Cookie Policy

Since so-called cookies are used on our Site for various purposes, with this notice we wish to explain what cookies are and how they are used on the Site.

Some cookies (so-called own or first-party cookies) are placed and controlled directly by Us. Through these cookies, the Company collects and processes certain personal data concerning you. In this notice, pursuant to Art. 13 of EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter, “Regulation”) and Legislative Decree 196/2003 (hereinafter, “Privacy Code” and, together with the Regulation, “Applicable Legislation”), we explain how we collect this data, for what purposes and what your rights are.

Other cookies (so-called third-party cookies), on the other hand, are placed and controlled by third parties, as better described below. In this notice you will find links to the notices published by these third parties, which we ask you to read carefully.

If you are not familiar with cookies, please read this notice and the general privacy notice of the Site carefully, so that you may be aware of your choices.

The Company attaches the utmost importance to the right to privacy and the protection of its Users’ personal data. For any information relating to this cookie notice, Users may contact the Company at any time, using the following methods:

• By sending a registered letter with return receipt to the Company’s registered office (Via Sebastiano Venier, 200, 35127 PADUA);
• By sending an email message to: privacy@ciels.it

The Company has not appointed a Data Protection Officer (DPO), as it is not subject to the appointment obligation provided for by Art. 37 of the Regulation.

A. What cookies are and what they are used for

Cookies are small text files that the websites visited by the user send directly to the user’s device (usually to the browser), where they are stored and then retransmitted to the same websites upon the user’s next visit (so-called own first-party cookies). While browsing a website, the user may also receive cookies on their device from different websites or web servers (so-called third-party cookies); this happens because the visited website may contain elements such as images, maps, sounds, specific links to web pages of other domains that reside on servers other than the one on which the requested page is located. In other words, these are cookies set by a website other than the one currently being visited.

Cookies may have a duration limited to a single browsing session on the browser (so-called session cookies), and in this case they are automatically disabled when the user closes the browser; or they may have a predetermined expiry date and, in that case, they will remain stored and active on your hard drive until that expiry date, continuing to collect information during different browsing sessions on the browser (so-called persistent cookies).

Cookies are used for various functions. Some are necessary to allow you to browse the Site and use its features (so-called technical cookies). Others are used to obtain statistical information, in aggregated or non-aggregated form, on the number of users accessing the Site and how the Site is used (so-called monitoring or analytics cookies). Finally, others are used to track your consumer profile and display advertising messages on the Site that may be of interest to you, as they are consistent with your tastes and consumption habits (so-called profiling cookies).

To learn more in detail about these different categories of cookies, continue reading this notice. Find out how they work and what they are used for, and freely choose whether to consent to their use or prevent it.

B. Technical tools

1. Technical cookies

Technical cookies are used on the Site solely to make it possible for you to browse the Site and to allow you to use its features. These are always first-party cookies, as they are placed directly by Us on the Site.

Some technical cookies are essential to provide you with an optimal browsing experience or to allow you to authenticate on the site, for example to make a purchase on the Site or enter your reserved area (so-called browsing cookies). Browsing cookies are normally session cookies and, therefore, once the browsing browser is closed, they are automatically disabled.

Other technical cookies are useful to allow you to store some of your preferences (for example, language or country of origin) without having to reset them during subsequent visits (so-called functionality cookies). For this reason, functionality cookies are often persistent cookies, as they remain stored on your computer even after the browsing browser is closed, until their scheduled expiry date or until you decide to delete them.

The following technical cookies are currently used on the Site:

1. Saving the User’s preferences

As provided for by the Applicable Legislation, your prior consent is not required for the installation of the technical cookies referred to in the previous paragraph B.1. Of course, you are free to block the installation of technical cookies by changing your browser settings (read paragraph E, no. 1 to find out how). Please consider, however, that by blocking the installation of technical cookies, or subsequently deleting them, the possibility of accessing the Site, using all or part of it, enabling or disabling certain functions or receiving certain services may be wholly or partially compromised.

On the other hand, for the installation of cookies and/or other tracking tools other than technical ones, such as profiling cookies, your prior consent is required. For this reason, when you access the Site, a specific banner is displayed prominently, also called a Consent Management Platform; hereinafter, “CMP”, which informs you that, subject to consent, non-technical cookies are used on the Site and that by pressing the relevant button provided therein, you may consent to the use of cookies.

If you express your consent to the installation of cookies in this way, we will keep track of your consent through a specific technical cookie or through other technical methods linked to the use of the CMP, which allow the documentation of the User’s choices to be kept constantly updated. In the latter case, the Company may process, for this purpose, metadata relating to the granular choices made by the User: the possible expression of consent, the details of the granular purposes for which the User has given consent, as well as the User’s possible choice to continue browsing while maintaining the default settings by pressing the relevant button provided by the CMP.

In this way, we will avoid showing you the cookie CMP during your subsequent visits to the Site and we will keep track of your choices in line with what is required by the Applicable Legislation.
Please consider that, if the Company uses a technical cookie or other methods to demonstrate that your consent has been obtained and to keep the documentation of the User’s choices constantly updated, and you delete this technical cookie or other tool used for this purpose from your browser in the manner set out in the following paragraph E, no. 1, the trace of your consent may be lost and, therefore, during your next visit to the Site the CMP may be displayed again.

C. Monitoring or “analytics” cookies

Analytics cookies are used on the Site to collect statistical information, in aggregated or non-aggregated form, on the number of users accessing the Site and how they visit the Site itself.
Third-party analytics cookies are installed on the Site only with your prior consent:

Of course, you are free not to give consent for the installation of analytics cookies and to object to their use at any time, without the possibility of visiting the Site and using its content being compromised in any way. To find out how, carefully read the third-party cookie notices by following the links shown in the table above.

Profiling cookies

Profiling cookies are used to create your user profile, based on the preferences and tastes you express while browsing the Internet, and to display advertising messages consistent with your profile. In this way, the advertising messages you see on our Site may be of greater interest to you.

Of course, you are free not to give consent for the installation of profiling cookies and to object to their use at any time, without the possibility of visiting the Site and using its content being compromised in any way. If you decide to disable behavioral advertising, this does not mean that you will no longer receive advertising on the Site. However, the banners you see on the Site may not reflect your interests or preferences on the browser you are currently using.

1. First-party profiling cookies

Some profiling cookies are installed directly by the Company or are tools through which the Company collects data as data controller or, in some cases, joint controller together with the provider of such cookies, as specifically indicated by the cookie provider in the privacy notice shown in the table in this paragraph D.1.

Below is the list of first-party profiling cookies used on the Site, with more details about each of them as well as the methods through which you may object to their installation:
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D.2. Third-party profiling cookies

In addition, other profiling cookies are installed on the Site by third parties, third-party cookies. Below is a list of the third-party profiling cookies currently used on the Site, with a link to the information pages created by their developers, also containing information on how to object to their installation, so-called opt-out, and on the related retention periods:

Some third-party cookies are installed by entities with which we do not have a direct contractual relationship. For this reason, we provide below links to the websites of the entities acting as intermediaries between Us and these third parties, on which you may find (i) the list of third parties that install profiling cookies on the Site and (ii) links to the privacy notices of those third parties, where you can obtain all necessary information on their profiling cookies and on how to object to their installation, opt-out:

The Company also informs Users that through the Google AdServer used by the Company, advertisers or additional third parties may be enabled to use cookies linked to advertising messages, in order to collect information on the User’s browsing activities.

Likewise, additional Company partners indicated within the CMP may process the User’s personal data to provide advertising, including interest-based advertising. For the relevant notices, please refer to the links next to each vendor within the CMP.

E. How to manage cookies and object to their use

There are several options for managing, disabling and deleting cookies.

(1) Change your browser settings

Follow the instructions provided by the manufacturer of the browser you use to find out how to manage, disable or delete all cookies:

• Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
• Chrome: https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies
• Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
• Safari: https://support.apple.com/it-it/guide/safari/manage-cookies-and-website-data-sfri11471/
• Opera: https://help.opera.com/en/latest/web-preferences/

Make your choices carefully. By indiscriminately blocking the receipt of all cookies, including technical cookies, without providing a specific exception for the Site, you may in fact no longer be able to browse the Site or use all or part of its features. In addition, by deleting all cookies from the browser, technical cookies may also be removed and, therefore, you may remove the preferences you have set using the Site.

(2) Use the interactive tools provided by third parties

To disable first-party profiling cookies, namely those installed directly by Us, you can simply use the interactive button(s) highlighted in paragraph D of this notice. Your choice to object to the use of these cookies will have no consequence on the possibility of browsing the Site and using its features, and may in any case be revoked by you at any time using the same interactive button.

To disable third-party cookies, consult the information pages of the third parties that install analytics cookies (see previous paragraph C) or profiling cookies (see previous paragraph D) to learn about the tools available to you to manage, disable and delete cookies and, more generally, to object to their use. Remember that, by disabling third-party cookies, (i) you object to their use not only on the Site but on all websites where such cookies are used and (ii) the possibility of browsing the Site and using its features will not be affected in any way.

(3) Use the website www.youronlinechoices.eu/it/

Your Online Choices is a website managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA), whose Italian-language version can be reached at www.youronlinechoices.eu/it/, which provides information on behavioral advertising based on profiling cookies (http://www.youronlinechoices.com/it/a-proposito) and allows Internet users to easily object (opt-out) to the installation of the main profiling cookies installed by advertising operators and used on websites (http://www.youronlinechoices.com/it/le-tue-scelte). Before using this tool, we recommend that you carefully read the general terms of service of the Your Online Choices website (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).

Use Your Online Choices knowingly. Although Your Online Choices brings together many of the most important companies in the advertising world that use cookies, some of the third parties that install cookies through the Site may not have joined Your Online Choices. Therefore, using Your Online Choices does not guarantee that you will receive third-party cookies when browsing the Site. Remember also that by deleting all cookies from your browser, the technical cookies released by Your Online Choices to remember your choices may also be deleted, making third-party cookies active again.

(4) Use the CMP

For the processing of personal data that, subject to the User’s consent, third-party companies may carry out through cookies, the User may also use the CMP implemented on the Site, to give or revoke consent by following the relevant instructions.

F. Data processing methods and retention periods

As highlighted in the introduction to this notice, the Company may collect and process some of your personal data through cookies that it places directly on the Site or cookies placed by third parties acting on behalf of the Company on the basis of a specific appointment as data processor pursuant to Art. 28 of the Regulation (first-party cookies). The Company acts as data controller for this data, in accordance with the provisions of the Applicable Legislation. We will process your data only with electronic tools, in a fully automated manner and without human intermediation. Therefore, our collaborators will never access the content of your personal data obtained through cookies, which means that they will never be able to access and/or have PII (Personally Identifiable Information), namely information from which it will be possible to identify you directly.

Some of our employees and/or collaborators, appointed by Us as persons authorized to process data pursuant to Art. 29 of the Regulation, may carry out maintenance operations on the IT systems that host your data, without ever being able to access their actual content.
Personal data may be stored on servers managed by third parties, such as IT system providers, or may be managed by entities specialized in online advertising, acting as data processors pursuant to Art. 28 of the Regulation, on the basis of a specific written appointment by the Company.

Your personal data will not be communicated to third-party data controllers nor will it be disseminated.

Your personal data, collected by the Company through the technical cookies referred to in the previous paragraph B, will be stored for the time strictly necessary to fulfill the primary purposes illustrated in this notice, or in any case as necessary to protect the rights and interests of both Users and the Company.

As regards, instead, the duration of the cookies themselves, including third-party cookies, and the retention periods of the data collected by third parties, please refer to the tables included in this notice.

Transfers of personal data to a third country

We inform you that, in compliance with the conditions and safeguards established by the Regulation, your data may be transferred to countries that do not belong to the European Economic Area (so-called EEA). Such countries may not offer a level of privacy and personal data protection comparable to that guaranteed by the Applicable Legislation; where the Company acts as data controller, we will take the security of the data into utmost consideration and, therefore, will manage such transfers with all due precautions and safeguards in accordance with the Applicable Legislation and, in particular, in accordance with Arts. 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to appropriate safeguards) of the Regulation.

Specifically, for the provision of the Google Analytics service (referred to in previous paragraph C), the Company’s provider, Google Ireland Limited, may transfer the pseudonymous personal data of Site Users outside the EEA, on the basis of the so-called Standard Contractual Clauses or an Adequacy Decision: in particular, to the United States, the data will be transferred on the basis of the Data Privacy Framework certification adopted by Google LLC (more information available at the following link). In view of the scope of processing, the nature of the data processed and the risks of the processing carried out by the provider, the Company has deemed appropriate the additional security measures that the provider guarantees to adopt to protect the personal data processed on behalf of the Company itself.

It should be noted that some of the third parties indicated in the tables in this notice and/or in the CMP may, as independent data controllers of the data collected through third-party cookies, process the personal data collected through the cookies installed on this Site from a location outside the European territory and, therefore, we recommend carefully reading their notices listed above for further details in this regard.

H. Your rights

To exercise your rights, or obtain any further information or clarification in relation to this cookie notice, please contact the Company in the following ways:

• By sending a registered letter with return receipt to the Company’s registered office (Via Sebastiano Venier, 200, 35127 PADUA);
• By sending an email message to: privacy@ciels.it.

The Company has not appointed a Data Protection Officer (DPO), as it is not subject to the appointment obligation provided for by Art. 37 of the Regulation.

Pursuant to the Applicable Legislation, Users have:

1. the right to withdraw consent at any time, where the processing is based on their consent;
2. the right of access to personal data;
3. (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and machine-readable format), the right to restriction of processing of personal data, the right to rectification and the right to erasure (“right to be forgotten”);
4. the right to object:
   1. in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if relevant to the purpose of collection;
   2. in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
5. where they believe that the processing concerning them violates the Regulation, the right to lodge a complaint with a Supervisory Authority (in the Member State where they habitually reside, where they work or where the alleged violation occurred). The Italian Supervisory Authority is the Italian Data Protection Authority, with registered office at Piazza Venezia, no. 11, 00186 – Rome (RM) (http://www.garanteprivacy.it/).

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The Company is not responsible for updating all links displayed in this cookie notice; therefore, whenever a link is not working and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by that link.