, rectification, erasure, restriction, objection, portability) and lodge a complaint with the Garante per la protezione dei dati personali pursuant to Art. 77 GDPR. For a full description of these rights and how to exercise them, please see the Privacy Policy.
9. How do we inform you of changes to this notice?
This notice is subject to periodic review to reflect changes in legislation or in the technologies used on the website. Any change will be published on this page, and the “Last updated” date shown at the top will be updated accordingly.
