Cookie Policy

1. What are cookies?

Cookies are small text files that sites visited by users send to their terminals, where they are stored and then transmitted back to the same sites on the next visit. Cookies from so-called “third parties” are, on the other hand, set by a website other than the one the user is visiting. This is because on each site there may be elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the site visited.

2. What are cookies used for?

Cookies are used for different purposes: performing computer authentication, session tracking, storing information about specific configurations regarding users accessing the server, storing preferences, etc.

3. What are “technical” cookies?

These are cookies that serve to carry out navigation or provide a service requested by the user. They are not used for any other purpose and are normally installed directly by the website owner.

Without the use of such cookies, some operations could not be carried out or would be more complex and/or less secure, such as home banking activities (displaying account statements, bank transfers, bill payments, etc.), for which cookies, which allow the user´s identification to be made and maintained within the session, are indispensable.

4. Are analytics cookies “technical” cookies?

No. The Garante (see order of May 8, 2014) has specified that they can be assimilated to technical cookies only if they are used for site optimization purposes directly by the owner of the site itself, who may collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules, regarding information and consent, as for technical cookies apply to analytics cookies.

5. What are “profiling” cookies?

These are the cookies used to track the user´s navigation on the web and create profiles on his tastes, habits, choices, etc. With these cookies can be transmitted to the user´s terminal advertising messages in line with the preferences already manifested by the same user when browsing online.

6. Is the user´s consent necessary for the installation of cookies on his terminal?

It depends on the purposes for which the cookies are used and, therefore, whether they are “technical” or “profiling” cookies.

For the installation of technical cookies, the users´ consent is not required, while it is necessary to give the information (art. 13 of the EU Regulation 2016/679). Profiling cookies, on the other hand, can only be installed on the user´s terminal if the user has given consent after being informed in a simplified manner.

7. How should the site owner provide simplified information and request consent for the use of profiling cookies?

As established by the Guarantor in the measure indicated in question no. 4, the information must be set up on two levels.

The moment the user accesses a website (on the home page or any other page), a banner must immediately appear containing a first “brief” information, the request for consent to the use of cookies and a link to access a more “extended” information. On this page, the user can find more and more detailed information about cookies choose which specific cookies to authorize.

8. How should the banner be made?

The banner must be large enough to partially cover the content of the web page the user is visiting. It must only be able to be removed by active user intervention, i.e. by selecting an element contained on the page below.

9. What indications must the banner contain?

The banner must specify that the site uses profiling cookies, possibly including “third-party” cookies, which allow it to send advertising messages in line with the user´s preferences.

It must contain the link to the extended information and the indication that, through that link, it is possible to deny consent to the installation of any cookie.

It must specify that if the user chooses to continue by “skipping” the banner, they consent to the use of cookies.

10. How can the acquisition of consent made through the use of the banner be documented?

To keep track of the consent acquired, the owner of the site can make use of a special technical cookie, a system that is not particularly invasive and does not in turn require additional consent.

In the presence of such “documentation”, there is no need for the short information to be repeated on the user´s second visit to the site, without prejudice to the possibility for the user to deny consent and/or modify, at any time and in an easy manner, his or her options, for example through access to the extended information, which must therefore be linkable from every page of the site.

11. Can online consent to the use of cookies only be requested through the use of the banner?

No. Site owners always have the option of resorting to modalities other than the one identified by the Guarantor in the measure indicated above, provided that the chosen modalities present all the requirements for the validity of consent required by law.

12. Does the obligation to use the banner also burden the owners of sites that use only technical cookies?

No. In this case, the owner of the site can give the information to users in the manner it deems most appropriate, for example, also through the inclusion of the relevant indications in the privacy policy indicated on the site.

13. What does the “extended” information have to indicate?

It must contain all the elements required by law, describe analytically the characteristics and purposes of the cookies installed by the site and allow the user to select/deselect individual cookies.

It must include up-to-date links to the disclosures and consent forms of third parties with whom the owner has entered into agreements for the installation of cookies through its site.

Finally, it must recall the possibility for the user to manifest their options on cookies also through the settings of the browser used.

14. Who is required to provide information and request consent for the use of cookies?

The owner of the website that installs profiling cookies.

For third-party cookies installed through the site, the information and consent obligations fall on the third parties, but the owner of the site, as a technical intermediary between them and users, is required to include in the “extended” information the updated links to the information and consent forms of the third parties themselves.