Cookie Policy

What are cookies, what are they used for and who installs them?

Cookies are small text strings that the websites you visit send to your device (e.g. PC, tablet, smartphone, etc.) where they are stored and/or read by your browser. They allow the browser to send information to the person who installed the cookies in order to offer you optimal navigation, produce statistics on your visits, and offer you personalised content and targeted advertising. Cookies are contained in various elements hosted on the page of the site itself (such as advertising banners, images, videos, etc.).

While browsing this site, you may receive the following cookies on your device:

– first-party cookies: these are cookies sent from the Data Controller’s site that you are visiting,

– third-party cookies: these are cookies sent by a site other than the one you are visiting, which installs its own cookies via the Data Controller’s site.

The management and responsibility for first-party cookies lies with the Data Controller, while for third-party cookies the Data Controller has no control over either the activity of the third party or whether the third party may modify them over time. With regard to third party cookies, the Data Controller acts as an intermediary and, in this capacity, refers to the third party’s privacy policy, which can be reached through a link located next to each of the cookies indicated in the specific area that can be reached from the banner or at the bottom of the page.

Other tracking tools. Similar to cookies, other tracking tools are being developed to serve the same purposes. These tracking tools can be categorised according to a number of different criteria, but the main criterion for grouping them together remains the purpose for which they are used: technical or commercial.

 

a) What is the purpose of this Cookie Policy?

In compliance with the provisions of current legislation on the protection of personal data (in particular Regulation (EU) 2016/679 on the protection of personal data “GDPR” and the European and Italian legislation on cookies) we wish to inform you about the processing of your personal data collected through cookies (and possibly other similar tracking tools), including third parties.

The processing will be based on principles of correctness, lawfulness and transparency, as well as on the protection of your privacy and your rights.

 

b) Who is the Data Controller? How to contact them?

The Data Controller of your personal data is the company Telerie Spadari s.r.l. with registered office in Via Spadari 13, Milan, Tax identification number/VAT number 01072880154, (hereinafter referred to as the Data Controller). The Data Controller can be contacted at the postal address indicated above or at the following e-mail address: info@teleriespadari.com.

 

c) What cookies does this site use? For what purposes, on what legal basis? Is it compulsory to provide data? What happens if you do not provide it?

The cookies used by this site can be classified into the following categories: 1) Technical cookies, which are used to operate the site, and 2) Profiling cookies, which are used to track user behaviour in order to analyse it so as to offer them services based on their preferences. Below are the relevant details:

 

  1. Technical cookies, which do not require your consent

This category includes the cookies listed below, which serve the purposes indicated respectively:

  • navigation or session cookies, which serve to ensure normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);
  • anonymised analytics cookies, these are cookies used to collect information, in aggregate form and therefore not traceable to the individual, relating to the number of users, the most visited pages, the places from which they connect, etc. in order to draw up statistics on the service and use of the site. These cookies may also be third party cookies. In this case, however, the Data Controller must have made them anonymous (e.g. by anonymising the IP or masking part of it) and must not allow the third party to cross-reference the information collected through the site with other information already at its disposal.
  • functionality cookies, which allow the user to navigate according to a number of selected criteria (e.g. language, products selected for purchase) in order to improve the service provided to the user.
  • Legal Basis. For technical cookies (navigation, functionality or anonymized analytics cookies) the legal basis lies in the provision of a service and therefore in the performance of a contract or of pre-contractual measures (article 6.b of the GDPR) since they are necessary to make the site and the service requested by users usable. The use of such cookies does not require your consent.
  • Necessity for the providing of data and consequences. The provision of the data collected through the cookies described above is not compulsory; however, it is necessary for connecting to the site and providing the service. In the partial or total absence of such provision, the site cannot be used or there may be problems in using it. The list of technical cookies used by this site and their relative characteristics (e.g. characteristics, data retention times, etc.) is available in the specific area accessible from the banner or at the bottom of the page.

 

  1. Profiling cookies, which require your consent

Profiling cookies can be:

  • First-party: installed directly by the Data Controller on its site.
  • Third-party: installed on the Data Controller’s site by a third party. The Data Controller has no control over third party cookies, neither over the activity and purpose of the third party, nor over the possibility that the third party may modify them over time. In this sense, the Data Controller acts as an intermediary. In this capacity, it refers to the third party’s information notice, which can be reached via the link located next to each of the cookies indicated in the specific area that can be reached from the banner or at the bottom.

Profiling cookies make it possible to follow and trace, by means of automated tools, the user’s behaviour while surfing the Internet. Their purpose is to create profiles of the user and they are used by the Data Controller or by the third party to be able to send the user personalised advertising content in line with his/her preferences and interests, as expressed during his/her navigation on the web.

Non-anonymised analytics cookies used by the third party are also profiling cookies when the Data Controller has not anonymised them (e.g. has not anonymised the IP) or when it allows the third party to cross-reference the information collected with other information it already has.

  • Legal Basis. The use of Profiling cookies (including non-anonymized analytics) can only take place with your consent, which provides the legal basis for the processing of data collected through such cookies, in accordance with the provisions of article 6.a of the GDPR. The consent can be provided or revoked by you at any time by operating directly in the appropriate area accessible from the banner or present at the bottom.
  • Necessity for providing data and consequences. Failure to provide data as a result of your refusal to consent to these cookies does not have any consequences for you in terms of browsing the site and its use, but it does mean that we are unable to offer you advertising on services and goods in line with your preferences and your real interests expressed during your web browsing.

 

d) How to manage cookie consent?

You can manage your consent for the individual categories of cookies by working directly in the appropriate area accessible from the banner or at the bottom of the page.

 

e) How do I deactivate all cookies in my browser?

Another way to restrict the use of cookies is to operate your browser. Most browsers offer you the possibility to make a choice regarding the use of cookies by sites. Below are the procedures for changing your cookie settings and links to the relevant pages of the main browsers on the market for expressing your choices.

 

a) Google Chrome – Select the Chrome menu icon > Select Settings > At the bottom of the page, select Show advanced settings > In the ‘Privacy’ section, select Content settings > Select Allow local data storage > Select Finish.

For more information see https://support.google.com/accounts/answer/61416?hl=it.

b) Safari – To set Safari to block cookies in iOS 8, tap Settings > Safari > Block Cookies and choose “Always allow”, “Allow only from websites I visit”, “Allow only from current website” or “Always block”. In iOS 7 or older, choose “Never”, “Third-party and advertisers” or “Always”.

For more information see https://support.apple.com/it-it/HT201265

c) Firefox – Click the menu button and select options > Select the Privacy panel > Under History settings: select use custom settings > To enable cookies, mark the Accept cookies from sites item; to disable cookies, unmark the item.

See https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie.

d) Edge – Click the Tools button and then click Internet Options > Click the Privacy tab and under Settings move the slider up to block all cookies or down to allow all cookies and then click OK.

See http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies.

 

f) Is personal data transferred outside the European Union (EU)?

Some data collected by cookies may be transferred abroad to locations outside the European Union. This transfer will however be carried out in compliance with the safeguards prescribed by the GDPR for this type of activity (Articles 45 to 49). These include: transfer to companies located in countries for which the existence of personal data protection guarantees comparable to those of the GDPR is recognised (countries on the White List); or to companies with which specific personal data protection contractual clauses approved by the Data Protection Authority or binding company regulations approved by the Data Protection Authority have been signed, or the transfer takes place on the basis of specific exceptions. For further information you can contact the Data Controller as indicated in the point below entitled “What are your rights as data subject”.

 

g) How long are data stored?

The retention period of data collected through the use of cookies is indicated in the lists of cookies used by this site available in the appropriate area accessible from the banner or at the bottom.

h) Who can know your data? Who do we pass them on to?

The data collected through cookies may be used by collaborators authorised by the Data Controller, such as, for example, those in charge of site maintenance and management, marketing and administration. It may also be used by any third parties (service providers, infrastructure providers, IT providers involved in the management and supervision of the site and such like) who work on behalf of the Data Controller and have been duly appointed as data processors in accordance with the provisions of Article 28 of the GDPR. With your consent, they may also be used by third parties who install their own cookies on the Owner’s site.

 

i) What are your rights as a data subject?

The GDPR grants you the following rights in relation to your personal data, which you may exercise within the limits and in accordance with the provisions of the legislation:

  • Right of access to your personal data (Art. 15);
  • Right of rectification (Article 16);
  • Right to cancellation (right to be forgotten) (Art. 17);
  • Right to restriction of processing (Article 18);
  • Right to data portability (Art. 20);
  • Right to object (Art. 21): the data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her based on legitimate interest, including profiling on the basis of such interest. The Data Controller shall refrain from processing unless it can demonstrate the existence of compelling legitimate grounds for processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims;
  • Right to object to a decision based solely on automated processing (Article 22);
  • Right to withdraw, at any time, the consent given, without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.

You may do so by sending a written request addressed to the Data Controller at the postal address or by e-mail, as indicated above. In addition, you have the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it) if you believe that the processing of your data is contrary to the legislation in force (Article 77) or to take legal action (Article 79).

 

l) How are personal data protected?

Personal data shall be processed using technical and organisational security measures appropriate to the nature of the data to ensure their integrity and confidentiality and to protect them against the risks of unlawful intrusion, loss, alteration, or disclosure to third parties not authorised to process them.

 

m) Updates

The Data Controller reserves the right to modify and update this policy at any time. The changes will apply as soon as they are communicated or published. It is therefore necessary for you to regularly check the current Policy.

 

n) Further information

For further information regarding the processing of personal data, please also consult the privacy policy on this site. For further details on the cookies used, we invite the user to consult the specific area accessible from the banner or present at the bottom.

 

EDITION OF 18/11/2021

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