Cookie Policy

This information, pursuant to Article 13 of the European Regulation 2016/679 of the European Parliament and of the Council, is provided in accordance with the provisions of Legislative Decree 196/2003 as amended and supplemented of the Italian Republic, the Order of the Data Protection Authority No. 231 of 10 June 2021, as well as Directive 2002/58/EC of the European Parliament and of the Council. 

What are cookies?

Cookies are strings of text that websites (so-called “publishers” or “first parties”) visited by the user or different websites or web servers (so-called “third parties”) place and store – directly, in the case of publishers, and indirectly, i.e. through them, in the case of “third parties” – within a terminal device available to the user. The terminals referred to are, for example, a computer, a tablet, a smartphone, or any other device capable of storing information.  

Software for surfing the Internet and operating these devices, such as browsers, can store cookies and then transmit them back to the sites that generated them on a subsequent visit by the same user, thus keeping a record of his or her previous interaction with one or more websites. The information encoded in cookies may include personal data, such as an IP address, user name, unique identifier or email address, but may also contain non-personal data, such as language settings or information about the type of device a person is using to browse the site. 

Cookies therefore perform important and diverse functions, including tracking sessions, storing information about specific configurations of users accessing the server, facilitating the enjoyment of online content, etc. They can be used to keep track of items in an online shopping cart or information used to fill in a computer form. 

It is through cookies that it is possible, among other things, to allow web pages to load faster, as well as to route information over a network, in line therefore with requirements strictly related to the very operation of websites. Again, through cookies it is also possible to convey behavioural advertising and then measure the effectiveness of the advertising message, i.e. to conform the type and modalities of the services rendered to the user’s behaviour that was previously observed.

Cookie Types

Italian legislation (Art. 122 of Legislative Decree 196/03 ‘Personal Data Protection Code’, hereinafter referred to briefly as ‘Privacy Code’) introduced EU Directive 2009/136/EC into our legal system, which requires website operators, who use cookies or other tracking technologies, to inform the user about the types of cookies used by the site. 

With Provision No. 231 of 10 June 2021, published in the Official Gazette No. 163 of 9 July 2021, the Data Protection Authority divided the types of cookies into two macro categories: ‘technical’ and ‘non-technical’ cookies. 

Technical Cookies

They are installed by the owner or operator of the website for the purpose of

information society explicitly requested by the subscriber or user to provide this service>> (art. 122, paragraph 1, of the Privacy Code). Users’ prior consent is not required for the installation of Technical Cookies. 

First-party and so-called third-party analytics cookies

They can be equated with cookies and other technical identifiers only if: 

– are only used to produce aggregate statistics and in relation to a single site or mobile application;

– at least the fourth component of the IP address is masked in the case of third parties; – third parties refrain from combining analytics cookies, thus minimised, with other processing (customer files or statistics of visits to other sites, for example) or passing them on to other third parties. Third parties are, however, permitted to produce statistics with data from several domains, websites or mobile applications that can be traced back to the same publisher or business group.

A data controller that merely carries out its own statistical processing of data relating to several domains, websites or mobile applications that can be traced back to it may also use unencrypted data, subject to the purpose constraint.

Non-technical cookies

They are used to lead back to specific, identified or identifiable subjects, specific actions or recurrent behavioural patterns in the use of the offered functionalities (patterns) in order to group the different profiles within homogeneous clusters of different sizes, so that it is also possible to modulate the provision of the service in an increasingly personalized way, as well as send targeted advertising messages, that is in line with the preferences expressed by the user in the context of web browsing.

They are referred to in Article 122 of the Privacy Code where it provides that > (Article 122(1) of the Code). 

The Garante also categorised cookies according to the entity that acts as the controller of the personal data collected by the cookie, distinguishing between ‘first-party’ and ‘third-party’ cookies. 

First-party cookies

They are managed by the site owner. For these cookies, the obligation to provide information lies with the site owner. The latter also has the obligation to indicate how the cookie can be blocked. 

Third-party cookies 

They are managed by a third party other than the site owner. For these cookies, the obligation to inform and indicate how the cookie may be blocked lies with the third party. The site owner is obliged to report the url where these elements are available. 

In both types of cookies (first-party or third-party), the collection of consent, which is necessary if the cookie is a profiling cookie, takes place via a banner on the home page of the site. 

Types of cookies used on our website

This website uses technical cookies, which may be used without requesting the data subject’s consent, since they are strictly necessary for providing the service. Moreover, third-party profiling cookies may be used, the use of which is subject to the consent directly given to such third parties by accessing the relevant information on the use of cookies. Profiling cookies may be used, by the Data Controller or by the owner of the cookie itself, to store the choices made by the Data Subject, to provide personalised or optimised functions or to store his/her habits and preferences expressed during browsing. For example, profiling cookies may be used to offer online services to the Data Subject, to send him/her advertising that takes his/her interests into account or to prevent him/her from being offered services that he/she has refused in the past. 

The next section of this Cookie Policy details the list of all cookies used by this website. 

In the first group are listed the so-called technical cookies whose use does not require the user’s consent. Profiling cookies are listed in the second group. 

For both groups, the following information is given for each type of cookie: 

1. cookie name 

2. function performed by the cookie 

3. expiry of the cookie. 

4. indication of whether the cookie is first-party or third-party 

5. if the cookie is from a third party, an indication of the link through which it is possible to reach the third party’s website where the third party’s information on the processing carried out on the personal data collected through the cookie and the modalities for blocking the cookie are indicated

TECHNICAL COOKIES
Cookie name FunctionExpiry date/sessionFirst or third partLink to the third party’s cookie policy (for third-party cookies)
PROFILING COOKIES
Cookie name FunctionExpiry date/sessionFirst or third partLink to the third party’s cookie policy (for third-party cookies)

This website does not exchange cookies with external sites or external data providers. 

The authorisation to collect and store data by means of cookies can be revoked at any time: the data subject can deactivate the use of cookies through the specific setting options of the various browsers. 

▪ Microsoft Explorer: 

https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookie

▪ Google Chrome: 

https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=it

▪ Mozilla Firefox: 

https://support.mozilla.org/it/kb/Bloccare%20i%20cookie

▪ Apple Safari: 

https://support.apple.com/kb/ph21411?locale=it_IT

UPDATING OF THIS COOKIE POLICY

This Cookie Policy was updated on 29/06/2022. Future updates will be published on this page. For further information on the privacy policy click here.