Cookies and Mobile Tracking Policy

EliteRefs Website and Mobile Application — Last updated: 26/02/2026

1. Scope and Legal Framework

This Cookies and Mobile Tracking Policy (“Policy”) describes how tracking technologies are used in connection with:

  • The public EliteRefs promotional website
  • The restricted-access EliteRefs SaaS platform
  • The EliteRefs mobile application (iOS and Android)

EliteRefs is operated by:

Algo Dynamics Srl
Via Monte Cervialto 197
00139 Rome, Italy
VAT No. 17440151003
Email: data@eliterefs.com

This Policy is drafted in accordance with:

  • Regulation (EU) 2016/679 (GDPR)
  • Directive 2002/58/EC (ePrivacy Directive)
  • EDPB Guidelines on Consent
  • Applicable national implementations

This Policy must be read together with the EliteRefs Privacy Policy.

Part I — Website Cookies

2. What Are Cookies?

Cookies are small text files stored on a user’s device when accessing a website.

EliteRefs may also use similar technologies such as:

  • Tracking scripts
  • Pixels
  • Local storage objects

Cookies may be:

  • First-party (set by EliteRefs)
  • Third-party (set by external providers)
  • Session-based
  • Persistent

3. Categories of Website Cookies

3.1 Strictly Necessary Cookies

These cookies are essential for:

  • Secure authentication
  • User session management
  • Access control
  • Fraud prevention
  • System stability
  • Load balancing

Legal basis: Legitimate interest (Article 6(1)(f) GDPR) and exemption under Article 5(3) ePrivacy Directive.

These cookies cannot be disabled via the consent tool.

3.2 Analytics Cookies

EliteRefs uses:

  • Google Analytics 4 (GA4)
  • Google Tag Manager (GTM)
  • Microsoft Clarity

These services collect:

  • IP address (subject to anonymization where applicable)
  • Browser type
  • Device information
  • Interaction data
  • Pages visited
  • Session duration
  • Click and scroll behavior

Purpose:

  • Statistical analysis
  • UX optimization
  • Performance monitoring
  • Technical diagnostics

Legal basis: Consent (Article 6(1)(a) GDPR and Article 5(3) ePrivacy Directive).

Analytics cookies are activated only after user consent where required.

3.3 Embedded Third-Party Content

The website may embed:

  • YouTube videos
  • Calendly scheduling widgets

When loaded, these third-party services may set their own cookies. EliteRefs does not control such cookies.

Users are encouraged to review the respective privacy policies of those providers.

Legal basis: Consent where required.

3.4 Advertising and Remarketing Cookies

EliteRefs does not currently use advertising or remarketing cookies.

If advertising technologies are introduced in the future:

  • Users will be informed
  • Explicit consent will be requested
  • This Policy will be updated accordingly

4. Consent Mechanism (Website)

Where required by law:

  • A cookie banner is displayed upon first visit
  • Non-essential cookies are blocked until consent is granted
  • Users may accept, reject, or customize preferences
  • Consent can be withdrawn at any time

Withdrawal does not affect prior lawful processing.

5. Cookie Retention Periods

Retention varies by category:

  • Session cookies: deleted upon browser closure
  • Analytics cookies: up to 14 months
  • Third-party cookies: defined by provider policies

Users may delete cookies via browser settings at any time.

Part II — Mobile Application Tracking

6. Tracking Technologies in the Mobile Application

Unlike websites, mobile applications do not use traditional browser cookies.

Instead, the EliteRefs mobile application uses:

  • Software Development Kits (SDKs)
  • Device identifiers
  • Local storage mechanisms
  • Push notification tokens

7. Analytics and Performance Monitoring (Mobile App)

The EliteRefs mobile application uses:

  • Google Analytics 4 (GA4)
  • Firebase Analytics
  • Microsoft Clarity

These tools may collect:

  • Device model
  • Operating system version
  • App version
  • Usage statistics
  • Session data
  • Interaction patterns
  • Crash diagnostics
  • Approximate geographic data derived from IP

Purpose:

  • Application stability monitoring
  • Performance optimization
  • User experience improvements
  • Detection of technical anomalies

Legal basis: Legitimate interest for strictly technical diagnostics. Consent where required under applicable law.

Analytics data is not used for behavioral advertising.

8. Push Notifications

The application may send push notifications that are:

  • Operational
  • Security-related
  • Service updates
  • System communications

Push notifications are not used for marketing purposes.

Users may disable push notifications at any time through device settings.

Push notification tokens are processed solely to enable message delivery.

Legal basis: Performance of contract.

9. Device Identifiers and Advertising IDs

The EliteRefs mobile application processes technical device identifiers necessary for app functionality.

EliteRefs does not use:

  • Apple Advertising Identifier (IDFA)
  • Google Advertising ID
  • Cross-app behavioral tracking technologies

The application does not engage in cross-platform profiling or targeted advertising.

10. Apple App Tracking Transparency (ATT)

Since EliteRefs does not perform cross-app advertising tracking, App Tracking Transparency permission is not required.

If future features involve advertising or cross-app tracking, explicit user authorization will be requested in compliance with Apple policies.

11. International Transfers (Mobile and Web)

Analytics and infrastructure providers (e.g., Google, Microsoft) may process data outside the European Economic Area.

Such transfers are safeguarded by:

  • Standard Contractual Clauses
  • Adequacy decisions
  • Encryption in transit and at rest
  • Contractual data protection obligations

12. User Control and Withdrawal

Users may:

Website:

  • Modify cookie preferences via the consent banner
  • Delete cookies via browser settings

Mobile App:

  • Disable analytics consent (where implemented)
  • Disable push notifications
  • Reset device identifiers
  • Uninstall the application

Uninstallation prevents further data collection from that device.

13. Security and Data Minimization

EliteRefs:

  • Does not collect special category data via cookies
  • Does not use tracking for automated decision-making
  • Applies data minimization principles
  • Periodically reviews tracking technologies

14. Limitation of Responsibility for Third-Party Technologies

EliteRefs is not responsible for:

  • Independent data processing conducted by third-party providers
  • Changes to third-party privacy practices
  • Data transfers initiated by embedded services

Users interact with third-party content at their own discretion.

15. Updates to This Policy

This Policy may be updated to reflect:

  • Legal developments
  • Regulatory guidance
  • Technological changes
  • Platform evolution

The latest version will always be available on the website and within the application.

16. Contact

For any inquiries regarding tracking technologies:

Email: data@eliterefs.com