Definition of “Cookie”
Cookies are small pieces of information that are sent from the Site to the terminal (normally the browser), where they are stored in order to be used again the next time the same user visits the Site. A cookie cannot retrieve any other data from your hard drive or pass on computer viruses, nor can it retrieve email addresses. Each cookie is unique to the user’s web browser. Some of the cookies functions can be delegated to other technologies. The term “cookie” refers to cookies as well as all similar technologies
Purpose of data processing and session technical cookies
1) cookies filled with user data (session identifiers), the duration of a session or cookies that in some cases are used only for a few hours,
2) cookies for authentication purposes, used for authentication services, for the duration of a session;
3) cookies for safety services that are user centric, used to identify the authentication abuse, for a limited duration;
4) cookies for multimedia players such as cookies for flash players, for the duration of a session;
5) cookies for load balancing, for the duration of the session;
6) cookies needed for the personalization of the user interface, for the duration of a session (or little more);
7) cookies for the sharing of content through social media plug-ins of third parties, for members of a social network that have logged on.
We would like to inform the user, therefore, that this Site uses the necessary operational and technical cookies in order to navigate the functions that are essential for the management of a navigation session.
For maximum transparency, we list a series of technical cookies and operational cases specific to this Site.
Cookies used to analyze statistics of access or uses of this site (the so-called “analytic” cookies) which are purely a statistical pursuit (and not for profiling or marketing) and collect information in aggregate form without the possibility to track the individual user identification. In these cases, since the current law allows that for analytic cookies, the user be provided clear and simple instructions in order to opt-out at their facility (including any anonymization mechanisms of such cookies), we would like to specify that it is possible to proceed with disabling Google Analytics as follows: Open the browser, select the settings menu, click on internet options, open the tab for privacy settings and enable the desired level of blocking of cookies. If you wish to delete the cookies currently stored in the memory, simply open the Security tab, and delete the history by checking the box “delete cookies”.
In addition to technical cookies, we would like to inform you that PROGECA S.r.l uses other cookies that do not qualify as “technical”, as they pursue the objective of behavioral analysis for marketing purposes.
The personal information collected through operational cookies can be treated, by ways of automated/computer modalities, for the following purposes that are specified below as requested by the Italian Data Protection Authority Provision from the 4th of July 2013 which lays down the guide lines to avoid spam: commercial promotions, advertising, solicitation to purchase behavior, market research, surveys (including telephone, online, or through standardized forms), statistical analysis (in the form of identification) , and marketing in the broadest sense of products and or services related to PROGECA S.r.l (hereinafter, collectively, “Data Processing for Marketing Purposes”).
In accordance to the General Provisions by Data Protection Authority for privacy of May 15th 2013, entitled “Consent to processing of personal data for use of direct marketing through traditional instruments and automated means of contact”, we would like to draw specific attention to users that:
1. Any given consent for the purpose of sending commercial and promotional sales communications, based on art. 130, paragraphs 1 and 2, of the PERSONAL DATA PROTECTION CODE (ie through the use of email, fax, sms, mms, and automated systems without operator intervention and the like, including electronic and other electronic media platforms) will involve the receipt of such notification, not only through the aforementioned automated modality, but also through traditional methods, such as paper mail or calls with an operator;
2. The right to object to the processing of personal data for “direct marketing” purposes through the aforementioned automatic electronic modalities will extend in all cases to traditional modes, and even in such case, retain the right to exercise this right in part, as provided by Art. 7, paragraph 4 of the PERSONAL DATA PROTECTION CODE, both with respect to certain modalities as well as certain data processing;
3. The possibility for the user, who does not give consent to the aforementioned terms, to manifest any desire to receive communications exclusively through traditional methods of contact, if any, such manifestation shall be carried out free of charge by sending a simple email to: email@example.com
In order to comply with the privacy obligations to the user in accordance with the principles and simplification of such obligations (art.2 of the PERSONAL DATA PROTECTION CODE) and in accordance with the Data Protection Authority of 15 May 2013 entitled “Consent to processing of personal data for “direct marketing” purposes through traditional means as well as automated contact means”, we would like to inform you of the the formula of specific consent with be single and comprehensive and will be with reference to all possible means of marketing processing, in accordance with Art. 23 and 130 of the Code, the user may, notify PROGECA S.r.l if the user desires not to receive with prior consent of marketing communications to the address: firstname.lastname@example.org
Furthermore, for the purpose of fulfilling privacy obligations to the user in accordance with the simplified principles of such obligations (Art. 2 of the PERSONAL DATA PROTECTION CODE), we would also like to inform you that the formula of giving specific consent will be single and comprehensive and will also be with reference to all the different and possible uses of marketing explicitly written here (that is, without multiplying each formula of consent for each distinct use of marketing by the owner), the user, may, at any time, notify PROGECA if the user desires not to deny consent to some or all of the marketing . In order to proceed to data processing for Marketing purposes, it is required to acquire specific, separate, express, documented, free, and informed consent that is of course, optional. Consequently, if the user decides to lend specific consent, the user should be informed and aware that the purpose of such data processing are of commercial, advertising, promotional nature and that of marketing in general. In the interest of absolute transparency, we would like to inform the user that data will be collected and further processed with the consent of the following specific provisions:
1. to send commercial, advertising, and informational (newsletters) material, or any promotional or sales material to users who have provided informed consent according to Art. 23 and 130 of the PERSONAL DATA PROTECTION CODE;
2. to carry out direct sales or placement of products or services of the Company;
3. to send commercial information, or interactive commercial communication in accordance with Art. 58 of the Legislative Decree 206/2005 through email;
4. to develop studies, research, or market statistics;
5. to send unsolicited commercial communication according to the Art. 9 of the Legislative Decree of 9 April 2003 n. 70 and the implementation of the so-called Directive of Electronic Commerce 2000/31/CEE, that provides that unsolicited commercial communication should be immediately and unequivocally identifiable as such and it should be indicated that the recipient of the message may refuse any future receipt of such communications.
With reference to the sending of Newsletters through electronic email, to which the user may eventually agree to, we would like to inform the user that the electronic content of such communications may be of promotional character and could be assisted with software (like cookies or web beacons) that are able provide information to the Company of a series of parameters, such as, but not limited to: the moment in time that the newsletter was opened, the pages viewed in the Newsletter, the link clicked on in the newsletter, links to sites that the newsletter has directed to. Such parameters, that do not constitute as profiling of the user, are used to give information to the Company about the statistical data of the use of services generated from several sources.
Therefore, providing the optional consent, the user or interested party takes specific note and authorizes ulterior or possible secondary data processing.
In any case, even if the interested party or user has already given consent to authorize PROGECA S.r.l to pursue all of the objectives of data processing from the aforementioned point 1 to 5, the interested party is free to revoke such consent by sending an informal and clear communication asking to revoke consent to PROGECA S.r.l at the email address email@example.com.
Following the receipt of such a request of an opt-out, PROGECA S.r.l will proceed to promptly remove or delete the data from the database used for Data Processing for Marketing and to inform any third parties about the request for cancellation. The simple reception of such a cancellation request will automatically communicate the confirmation of the cancellation.
Communication and dissemination of Personal Data collected via cookies as part of the data processing for Marketing Purposes
For the same purposes aforementioned form point 1 to 5 of the preceding paragraph. PROGECA S.r.l would like to inform that collected data may be communicated to third party business partners (Third Parties). The consent to Data Processing for Marketing purposes by PROGECA S.r.l as holder and owner of the processed data, where there has been consent by the user, does not cover a different or ulterior data processing for marketing purposes represented by the communication to third parties of data for the same purposes.
In order to proceed with such communications to an external source, it is required to acquire the consent from the user or interested party that must be informed, ulterior, separated, in addition, documented, and express and completely optional.
As in fact, clarified by the Data Processing Authority’s Provisions of 4 July 2013 laying down the Guidelines to avoid spam:
1. communication to third parties for marketing purposes in general, communication or transfer to third parties of personal data for marketing purposes can not be based on the acquisition of a unique and generic consent from interested parties for such purposes;
2. The holder or owner of data who intends to collect personal data also interested in communicating them (or sell them) to third parties for promotional purposes must first be given appropriate information that identifies each of the third parties also, or alternatively, indicating the categories to which they belong (economic or industries);
3. it is necessary that the holder acquires specific consent for communication (and / or transfer/sales) of personal data to third parties for promotional purposes, as well as distinct consent required by the holder itself to carry out promotional activities;
4. if the interested party gives such consent for the communication to third parties, these third parties could provide promotional activities with automated procedures according to Art. 130, paragraph 1 and 2 of the PERSONAL DATA PROTECTION CODE without having to acquire new consent for promotion Data Protection Authority Provision of 4 July 2013 laying down the guidelines to avoid spam the third party recipients of the personal data provided through the data processing for Marketing Purposes can be identified with one of the following product or economic categories: publishing, suppliers of goods and electronic communications services, Internet service providers, communication agencies, companies providing insurance and financial services companies in the food and catering, clothing, ICT hardware and software, banks and credit institutions, travel agencies, companies offering services in the tourism sector, companies offering services and goods for the person, including health care goods and services, a company supplying goods and services in the sector of Energy and Gas.
Personal data will not be disseminated.
Mandatory or voluntary consent for the operation of cookies pursuing marketing purposes
Mode of giving consent
We draw particular attention to the fact that both the consent to cookies that pursue marketing purposes, as well as the connected and subsequent data processing for Marketing Purposes that have obtained separate consent for the disclosure of personal data collected by a third party cookies the data processing for marketing purposes and in the manner described above are entirely voluntary and optional (and in any case revocable without formalities later on) and lack of transfer will not result in further consequences for PROGECA S.r.l or any third party to pursue data processing for marketing purposes mentioned. In case a refusal to consent, there will be no interference and / or consequence to access the Site.
Activation/Selection of Cookies
Internet Explorer: http://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-11
Google Chrome: https://support.google.com/accounts/answer/61416?hl=it
Apple Safari: http://support.apple.com/kb/HT1677?viewlocale=it_IT
Mozilla Fireforx: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
Disabling Flash cookies: http://www.macromedia.com/support/documentation/it/flashplayer/help/settings_manager02.html#118539
Also remember, that by completely disabling cookies in your browser, the user may not be able to use all the interactive features.
Cookies of Third Parties
While navigating the Site, users may receive cookies on their devices of different web sites or servers (so -called cookies of “third parties”): this happens because on this Site, there could be elements such as, for example, images, maps, sounds, specific links to web pages in other domains that reside on different servers from the page that the user is on. In other words, these cookies are set directly from website operators or different servers from the Site. These cookies can be sent to your browser from third-party companies directly from their web sites that can be accessed by navigating on the Site. In such cases, PROGECA S.r.l is foreign to the operation of such cookies, the sending of which is the responsibility of such third parties .For the sake of transparency of information, we inform you that on the website the following third-party cookies may be found:
On this site there are certain “buttons” (called “social buttons / widgets”) that depict the icons of social networks (such as Facebook). Such buttons allow users browsing the site to interact with a “click” directly with the social network depicted therein and share the information collected on this website. In this case the social network acquires data on the user’s visit, while the owner will not share any navigation information or user data acquired through its website with the social network accessed through social buttons / widgets. Such services shall issue “third-party cookies.” Below is the link to the privacy information of the social network used where buttons link to:
– Facebook: https://www.facebook.com/help/cookies
– Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter#, and https://twitter.com/privacy?lang=it
– Google+ information: http://www.google.it/intl/it/policies/technologies/cookies/ Google+ (Configuration): http://www.google.it/intl/it/policies/technologies/managing/
– Linkedin information: https://www.linkedin.com/legal/cookie-policy
– Linkedin (configuration): https://www.linkedin.com/settings/
The deactivation of these cookies will interrupt the functions offered by these third parties.
The identification of the Data Controllers with respect to the data processing are as follows:
Via Piave, 178 – 10014 Caluso (TO)
Tel: +39 011 9891784 | Fax: +39 011 0960595
Email address to exercise rights under Art. 7 of the Privacy Code: firstname.lastname@example.org
Exercize of the Rights of the concerned party
At anytime the user may – without formality – exercise the rights under Art. 7 of the PERSONAL DATA PROTECTION CODE (also by using the form made available by the Data Protection Authority at: www.garanteprivacy.it), the PERSONAL DATA PROTECTION CODE is copied here below in order to be useful. The exercise of rights is not subject to any form of constraint.
Art. 7 PERSONAL DATA PROTECTION CODE
(Right to Access Personal Data and Other Rights)
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. A data subject shall have the right to be informed
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
3. A data subject shall have the following rights:
a) to obtain updating, rectification or, where interested therein, integration of the data;
b) to obtain erasure, anonymization or blocking of data that have been processed unlawfully,
including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) to obtain certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. A data subject shall have the right to object, in whole or in part,
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.