SECOND SECTION: PROCESSING OF PERSONAL DATA COLLECTED THROUGH COOKIES
1. Subject and purpose of processing and type of data
Cookies (also known as an HTTP cookie, web cookie, or browser cookie) are small files that sites visited by users send to their terminals, where they are stored, only to be retransmitted to the same sites on the next visit.
In general, based on the characteristics and use of cookies we can distinguish several categories:
• Strictly necessary cookies: These are cookies that are indispensable for the proper functioning of the site and are used to manage login and access to restricted functions of the site. The duration of cookies is strictly limited to the working session (once the browser is closed, they are deleted).
• Analytics and performance cookies. These are cookies used to anonymously collect and analyze site traffic and usage.These cookies, while not identifying the user, allow, for example, detection of whether the same user returns to log on at different times. They also make it possible to monitor the system and improve its performance and usability.Deactivation of such cookies can be performed without any loss of functionality.
• Profiling cookies. These are permanent cookies used to identify (anonymously and non-anonymously) user preferences and improve the user’s browsing experience. This website does not use profiling cookies. Cookies are not used to transmit personally identifiable information, nor are persistent cookies of any kind used.
The main cookies dispensed on the site are summarized below (clicking on the link will redirect you to the disable option):
• Google analytics cookies: Analytical cookies are used to collect statistics and anonymous information on the number of visitors, most visited pages, etc…
The use of cookies (Google Analytics) is subject to contractual constraints between the Owner and Google Inc, which include, among other covenants, the designation of the provider as a data controller (Amendment on the processing of personal data).
You can disable analytical cookies, without consequences for browsing, at:
https://tools.google.com/dlpage/gaoptout/This site does not use profiling cookies. For more information about cookies and to manage your settings regarding third-party profiling cookies, please visit
https://www.youronlinechoices.com
More information on this can be found in paragraph No. 7 “Additional Information” in this section.
On the first visit, the site collects the user’s consent for the types of cookies that require it through a banner. It remains possible, however, to change your mind and revoke your consent to all or some of them.
This policy refers only to cookies sent to your computer during your visit to this website and does not refer to cookies sent from other websites, links to which are available on our pages.It is possible, in fact, that third-party cookies are sent to your browser while you are browsing our website, such as in the case of social sharing cookies for the hypothesis of sharing data extracted from our site on social networks (Facebook, Twitter, Instagram, YouTube) or when you click on a link to an external website. Please refer to the policies of these third parties for the purposes and use by their respective Owners. The Company also uses the Google Analytics service, which, although it does not identify the user, allows it to obtain analytical data in order to monitor the system and improve its performance and usability, such as, for example, to detect whether the same user returns to log in at different times, data on visits and the number of actual users landed on the site, the number of total pages and the average value per visit, the average value of visit time, the type of audience entered based on the device used, geographic area, language, which pages are the most visited, what is the flow of visits (entry pages and the route taken within the site). For these cases the IP address is anonymized, but these cookies are not equated with technical cookies and therefore require consent.
2. Legal basis and duration of processing
Based on the provisions of Article 122 of Legislative Decree No. 196/2003 (as amended by Legislative Decree No. 101/2018 - hereinafter the Privacy Code), the use of technical or strictly necessary cookies does not require the consent of the user. In fact, they are used for the sole purpose of “carrying out the transmission of a communication over an electronic communications network or to the extent strictly necessary for the provider of an information society service expressly requested by the contracting party or user to provide such service”.
The legal basis for the processing of personal data related to the other cookies used on the site is the consent that the user can express through the banner posted on the site.
The user may modify or revoke his or her consent at any time and free of charge, including through the browser. To learn more, the user is invited to read the last part of this policy.
Analytics and performance cookies (Google Analytics) last no longer than 24 months, while third party cookies last no longer than 12 months.
3. Nature of Data Provided
The provision of data is required for essential cookies, while it is optional and there will be no appreciable consequences in the absence of the above provision for analytics and third party cookies.
4. Method of processing
The data will be processed in accordance with the obligations imposed on the data controller by the GDPR and the current Privacy Code.
Processing may be carried out by automated methods suitable for their storage, management and transmission, and will be carried out by means of instruments suitable, within reason and the state of the art, to guarantee their security and confidentiality, including through the implementation of procedures to prevent the risk of breach.
With respect to third party cookies, please refer to the cookie policy of such entities linked at the bottom of this page.
5. Categories of recipients
The personal data in question may also be communicated to and processed by the Data Controller’s collaborators (e.g. external consultants in charge of processing and/or consulting operations, webmasters and IT service providers) who carry out outsourcing activities on behalf of the Data Controller, in their capacity as Data Processors and with whom the Data Controller has entered into appropriate deeds of appointment pursuant to and in accordance with Article 28 of the GDPR.
In addition, data related to cookies may be shared with third parties that provide them, in their capacity as Data Controllers, unless otherwise specified in this Policy (e.g. Google Inc.).
In all cases, with respect to third party cookies, please refer to the cookie policies of those parties linked at the bottom of this policy.
Information may also be shared:
• to competent authorities in the performance of obligations to which the Controller is subject;
• to supervisory, law enforcement or judicial authorities and, more generally, to subjects who are entitled to access them in accordance with the laws in force from time to time.
6. Transfer of data abroad
Data related to strictly necessary cookies will not be transferred outside the European Union. In particular, the management and storage of personal data will take place on servers located in the European Union of the data controller and/or third party companies, if appointed as external data processors pursuant to Article 28 of the GDPR.
Data related to analytics and third party cookies (e.g., Google Inc.) may be transferred outside the European Union. Currently, in the absence of an adequacy decision for the transfer of data to the U.S., unless otherwise specified, the protective instrument governing the transfer is the standard contractual clauses under Art. 46(1) of the GDPR. For more information, please refer to the cookie policies of these entities.
