General model of clauses for information “cookies”
It should also be noted that the “extended” information must be accessible from all pages of the site, as required by the aforementioned general provision. Only in the event that there are profiling cookies from the site manager or “third party” is it necessary to also have the “short” information.
[N.B .: text prepared in the light of the general provision of the Guarantor 8-5-2014 and opinion of the Working Group WP 194 of 4/2012]
What are cookies
Site manager cookies
The Site uses only “technical” cookies, such as navigation or session cookies, functionality cookies and analytical cookies.
- Navigation or session cookies
Specifically, navigation or session cookies are used, aimed at ensuring normal navigation and use of the website, and therefore aimed at making the navigation within the site functional and optimized.
- Functionality cookies
In addition, functionality cookies are installed, strictly necessary to provide services explicitly requested by the user.
- Analytical cookies
Finally, there are Google analytics cookies, used by the site manager and by Google, according to the terms of service prepared by the same, to collect information, in aggregate and anonymous form, on the number of users and how users visit the site.
Third party cookies
- Analysis cookies of third-party services
These cookies are used in order to collect information on the use of the site by users anonymously such as: pages visited, time spent, origins of the traffic of origin, geographical origin, age, gender and interests for the purpose of marketing campaigns . These cookies are sent from third-party domains external to the site.
- Cookies to integrate products and functions of third-party software
This type of cookie integrates features developed by third parties within the pages of the Site such as icons and preferences expressed in social networks for the purpose of sharing site content or for the use of third-party software services (such as software for generate maps and additional software that offer additional services). These cookies are sent from third-party domains and from partner sites that offer their functionality on the pages of the site.
- Profiling cookies
These are cookies sent by third parties, through the Site, necessary to create user profiles in order to send advertising messages, by the same third parties, in line with the preferences expressed by the user.
For third party cookies: Yandex Metrica (5): https://metrica.yandex.com/about/info/privacy-policy
Installation / uninstallation of cookies. Browser options
The user can object to the registration of cookies on his device by configuring the browser used for navigation: if he uses the Site without changing the browser settings, it is assumed that he intends to receive all the cookies used by the Site and to use all the features.
Remember that the user can prevent the use of some or all of the cookies described above, by configuring the browser used for navigation, namely: “To disable or enable browser cookies …., click here” http: / /windows.microsoft.com/it-IT/windows7/Block-enable-or-allow-cookies;
Mozilla Firefox: http://support.mozilla.org/it/kb/Blocchi%20i%20cookie?redirectlocale= enUS & redirectslug = Blocking + cookies]
Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=it
(1) Based on the general provision of the Guarantor of 8 May 2014, if there are profiling cookies inserted by the site operator, or even by third parties, it is also necessary to prepare a preliminary “short” information contained in an immediate pop-up banner on the home page (or on other pages from which the user can access to the site) which summarizes some fundamental information and also an explicit request for consent to use for profiling purposes. The information to be reported in the “short” information is:
a) an indication of the use by the site manager of profiling cookies;
b) if it occurs, that the site allows the use of these profiling cookies also by third parties;
c) the link to the “extended” information;
d) the indication that through the extended information it is possible to deny the installation of any (all or some) cookies;
e) the indication that the continuation of navigation involves the provision of the consent necessary for profiling. The Guarantor has prepared a “short” information model.
The possible insertion of technical cookies for the “tracking” of the consent already given by the user by continuing to navigate to the treatment by means of profiling cookies, allows to avoid that – during subsequent visits by the same user – the information must be re-proposed ” short”.
The provisions of the general mandatory provision must be implemented by June 3, 2015.
(2) The code identifies these cookies (not subject to prior consent or notification in cookies “aimed solely at carrying out the transmission of a communication on an electronic communications network, or to the extent strictly necessary for the provider of an information society service. explicitly requested by the contractor or user to provide this service “(art. 122, paragraph 1 of the privacy code).
(3) If, following acceptance, the specific service, “Google analytics” is used, since cookies are not used directly by the site operator, it is necessary to inform users that: “the data acquired through Google analytics may be also used by Google, according to the terms of service provided by the same “. In any case, for technical and analytical cookies it is not necessary to request consent from the user.
(4) Profiling cookies are those which by determining “the storage of information in the terminal device of a contractor or user or access to information already stored are permitted only on condition that the contractor or user has expressed the your consent after being informed in the simplified procedures referred to in Article 13, paragraph 3 “. The use of profiling cookies by the site operator therefore requires, in addition to the information to the user (art.13 of the privacy code, whose omission is sanctioned on the basis of art.161 of the same) also the acquisition of consent (art.23 of the code): in case of failure to acquire consent, the violation is sanctioned (art.162 bis of the code).
Furthermore, the presence of these profiling cookies also imposes the obligation, for the manager himself, to notify the Guarantor of this treatment in advance (art.37, paragraph 1, letter d, of the privacy code; the omission is sanctioned in based on article 163 of the code).
(5) The general provision on cookies (point 4.2) prescribes that links to the information and consents of third parties with which the site operator has entered into agreements, or to the intermediaries’ sites are included in the “extended” information. such as advertising agents) between the site operator and third parties. For the possible use of Google analytics, it is necessary to link to the specific Google information page: www.google.it/policies/privacy/partners/.