The Data Controller, pursuant to articles 4 and 24 of EU Regulation no. 2016/679, is: PROMOS S.R.L., Via San Zeno, 173 – 25124 Brescia (BS), Italy, e-mail: privacy@promosgroup.it, Tel: +39 030 2422862.
The Data Protection Officer, pursuant to art. 37 of the Regulation, can be reached at the following e-mail address: dpo@promosgroup.it.
What are cookies?
Cookies are short strings of text that the websites visited by the user send to the user’s terminal (usually a browser), where they can be saved and sent back to those websites on the occasion of subsequent visits by the same user (so-called first-party cookies).
When navigating on a website, users may receive cookies from other websites or servers (so-called third-party cookies); this happens because there may be elements, like pictures, maps or sounds, specifically linked to the website pages of other domains, which reside on different services from that on which the required page is located. In other words, they are cookies that are posted by a website different from the one the user is currently visiting.
Cookies can be limited just to the time of the single session of navigation on the browser (so-called session cookies) and, in that case, are automatically inactivated when the user closed the browser; or they may have a specific term limit and, in that case, will remain active in the memory of the hard disk until that date, continuing to collect information during different sessions of navigation on the browser (so-called permanent cookies).
First-party Cookies
The website makes use of the following types of essential, first-party cookies, the installation of which does not require any consent from the user but for which PROMOS is required to provide adequate information:
(a) Navigation or session cookies: fundamental to enable users to move normally within the PROMOS website and to benefit correctly from the relative services; since they are not saved on the users’ computers, they disappear when the browser is closed;
(b) “Functional” cookies: serving solely to improve and speed navigation on the website, by saving certain choices made by the users (such as the language preference).
They are tools used by PROMOS to ensure efficient navigation, among other things, as well as the stability of the session and memory of the login during the entire session, as well as the country of navigation selected. They also serve to memorize the choices made by users relative to the visualization of certain elements of the page, such as informative banners and messages.
Use of these cookies and performance of processing connected with them do not require the prior consent of the users. Users can, however, prevent the installation of technical cookies by making the appropriate settings on the browsers, with the understanding that a similar choice could complicate, slow and at times even prevent navigation on the website. PROMOS acts at exclusive data controller with reference to the first party cookies installed on its website.
Third–party cookies
While users are navigating on the website, cookies not directly controlled and managed by PROMOS may be saved on their devices. This could happen, for example, when the users visit a page that includes content of a third party website.
In that connection, please note that PROMOS has no role in the processing of data deriving from this type of cookie, as it is a simple technical intermediary.
Third-party profiling cookies serve to display customized ads on the website and on those of other websites, and their function is based on the user’s navigation habits. This type of cookie could also be used by third parties to show their products and services on the website.
The website also uses certain types of analytic third-party cookies through which certain information may be collected, such as (by way of example):
(a) number of visitors, viewing of pages and navigation within the website;
(b) effectiveness of the campaigns of acquisition based on the source of web traffic;
(c) details of products viewed and possible downloaded from the website.
These cookies, and the purposes for which they are used outside of the website, fall under the direct and exclusive responsibility of the third party that provides to install them on the users’ terminals, and serve to show ads in line with their interests (this is the case of third-party cookies for profiling/retargeting).
If the users do not wish to receive third-party cookies on their terminals, they can refuse to provide their consent and, at any time, through the links shown, or through the options of selection/refusal in this cookie policy statement or banner.
The box below lists all the cookies present on the website, with respect to which the users can decide to opt in or out, blocking or deleting any as they wish.
Third-party Trackers
SPAM protection
Other activities involving the use of Trackers
Experience
This Website uses Trackers to improve the quality of the user experience and enable interactions with external content, networks and platforms.
Measurement
This Website uses Trackers to measure traffic and analyze User behavior to improve the Service.
Management of cookies and consent
At the time of their first visit to the website, users can (i) accept all the cookies, clicking on the “Accept all” key; (ii) keep only the default settings, which provide exclusively for the use of the cookies necessary for website operation (“Use only necessary cookies”), or (iii) select individually only certain cookies and certain uses and then click on “Accept Selections”.
The cookie banner will be displayed at the first visit to the website and again after every six months.
Closing the banner and accessing the subsequent pages, without selecting any option will allow PROMOS to use only the essential cookies.
In every other case and at every subsequent visit to the website, clicking on the “Cookie Policy” link at the bottom of each page of the website and on the special “Edit Consent” key, users can deny or revise consent to the installation of unnecessary cookies.
In any case, since most browsers are programmed to accept cookies automatically, users can choose not to receive them, by accessing the browser settings and disabling their use, according to the procedures described at the following addresses:
Internet Explorer: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies
Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
Google Chrome: https://support.google.com/accounts/answer/61416?hl=it
Safari: https://support.apple.com/it-it/HT201265
Opera http://help.opera.com/Windows/10.00/it/cookies.html
It is also possible to link to the website www.youronlinechoices.com (only for the services covered by that platform), to obtain information about how to eliminate or manage cookies depending on the browser used, and to set the preferences for use of third-party cookies: www.youronlinechoices.com/it/
Your Online Choices is a website managed by the non-profit organization European Interactive Digital Advertising Alliance (EDAA), whose Italian version can be accessed at the address: www.youronlinechoices.com/it/, and which provides information about behavioral advertising based on profiling cookies. (http://www.youronlinechoices.com/it/a-proposito). It enables internet users to easily opt out of installation of the main profiling cookies installed by advertising operators and used on internet websites (http://www.youronlinechoices.com/it/le-tue-scelte). Before using this tool, we recommend that users read carefully the general conditions of services of the website Your Online Choices (http://www.youronlinechoices.com/it/condizioni-generali-di-servizio), the frequently asked questions (FAQ) (http://www.youronlinechoices.com/it/faqs) and the user guide (http://www.youronlinechoices.com/it/help).
Processing methods and time of data conservation
As noted in the introduction to this informative document, PROMOS collects and processes certain personal data of the users through the cookies that it incorporates directly in the website (first-party cookies). PROMOS acts as Data Controller of these data, in accordance with the provisions of the Regulation. PROMOS will process users’ data only with electronic tools and procedures that are fully automatic.
The personal data processed may be saved on servers managed by third parties (such as suppliers of information systems) or may be communicated to organizations specialized in online advertising, which act as data processors for PROMOS, on the basis of specific contracts. PROMOS informs its users that, in respect of the guarantees established by the Regulation, users’ data may be transferred to countries outside the EU. In that case, PROMOS will apply adequate procedures to ensure confidentiality. Personal data will not be published.
The personal data of website users will be kept for the time strictly necessary to fulfill the primary goals illustrated in this information document, or in any case, as long as necessary to protect the rights and interests of the users and PROMOS.
Users’ rights
The articles from 15 to 22 of the GDPR grant data subjects specific rights. Art. 15 recognizes the right of data subjects to access their personal data and obtain a copy of it. The right to obtain a copy of their data shall not infringe on the rights and freedoms of others.
With the request of access, data subjects have the right to obtain from the data controller confirmation or denial of the fact that their data is being processed and to know the purposes and categories of data processed, the third parties to which they have been communicated and whether the data have been transferred to a country outside Europe with adequate guarantees. Data subjects also have the right to know for how long their personal data will be used, in respect of the aforementioned purposes.
With respect to their personal data, data subjects may request correction of incorrect data and completion of incomplete data, as well as deletion (right to oblivion) at the conditions indicated by art. 17 of the Regulation, and may also request limitation of processing and portability of data.
Data subjects have the right at any time to oppose the use or revoke their consent to use of their data with regard to purposes of marketing and profiling if connected to marketing.
To exercise the above rights, it will be necessary to contact the data controller at the e-mail privacy@promosgroup.it, or at the address of the registered office.
Before responding, it may be necessary to identify the data subjects by asking them to supply a copy of their identity document. The data controller will provide a written answer without undue delay and, in any case, no later than one month after receipt of the request.
Claims with the guarantor for the protection of personal data
Data subjects who believe that their personal data may have been used in violation of the provisions of the Regulation or local legislation on the subject of data protection have the right to file a claim with Guarantor for the Protection of Personal Data with office in Rome, pursuant to art. 77 of the Regulation, as well as with the courts of law.
Updates.
This privacy policy may undergo amendments and/or additions following any amendments and/or additions to the legislation, the update or provision of new services or intervening technological innovations. Any changes will be published on the website and, if necessary, communicated to the data subjects via e-mail.