Cookie Policy

Cookies are short text files with relevant information that your browser processes when you visit a website.

They can be categorised by the purpose they serve. Some cookies are strictly necessary for the site to work, while others collect statistical information in order to analyse use and performance, provide additional features, or store your browsing preferences whenever you use the same device. They do not damage your device and, when enabled in the browser settings, they help identify and resolve possible errors in the site's operation.

Alongside cookies there are other forms of browser storage, such as local storage. The law treats them in the same way, and so does this policy.

On the public site, contrary to what is usual, we put nothing on your device simply because you opened it. What exists is this, and nothing more:

• Your answer to the cookie notice. Stored in your browser's local storage, not in a cookie: the site is static and there is no server reading it. It exists only so that we do not ask you the same question again on every page. It is strictly necessary and does not depend on consent, because it is what records that consent.
• Visit measurement, with Google Analytics. Only after you have authorised it. The next clause says what it does.
• YouTube videos. Only after you click on one, and the clause on videos says why.

The Academy is different, and has to be, because an account does not work without cookies. The Academy lives at academia.clc-financialpartners.com and exists only for those who have an account. Opening any of its pages stores two cookies, and signing in adds a third:

• __Host-authjs.csrf-token, which protects forms against requests forged from another site.
• __Secure-authjs.callback-url, which remembers the page to return to after signing in.
• __Secure-authjs.session-token, which is what keeps you inside your account. It lasts seven days.

All three are strictly necessary and do not depend on consent: without them signing in is not possible. None of them measures anything, none of them follows you outside the Academy, and the Academy does not load Google Analytics.

We do not use cookies for advertising, to measure campaigns, to follow you on other sites, or to build a profile about you.

We want to know how many people visit the site and which pages they read, so we can understand what is useful and what is not. For that we use Google Analytics 4, provided by Google Ireland Limited.

Nothing from Google is loaded before you click "Accept". It is not a case of the tool being loaded and waiting for authorisation: as long as there is no answer, or if the answer is "Decline", the program is never even requested from Google's servers and no contact is made with them.

If you accept, the cookies _ga and _ga_ followed by the property identifier are stored on your device. They distinguish visitors and maintain the session state, and last up to two years, which is Google's default period. The information collected is aggregated: pages viewed, visit duration, device type, and approximate origin. We do not collect your name, your email or any data that identifies you by this route.

Google may transfer and process this data outside the European Economic Area. The lawful basis for this processing is your consent, and you can withdraw it whenever you want.

Some testimonials are videos hosted on YouTube. Until you click on one, what is on the page is only a cover image, and your browser makes no request to the YouTube player.

When you click a video, the player is loaded in YouTube's privacy-enhanced mode, at youtube-nocookie.com. At that point YouTube may store information on your device under Google's policies, over which we have no control. Your click is the consent, and that is why the cover image exists: without it, opening the page would already be authorising.

On your first visit a notice appears with two options, Accept and Decline. Both take the same gesture, and neither is pre-selected. Until you answer, the site measures nothing. Declining closes nothing and restricts access to no page.

Withdrawing consent is as easy as giving it. In the footer of every page there is a "Cookie preferences" button, which asks you the question again. If you move from "Accept" to "Decline", measurement stops immediately and the cookies Google Analytics had left behind are deleted.

Your answer lasts six months. After that period we ask again, and we also ask again if we start using a tool we do not use today.

Whatever you answer here, a simple browser setting lets you block the use of cookies at any time. Those already stored can be deleted or removed by the browser itself or by other programs. This feature exists in every widely used browser on the market.

Note that clearing your browser storage also clears your answer to this notice, and so it will appear again on your next visit.

We have a presence on the main social networks, and we want to make clear that we do not set cookies by displaying links to those channels. The links from the site to Instagram, WhatsApp or any other platform are ordinary addresses, and nothing is loaded from those services until you click on them.

Those platforms have their own privacy and cookie policies, over which we have no control.