Cookie – Policy

Cimbali Group S.p.A. with registered office in Via A. Manzoni 17 – 20082 Binasco (MI), (hereinafter, the “Company“) provides below information on navigation data and the operation of cookies and other tracking tools, within the site www.cimbaligroup.com (“Site“), also on the basis of the guidelines provided by the Guarantor for the protection of personal data. For the purposes of this statement, the term “cookies” also refers to other tracking tools used by the Site, as described below.

The following information (“Cookie Policy“) is provided for the Site and not for other third-party websites that may be consulted by the user through links.

This Cookie Policy governs the processing of personal data of users (“Users“) by means of cookies and other tracking tools and should be read in addition to the Privacy Policy available at the page “Privacy Policy”, which should be referred to for any other information on the processing of personal data.

1. Browsing data, cookies and other tracking tools

• Navigation data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified persons, but by their very nature could, through processing and association with data held by third parties, allow Users to be identified.

This category of data includes IP addresses or domain names of computers used by Users who connect to the Site, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the User’s computer environment.

These data are used only to obtain anonymous statistical information on the use of the Site and to check its correct functioning and are deleted immediately after processing.

The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Site: except for this possibility, the data are stored for the time defined by the relevant legal regulations or, in general, for the time strictly necessary to provide the User with the requested service and to ensure the transmission of the communication.

• Cookies and other tracking tools

Cookies are usually strings of text that websites (so-called publishers or “first party”) visited by the User or other websites or web servers (so-called “third parties”) place and store – directly, in the case of publishers, and indirectly, i.e. through them, in the case of “third parties” – in a terminal device available to the User. The terminals referred to are, for example, a personal computer, a tablet, a smartphone, or any other device capable of storing information.

Internet browsing software and the operation of these devices, such as browsers, can store cookies and then transmit them back to the sites that generated them on the occasion of a subsequent visit by the same User, thus keeping memory of his previous interaction with one or more websites.

The information encoded in cookies may include personal information, such as an IP address, User name, unique identifier, or email address, but may also contain non-personal information, such as language settings or information about the type of device a person is using to browse the Site.

Cookies can therefore carry out important and different functions including, session monitoring, the memorization of information on specific configurations regarding the Users who access the server, the facilitation in the fruition of online contents etc. They can, for example, be used to keep track of the items in an online shopping cart or the information used to fill out a computer form. If, on the one hand, it is through cookies that it is possible to allow, among other things, web pages to load more quickly, as well as to route information on a network – in line, therefore, with obligations strictly connected to the very operation of websites -, again through cookies it is also possible to convey behavioural advertising and then measure the effectiveness of the advertising message, that is to say to conform the type and modalities of the services rendered to the behaviour of the User under previous observation.

The same can also be achieved through other tools (all of which can be distinguished between the so-called “active identifiers”, such as cookies, and “passive”, the latter assuming the mere observation), which allow to carry out treatments similar to those mentioned above.

• Types of cookies

Cookies and other tracking tools can have different characteristics in terms of time and therefore be considered according to their duration (session or permanent), or from a subjective point of view (depending on whether the publisher acts independently or on behalf of the “third party”). However, the classification that mainly meets the needs of User protection is the one based on two macro categories:

• technical cookies, used for the sole purpose of “carrying out the transmission of a communication on an electronic communication 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); these cookies can be installed on the User’s terminal without the User’s consent, based, depending on the case, on the need to carry out a request or on the legitimate interest of the Company;
• profiling cookies, used to refer to specific subjects, identified or identifiable, specific actions or behavioral patterns recurring in the use of features offered (pattern) in order to group the different profiles within homogeneous clusters of different sizes, so that it is possible for the owner, among other things, also to modulate the provision of the service in an increasingly personalized beyond what is strictly necessary to provide the service, as well as send targeted advertising messages, that is, in line with the preferences expressed by the User during navigation on the network; this type of cookie can be downloaded to the User’s terminal only with the latter’s consent.

Cookies can also be used, among other things, to assess the effectiveness of an information society service provided by a publisher, for the design of a website or to help measure its “traffic”, i.e. the number of visitors also possibly broken down by geographical area, time of connection or other characteristics. These identifiers, defined as analytics cookies, may be included in the category of technical cookies, and as such may be used without the prior consent of the interested party, provided that the following conditions occur:

• are used only to produce aggregate statistics and in relation to a single site or mobile application;
• at least the fourth component of the IP address is masked for third-party ones;
• the third parties refrain from combining these analytics cookies with other processing (customer files or statistics of visits to other sites, for example) or from transmitting them to third parties.

If these conditions are not met, analytics cookies also require the User’s consent to be downloaded.

Finally, cookies may also be used to enable interaction and easy sharing of content on social networks and/or to enable targeted advertising based on User preferences (social cookies); these cookies also require the User’s consent.

Like cookies, other tracking tools can be categorized according to a number of different criteria, the main one being, however, the purpose for which they are used: technical or commercial.

2. List of cookies used by the Site

This Site uses cookies for technical, analytical and statistical purposes, to improve User interactivity with the Site via social networks and to customize the delivery of information and advertising communications according to the interests of the User (profiling).

• Technical cookies

Below, for each technical cookie used by the Site, we report: the name, the purpose of use and the duration.

 

For the installation of technical cookies is not required prior consent of Users. All browsers, however, allow you to change cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. To understand these settings, the following links may be helpful. Or you can use the “Help” option in your browser for more information.

• Cookie settings in Explorer/Edge
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari and iOS

If you block the use of cookies, the service provided to you through the Site will be limited, thereby affecting your experience of using the Site.

• Non-technical cookies

Below, for each cookie used by the Site that does not fall into the category of technical cookies, we report: the name, the relevant third party if the cookie is not a first party, the purpose of use and duration.

For all the information relating to cookies provided by third parties and for the methods of opting out of individual cookies, it will be possible to access the respective information as well as the tool provided by the third party for opting out of individual cookies.

Please note that the following link allows you to opt-out of third-party cookies (i.e. companies that are members of the WebChoices tool of the Digital Advertising Alliance, including Facebook) installed on your browser: https://optout.aboutads.info/?c=2&lang=EN

You can also use the following tool provided by Your Online Choices to control your preferences by opting out of third-party cookies: https://www.youronlinechoices.com/it/

Profiling cookies

 Profiling cookies are non-technical cookies that allow the Company to provide personalized services. The Company uses the profiling cookies indicated below.

 

The communication of personal data is purely optional. In case of non-disclosure of data, it will be impossible for the Company to provide you with personalized services through profiling. The legal basis of the treatment is the consent, expressed in accordance with current legislation.

Analytical (non-technical) cookies

In the case of use of third party statistical cookies, the Company has contractually bound the third party to use them solely for the provision of the service, to store them separately and not to “enrich” or “cross-reference” them with other information they have.

 

Social cookies  

Other social features (e.g. plugins)

In addition to the above mentioned cookies, the Website also incorporates plugins and/or buttons in order to allow easy sharing of content on the following social networks: Facebook, Instagram, Twitter, YouTube. When the User visits a page of the Site that contains a plugin, the browser of the Site connects to the server of the social where the plugin is loaded, which server can track the visit to the Site and, if necessary, associate it with the social’s account, in particular if the User is logged in at the time of the visit or if he/she has recently surfed one of the websites containing social plugins. If you do not want social to record data about your visit to the Site, you must log out of your social account and delete the cookies that social has installed in your browser.

In relation to certain activities, the Company and the social may also act as joint controllers within the meaning of Article 26 of the GDPR, in particular when the Company, via a plugin, jointly determines with the social the purposes and means of processing consisting in the collection and transmission of User data to the social. The Company, in such cases, adheres to the contractual conditions of the social, which may include co-ownership agreements.

In particular, with respect to Facebook plug-ins, the Company and Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland act as joint controllers and the relevant joint ownership agreement (“Data Controller Appendix“) can be found at the following link: [https://it-it.facebook.com/legal/terms/page_controller_addendum]. Facebook Ireland is responsible for the data subjects’ rights pursuant to Articles 15-20 of the GDPR in relation to the personal data stored by Facebook Ireland after joint processing. The following supervisory authority is responsible for Facebook: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland (https://www.dataprotection.ie/).

Regarding instead the Linkedin Page Insights service, the joint ownership agreement between Linkedin and called “Page Insights Joint Controller Addendum (the Addendum)” is available at the following link: https://legal.linkedin.com/pages-joint-controller-addendum

Finally, it should be noted that any co-ownership, in any case, does not extend to treatments carried out by the social in relation to which the Company does not determine the purposes and means of treatment (eg operations carried out by the social after the communication of User data by the Site).

With reference to the collection and use of information by the socials, please refer to their respective privacy policies.

• Facebook (link to cookie information);
• Instagram (link cookie information);
• Twitter (link to cookie information);
• YouTube (link to cookie information).

3. Tracking tools

Below are the tracking tools used on the Site:

• Google Analytics
• Facebook
• Google Maps
• GeoTargetly.

4. Personal data retention period

The Company will keep the personal data processed with technical cookies in order to allow proper use of the Site for a period not exceeding 12 (twelve) months from the date of individual collection, in accordance with the provisions of point 2.2. of the Cookie Policy;

The Company will retain the personal data processed to provide personalized services through non-technical and profiling cookies for a period not exceeding 12 (twelve) months from the date of individual collection, in accordance with the provisions of point 2.2 of the Cookie Policy;

The Company will keep the personal data provided voluntarily and processed to respond to requests for a period of time strictly necessary to achieve this purpose and, in any case, not more than 12 (twelve) months from the date of individual collection.

The Company reserves the right, in any case, to request the renewal of consent to treatment and / or to verify the consents already expressed.

5. Data protection rights

Every User has the right to obtain from the Company, subject to the existence of the legal prerequisite underlying the request:

• access to personal data concerning him/her;
• the cancellation of personal data, as well as their rectification;
• the rectification of personal data held by the Company;
• revocation of consent in cases where processing is based on consent;
• the limitation of the processing of personal data;
• the copying of personal data provided by Users to the Company, in a structured, commonly used and machine-readable format (portability) and the transmission of such personal data to another data controller;
• human intervention in the automated decision-making process, to express one’s opinion, to obtain an explanation of the decision reached by the Company and to contest it, in the case of consent to processing with profiling cookies in order to use personalized services.

Right to object: in addition to the rights listed above, the User is always entitled to object at any time, for reasons related to his particular situation, to the processing of his personal data carried out by the Company in pursuit of its legitimate interests and to the processing of his personal data for marketing purposes. The User may object to the processing of personal data for direct marketing purposes even if only in part, for example by objecting only to the sending of promotional communications by automated and/or digital means, or to the sending of paper communications and/or the receiving of telephone communications.

In addition, the User, as a contracting party, always has the right to object at any time, free of charge, to receiving commercial communications from the Company.

The User may exercise the rights indicated by addressing the requests directly to the Company at the email address: privacy@cimbaligroup.com or by sending the relative communication by registered letter with return receipt to the address Via A. Manzoni 17 – 20082 Binasco (MI).

Should the User exercise any of the aforementioned rights, it will be the responsibility of the Company to verify that the same is legitimate to exercise it and will be given feedback, as a rule, within one month.

If the User believes that the processing of his personal data is in violation of the provisions of the applicable legislation on the protection of personal data, he has the right to complain to the Guarantor for the protection of personal data, using the references available on the website https://www.garanteprivacy.it/, or to take legal action.

6. Changes

The Company may modify the Cookie Policy, also in order to comply with national and/or European Union legislation or technological innovations. Any new versions of the Cookie Policy will be posted on the Site. Users are invited to periodically check the Cookie Policy. Any changes will be communicated through a pop-up on the Site or by other means and/or computer tools. If the Company substantially modifies the Cookie Policy, providing for new purposes of treatment and / or categories of personal data processed or changing the third parties, the Company will inform Users, requesting the necessary consents, through a special banner. If it is impossible for the Company to verify that the cookies have been stored on the device on the occasion of a subsequent visit to the Site, for example in case of cancellation of the cookies installed, the Company will inform the Users, requesting the necessary consents, by means of an appropriate banner. If at least 6 (six) months have elapsed since the previous presentation of the banner on the Site, the Company itself will inform Users, requesting the necessary consents, by means of an appropriate banner.

7. Contact

The contact details of the Company, for questions and for the exercise of rights regarding the processing of personal data are as follows: privacy@cimbaligroup.com

Last updated: October 18, 2023