Cookie and Privacy Policy

This notice explains how we handle and protect your personal information when you browse this website (the “Site”).

It is provided in accordance with Article 13 of Regulation (EU) 2016/679 (“GDPR”), Article 122 of Italian Legislative Decree 196/2003 and subsequent amendments (“Privacy Code”), as well as the requirements set by the Italian Data Protection Authority’s provision “Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies” (May 8, 2014), supplemented by the “Guidelines on cookies and other tracking tools” (June 10, 2021) (collectively, the “Provision”).

1. Data Controllers (Parties Who Determine the Purposes and Methods of Processing)   

Your personal data is processed by Del Monte & Partner Comunicazione S.r.l., registered office in Milan (MI), Viale Bodio 37 – 20158, email: privacy@digital360.it (“OPCO”). Your data will also be shared by OPCO with the Digital360 S.p.A. holding company, registered office in Milan (MI), Viale Bodio 37 – 20158, email: privacy@digital360.it (“Digital360”). Digital360 will process your data as an independent data controller (collectively referred to as the “Companies”).

2. How to Contact the Data Protection Officer (DPO)  

3. Which Personal Data Do We Process

a. Browsing Data

During normal website operations, certain personal data is automatically collected as part of using internet communication protocols.

This data includes your device’s IP address or domain name, the requested resource’s URI/URL, the time of the request, the method used to submit the request, the size of the response file, a numerical code indicating the server’s response status (such as success or error), and other technical details about your operating system and browsing environment.

This data, which is required to access our web services, is also used to:  

• gather statistical information on service usage (such as most visited pages, number of visitors by time of day or day, and geographic origin of users);  
• monitor that services are functioning correctly;  
• exercise or defend the Companies’ rights in legal proceedings, including in cases of criminal investigations by authorities.

b. Data You Provide Voluntarily

To access certain services, you will need to provide personal data. Detailed information about how your data is handled will be provided at the time it is collected, in accordance with Article 13 of the GDPR.

c. Cookie  

The Site uses cookies.

What are cookies

Cookies are small text files created by our web server and stored on your device when you access this site.

They hold information that helps us recognize your device each time you return, allowing the website to remember your preferences and provide a consistent browsing experience.

First-party and third-party cookies

Cookies can be set not only by the website you are visiting (known as first-party cookies), but also by external websites (third-party cookies) through elements integrated into the site, such as images, maps, audio, or links to other domains.

According to the applicable regulations, for third-party cookies, the responsibility to provide information and, when required, to collect consent, falls on the third parties themselves. As the website owner, we act as a technical intermediary and include updated links to third-party privacy policies and consent forms within this extended notice.   

Technical, Analytics, and Profiling Cookies

Depending on their purpose, cookies are categorized as either technical cookies or profiling cookies.

Technical cookies are strictly necessary for the transmission of information over electronic communication networks or for providing a service explicitly requested by the user. These cookies are typically used to support seamless navigation between pages, store user preferences, save specific user configurations, and authenticate users.

Technical cookies include navigation cookies, which record essential data to enable smooth browsing and use of the website (such as remembering preferred page sizes), and functional cookies, which allow the site to retain specific user choices to optimize functionality (for example, remembering a user’s language selection or maintaining a logged-in state).

Some technical cookies are considered essential or strictly necessary, as certain operations on the website would not be possible without them.

According to Article 122, paragraph 1, of the Privacy Code, the use of technical cookies does not require user consent, but users must be informed about their presence.

As established by the Provision, analytics cookies are treated as technical cookies—and therefore do not require user consent—if they meet certain criteria:

1. created and used directly by the website operator (without involvement from third parties) to optimize the site by collecting aggregated information on the number of users and how they interact with the website, as well as  
2. created and provided by third parties when:
   
   1. used directly by the website for statistical purposes only, provided that suitable minimization measures are applied to reduce their ability to identify individuals (for example, by masking portions of the IP address), and used exclusively to generate aggregate statistics, generally related to a single website or a single mobile application, so they do not allow tracking users across different websites or applications;
   2. Third-party providers that offer web measurement services for this site are not permitted to combine, enrich, or cross-reference the collected data—even when minimized as described above—with other information they may hold (such as customer databases or statistics from visits to other websites), nor may they share this data with additional third parties.  

Profiling cookies are used to track your browsing activity, analyze your behavior for marketing purposes, and build a profile based on your interests and preferences. This enables us to deliver targeted advertising tailored to your online activity. These cookies will only be installed on your device if you have given your explicit consent.

Persistent and session cookies

Based on their duration, cookies are classified as either persistent or session cookies. Persistent cookies remain stored on your device until they expire or are manually deleted by you. Session cookies, on the other hand, are not stored permanently and are deleted automatically when you close your browser.

Cookies Used by the Companies  

Technical Cookies

The Companies use cookies for specific, limited purposes—mainly to make navigation easier for users, to ensure system security, and for internal system administration.

These cookies are essential and cannot be disabled. As outlined above, their use does not require prior user consent under Article 122 of the Privacy Code.  

Anonymized analytics cookies  

The Companies use Google Analytics, a web analytics service provided by Google Inc., to identify the most visited pages on the Site, analyze how long visitors stay, and determine their general geographic location. For more information, please see: https://support.google.com/analytics/answer/1011397.

The analytics cookies used are properly anonymized (by masking significant portions of the IP address), allowing us to collect aggregated data about the number of users and their browsing patterns on the Site without identifying individual visitors. Additional details are available at: https://support.google.com/analytics/?hl=it#topic=3544906.

You can choose to disable Google Analytics by installing the dedicated browser add-on provided by Google, available here: https://tools.google.com/dlpage/gaoptout.

While these cookies are not essential for the operation of the Site, they are important for measuring site performance and traffic, including metrics such as visitor count and distribution by geographic area, time slot, or other characteristics.

When properly anonymized, analytics cookies are classified as technical cookies. For this reason, your prior consent is not required for their use.

Profiling cookies

he Companies use marketing cookies to track visitors across websites, analyze user behavior for marketing purposes, and build profiles based on interests, habits, and preferences. The goal is to display advertisements that are relevant and engaging for each individual user, providing greater value to publishers and third-party advertisers.  

These cookies are only installed with your explicit consent.  

For a detailed list of cookies used on the Site, please refer to the table below.

List of Cookies Used on the Site  

4. How to Give or Withdraw Consent and Manage Browser Settings  

Profiling cookies will only be installed on your devices with your explicit consent, which can be provided by clicking the “Accept” button within the banner that appears when you access the website, or by selecting your preferred cookie categories in the second level of the banner and confirming with “Save settings.” Your consent is securely stored using a dedicated technical cookie.

You can update or withdraw your cookie preferences at any time by clicking the “Cookies” button available on every page of the website.

Additionally, you have full control over cookies through your browser settings. Even if your browser is set to automatically accept cookies, you can modify these preferences at any time, allowing you to delete or remove some or all cookies, block cookies entirely, or restrict their use to specific websites. Please note that disabling, blocking, or deleting cookies may affect the optimal use of specific areas of the Site or limit certain features, as well as affect the functionality of third-party services integrated within the Site.

Below, you will find direct links to the guides for managing cookies in the most commonly used browsers:

• Microsoft Internet Explorer
• Microsoft Edge
• Google Chrome
• Mozilla Firefox
• Safari

For browsers not listed above, please refer to the specific browser’s help guide for instructions on managing cookies.

5. Recipients of Personal Data  

Your personal data is handled only by authorized employees and collaborators within our group of Companies, who have received dedicated instructions to ensure data protection and confidentiality.

In addition, certain third-party service providers—such as those supporting website management, internet connectivity, market research, CRM maintenance, or marketing automation—may process your data on our behalf, in accordance with Article 28 of the GDPR and under strict contractual obligations as Data Processors.

Your data may also be shared with independent data controllers, including regulatory authorities, supervisory bodies legally entitled to request it, and, where applicable, external providers (or third parties) listed in the tables above regarding cookies.

6. Transfer of Personal Data Outside the EU

Your data may be transferred to recipients located outside the European Union (EU) or European Economic Area (EEA), specifically to the United States, which has been recognized as offering adequate protection by the European Commission under the "EU-US Data Protection Framework" as of July 10, 2023.  

If your data is sent to recipients in a "third country" without an adequacy decision, we will implement Standard Contractual Clauses (SCC) in accordance with Article 46(2)(c) of the GDPR. You can request a copy of these clauses by contacting the Companies using the details provided in section 1 above.

For further information about third-party recipients listed in the table above, please refer to the links to their privacy notices.

7. Rights of Data Subjects  

In addition to withdrawing consent for the use of profiling cookies as outlined in section 4, you may exercise your rights under Articles 15–22 of the GDPR by contacting the Companies using the details provided in section 1. Specifically, you have the right to:

1. Request access to your personal data and related information, as described in Article 15 (including purposes of processing, categories of data processed, etc.);
2. Request deletion of your data in cases specified by Article 17, such as when the Companies no longer have the right to process it;
3. Request correction of inaccurate data or completion of incomplete data;
4. Request restriction of processing—in other words, have your data temporarily retained without further processing—in situations covered by Article 18 GDPR;
5. Object to the processing of your data at any time, free of charge and easily, for reasons related to your specific situation, when data is processed based on the legitimate interests of the controller;  
6. Receive your data in a structured, commonly used, and machine-readable format—and, when technically feasible, have it transmitted directly to another controller—if processing is based on your consent or a contract and carried out by automated means.
7. You also have the right to file a complaint with the Italian Data Protection Authority or with the relevant supervisory authority in the country where you reside, work, or where an alleged violation has occurred.