Trentini Francesco, Loc. Casale 4, 37010 Brenzone sul Garda (VR), Italy, VAT number 04608560233 and C.F. TRNFNC69S13F861W, as Data Controller pursuant to art. 4 n. 7) and 24 of EU Regulation no. 2016/679 (GDPR), illustrates, below, the cookie policy (“Policy”) referable to this website www.allmost.it (“Site”).
1. Legal framework of reference.
1.1. The Policy is based on the following EU and / or national regulatory provisions (first and / or second level): (i) Directive no. 2002/58 / EC of 12.7.2012 (so-called ePrivacy Directive), as amended by Directive no. 2009/136 / EC; (ii) art. 122 of the new Legislative Decree no. 196/2003 (Privacy Code), which transposed the ePrivacy Directive within the national legal system; (iii) GDPR: art. 4 n. 11), 7, 12, 13, 25 and 95 (in addition, in particular, to Recital no. 30, 32 and 173); (iv) Guidelines no. 5/2020 adopted on 4.5.2020 by the EDPB, replacing the Guidelines of 10.4.2018 signed by WP Art. 29; (v) Provision no. 231 of 10.6.2021 [Doc. web n. 9677876] signed by the Guarantor for the protection of personal data (Privacy Guarantor); (vi) Recommendation No. 2/2001 of the WP Art. 29; (vii) Opinion no. 2/2010 of WP Art. 29; (viii) Opinion no. 4/2012 of the WP Art. 29; (ix) Guidelines no. 8/2020 of the EDPB.
2. Cookies and other tracking tools: definition and classification.
2.1. “Cookies” are, as a rule, strings of text that a website (“publisher” or “first party”) visited by the user or a different website (“third party”) places and stores, directly ( in the case of the first-party website) or indirectly (through the latter, in the hypothesis of the third-party website), within a terminal device in the availability of the user: in this regard, the Privacy Guarantor has specified the fact that the information, encoded in the cookies, can include both personal data pursuant to art. 4 n. 1) of the GDPR (e.g. IP address; username; email address; unique identifier) and non-personal data pursuant to art. 3 n. 1) of the EU Regulation no. 1807/2018 (e.g. language; type of device used).
Alongside (or beyond) them, the “other tracking tools” may exist (and therefore be used), which can be divided into “active” (which have almost the same characteristics as cookies) and “passive” (eg . finger printing).
2.2. Beyond the described intrinsic characteristics, cookies (and other tracking tools) can record different peculiarities in terms of time (and, therefore, be considered “session” or “permanent”, due to their duration), from subjective point of view (depending on whether the publisher acts independently or on behalf of a “third party”) as well as, finally (but in particular), based on the processing purpose pursued, so as to be divided into two different ones (macro ) categories:
– “technicals”, used for the sole purpose of “carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contractor or user to provide such service “(Article 122 paragraph 1) of the Privacy Code).
In this regard, the Privacy Guarantor highlighted, within the Provision no. 231 of 10.6.2021 (in line with the previous Provision on the subject of 2014), that “analytics cookies” may well be included within the channel of cookies (or other tracking tools) of a “technical” nature (and, therefore, they can be used in the absence of the prior acquisition of consent by the interested party), upon the occurrence of certain conditions, aimed at precluding the possibility that, through their use, the direct identification of the interested party is reached (single out).
– “profiling” / “marketing” (so-called non-technical), used to bring back to specific, identified or identifiable subjects, specific actions or behavioral patterns recurring in the use of the features offered (patterns) in order to group the different profiles within homogeneous clusters of different sizes, so that it is possible for the Data Controller, among other things, to modulate the provision of the service in an increasingly personalized way beyond what is strictly necessary for the provision of the service, as well as send targeted advertising messages (that is, in line with the preferences expressed by the user in the context of surfing the net).
3. Cookies installed on the Site.
4. Responsibility for the operation of third-party cookies.
4.1. In this regard, the provisions of the Provision of 8.5.2014 signed by the Privacy Guarantor are faithfully recalled: “There are many reasons why it is not possible to place the obligation on the publisher to provide the information and acquire consent to the installation of cookies within its site also for those installed by “third parties”. In the first place, the publisher should always have the tools and the economic-legal capacity to take on the obligations of third parties and should therefore also be able to verify from time to time the correspondence between what is declared by the third parties and the purposes they actually have. prosecuted with the use of cookies. This is made very difficult by the fact that the publisher often does not directly know all the third parties that install cookies through their site and, therefore, not even the logic underlying the related processing. In addition, it is not uncommon for the publisher and third parties to interfere with subjects who play the role of concessionaires, making it very complex for the publisher to control the activities of all those involved. Third-party cookies could then be modified over time by third-party suppliers and it would be impractical to ask publishers to keep track of these subsequent changes as well”.
5. Browser settings.
5.1. Allmost highlights the possibility for the user to cancel and block the operation of the cookies described in the previous art. 3) at any time using the appropriate setting features in the browser used: in this regard, Allmost adds that, where the user decides to disable the technical cookies referred to in art. 2.1. point i), the quality and speed of the services and functionalities offered and made available on the Site could deteriorate.
5.2. Enabling or disabling cookies.
Below are some brief instructions and the related links to specific instructions on how to change the cookie settings through the browser tools with reference in particular to the four most popular navigation programs:
Microsoft Internet Explorer
Click the Tools icon in the upper right corner and select Internet Options. In the pop up window select Privacy. Here you can adjust the settings of cookies, adjusting the level of use of the same among the various options available.
https://support.microsoft.com/it-it/windows/eliminare-e-gestire-i-cookie-168dab11-0753-043d-7c16-ede5947fc64d#:~:text=Per%20eliminare%20i%20cookie,Web%20e%20quindi%20scegliere%20Elimina.
Google Chrome
Click the Customize icon and check Google Chrome; in the upper right corner and select Settings. At this point select Show advanced settings and then, in the Privacy section, click on Content settings. In the pop up window that will open, by clicking Manage exceptions, you can change the cookie settings, selecting or deselecting the cookies to be kept active or to be blocked.
https://support.google.com/chrome/bin/answer.py?hl=it&answer=95647&p=cpn_cookies
Mozilla Firefox
From the drop-down menu in the upper left corner, select Options. In the pop up window select Privacy. Here you can adjust your cookie settings.
https://support.mozilla.org/it/kb/Eliminare%20i%20cookie
Safari
From the drop-down setting menu in the upper right corner, select Preferences. Select Security and here you can adjust your cookie settings. We will keep the preferences regarding cookies thanks to a specific technical cookie having the characteristics specified in the previous table.
If you do not use any of the browsers listed above, select “cookies” in the relevant section of the browser used to find out where the cookie folder is and how to manage it.
https://support.apple.com/it-it/HT201265
