This Policy has been updated in accordance with the guidelines for cookies and other tracking tools – 10 June 2021 (published in the Official Gazette no. 163 of 9 July 2021) issued by the Italian Data Protection Authority.
- Contact details of the Data Controller
Ad Hoc Communication Advisors Srl – Piazzetta U. Giordano 2 – 20122 Milan
Tel: +39 02 7606741 Fax +39 02 76017251
Any requests for information and/or clarifications may be sent to the Data Controller using the contact details given above or the following e-mail address: firstname.lastname@example.org.
- What are cookies?
Cookies are strings of text that the websites (known as Publishers or “first parties”) visited by the user, or other websites or web servers (known as “third parties”), place and store – directly, in the case of publishers, and indirectly, through the latter, in the case of “third parties” – in a terminal available to the user.
The terminals here referred to are, for example, a computer, a tablet, a smartphone, or any other device capable of storing information.
The internet browsing software and the way these devices operate, e.g. the browsers, can store cookies and then transmit them, on subsequent visits by the same users, back to the sites that generated them, thus keeping a record of their previous interaction with one or more websites.
The information encoded in cookies may include personal data, such as an IP address, a user name, a unique identifier or an e-mail address, but may also contain non-personal data, such as language settings or information about the type of device a person is using to browse the site.
Cookies can therefore perform important and diverse functions, including session monitoring, storing information on specific configurations of the users who are accessing the server and facilitating the use of on-line content, etc. They can, for example, be used to keep track of items in an on-line shopping cart or information used to fill out an electronic form.
The same result may also be achieved through the use of other tools (all of which may be distinguished between the so-called “active identifiers”, such as cookies, and “passive identifiers”, the latter based on simple observation), which allow processing operations similar to those indicated above.
The “passive” tools include fingerprinting, i.e. the technique that makes it possible to identify the device used by the user by collecting all or some of the information relating to the specific configuration of the device used by the data subject. This technique can be used to achieve the same profiling purposes that also aim at displaying personalised behavioural advertising and at analysing and monitoring the behaviour of visitors to the websites, or to conform the type and methods of the services provided to the behaviour of the user under previous observation.
- Cookies classification
Cookies and other tracking tools can be classified according to their duration (they can thus be session-based cookies or permanent cookies), or they can be classified as first-party cookies, installed directly by the website the user is visiting, or third-party cookies, installed by a domain other than the one the user is visiting.
The following is a classification of cookies according to their function.
|Technical cookies are those 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 contracting party or user to provide such service” (see Art. 122, paragraph 1 of the Privacy Code).
|They are used to trace specific actions or recurring behavioural patterns in the use of the available functions back to specific identified or identifiable subjects, in order to group the various profiles within homogeneous clusters of different sizes, so that it is possible for the Data Controller, inter alia, to modulate the provision of the service in an increasingly personalised manner beyond what is strictly necessary for the provision of the service, as well as to send targeted advertising messages, i.e. in line with the preferences shown by the user while surfing the web.
Below is all the information about the cookies installed through this site, and the necessary guidelines on how to manage all related preferences.
For more information on cookies and their general functions, see information sites such as http://www.allaboutcookies.org/
- Legal basis and data processing purpose
The cookies described are used for the purpose of enabling the website to function properly. As part of the browsing activities, information may be collected such as: internet protocol (IP) address; browser used; parameters of the device used to connect to the site; Internet Provider, time references relating to the visit (date and time), web page of origin of the visitor (referral) and exit; number of clicks. This information may only be used for statistical purposes without further interconnection with other data.
In the event that the users voluntarily fill in the forms available on the site, thus providing their data, these will be processed in order to fulfil pre-contractual requirements and to enable the Data Controller to contact the user again. Please note that at the bottom of each form you will find the relevant information on the processing of personal data.
Data processing by means of technical cookies does not require consent; on the contrary, the use of profiling cookies will take place only and exclusively on the basis of the specific consent of the user to be expressed using the appropriate banner options. Consent is free and optional and its absence does not affect proper navigation. Consent can be revoked at any time through the options available in the browser used for navigation (see also point 5.4).
- Cookies used by this Website
Following are the categories of cookies used by the website mentioned in the Introduction.
It should be noted that technical cookies or equivalent ones relate to activities that are strictly necessary for the functioning of the website and the provision of the service, and they are installed automatically once the website is accessed.
5.1 Tracking tools
Cookie Name: Google Analytics with anonymised IP
Purpose of use: Anonymous statistics services
Expiry date: Two years since the start of the session
Cookie Name: Cookie Solution by iubenda (Consent cookies) (iubenda srl)
Type: Third Party Tracking Tools
Purpose of use: Further information on Personal Data
Expiry date: One year since the start of the session
5.2 Social Network cookies
Social network icons are shown on the homepage of this website, allowing access to the relevant company page.
The links below provide details of the relevant policies:
For LinkedIn: http://www.linkedin.com/legal/cookie_policy
5.3 Managing preferences
With regard to cookies management, here are the steps to be taken to access and manage the settings to delete cookies (excluding those required for browsing) and links to the most popular browsers. For information on browsers not listed, please visit the developer’s website.
Click on the spanner icon in the top right-hand corner; select “Settings”; select “Show advanced settings”; change your “Privacy” settings.
Click on the icon with the three dots in the top right-hand corner; click on “Settings”. From the menu on the left, select “Cookies and site permissions” and change your cookie settings.
Click on the icon with the three horizontal bars at the top right and select “Options”; select “Privacy and security” to change your cookie settings.
Click on the icon with the three dots in the top right-hand corner and then on “Settings”. From the menu on the left, select “Cookies and site permissions” and adjust your cookie settings.
Click on the icon with the three horizontal bars in the top right-hand corner and then click on “Advanced”. Select “Confidentiality & Security” and then “Site Settings”. In the “Cookies and site data” section, adjust your cookie settings.
Click on “Preferences” and then on “Privacy” and proceed to change your cookie settings.
It should also be noted that a specific add-on is available to deactivate Google Analytics monitoring on all websites. This component is available at this link:
For more information about cookie management as well as enabling and disabling third-party cookies, visit the following links:
- Processing methods
Processing is carried out by automated and paper-based means.
- Disclosure of data to third parties
The data may be accessible to third parties such as authorities and supervisory and control bodies, and public authorities, in fulfilment of administrative or institutional requirements; service providers used by the Data Controller for the management of the aforementioned website (maintenance and updating of the site, services related thereto). These subjects may operate as independent Data Controllers or as properly accountable Data Processor.
- Data disclosure scope
No data is disclosed.
- Data provision
The processing of personal data by the Data Controller through the installation of technical and analytical cookies is necessary to allow the user to properly navigate the website. If profiling cookies are used, the data processed through these cookies will only be processed with the consent of the user.
As regards the spontaneous provision of data by the user who decides to fill in any forms on the website, it must be noted that data processing is carried out in accordance with the relevant information which the user has read.
Please also note that the user can choose which types of cookies to authorise by using the appropriate banner options or those offered by the browser used for navigation.
- Storage period
The data shall be stored for the time necessary to pursue the activities described above. Cookie expiry dates are available in section 5 et seq.
- Data transfer abroad
The transfer of data abroad is dependent on the use of the analysis services provided by Google LLC (via Google Analytics). Please refer to the relevant information:
- Rights of the Data Subject
The data subject may exercise the rights set out below in one of the following ways:
- by contacting our office at the following telephone number +39 02 7606741;
- by using our fax number +39 02 76017251;
- by sending an email to the address email@example.com.
The rights that the Data Subjects may exercise at any time are as follows: the right to access their data and information; the right to rectify inaccurate data or to supplement incomplete data; the right to cancel their personal data (in the cases provided for by the law); the right to limit the processing of their personal data (again, in the cases provided for by the law); the right to data portability; the right to object to the processing of their personal data in the event of special situations concerning them.
In addition, the Data Controller shall stop the processing when it receives a communication from the Data Subject withdrawing the consent previously given, if the consent constitutes the legal basis for the processing.
If you contact the Data Controller, please provide your e-mail address, name, address and/or telephone number so that your request can be properly handled.
Updated on: 22/07/2021