| 1.IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER |
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The Data Controller is the natural person – pro tempore legal representative – of epiqa S.r.l. Unipersonale with registered office in Piazza della Repubblica no. 32, 20124 Milan, certified email epiqasrl@legalmail.it email privacy@snaitech.it, Company Register, Tax Code and VAT number 01779230463. The pro tempore Data Protection Officer, for the purpose of this disclosure domiciled at the registered office of the Data Controller, may be contacted at the following email address: dpo@epiqa.it |
| 2.PURPOSES OF THE PROCESSING |
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Your personal data are collected and processed for the following purposes:
(1) to ensure and optimize the navigation and use of the website,
(2) to improve the use of the website, through the activity of analyzing data/information (consisting, for example, of the number of users and how they visit the website) in aggregate and anonymous form. |
| 3.LEGAL BASIS FOR THE DATA PROCESSING |
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The legal basis for the aforementioned processing is contractual. Personal data may be processed using IT tools in compliance with the provisions on the protection of personal data and, in particular, the security measures to ensure the required confidentiality. |
| 4.CATEGORIES OF PERSONAL DATA |
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Navigation data (e.g., IP addresses, pages visited, the server response status code, device type and operating system used to connect to the website) |
| 5.WHAT ARE COOKIES? |
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Cookies are small text strings exchanged between a server and the web client. Specifically, they are files that a site sends to the user’s browser and are stored on the user’s device.
During navigation, minimal amounts of information will be collected in the devices in use (whether computers or mobile devices), in small text files – referred to precisely as “cookies” – saved in the directories used by the User’s web browser, for varying periods of time depending on the need and generally ranging from a few hours to a few years.
The information recorded on the User’s device may be reused during the same visit to the websites (session cookies) or later, even days later (persistent cookies). Cookies are stored, based on the user’s preferences, by the individual browser on the specific device used (computer, tablet, smartphone).
Cookies can be classified according to:
- duration: session or persistent cookies
- origin: first-party or third-party cookies
- nature: technical, analytical, or profiling cookies.
Cookies that expire at the end of a browser session (normally when a user closes their browser) are referred to as session cookies and are useful, for example, to store a user’s purchase order or for security purposes, such as when accessing their internet banking or webmail account. Cookies that, on the other hand, are stored for a longer period (between sessions) are called persistent cookies and are useful, for example, to remember user preferences or to serve targeted advertising.
The definition of first-party or third-party refers to the website or domain that installs the cookie. First-party cookies are installed directly by the website the user is visiting, while third-party cookies are installed by a domain different from the one the user is visiting, for example in the case where the website incorporates elements from other sites, such as images, social media plugins, or advertisements. |
| 6.CATEGORIES OF COOKIES |
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This website uses only cookies all belong to the category of “technical cookies” that do not require the acquisition of consent since, as mentioned above, the legal basis is contractual; the category of “technical cookies”, includes within it both “strictly necessary cookies” and “anonymized analytical cookies”.
(a) Strictly necessary cookies
These cookies are used for the operation of the website, with particular reference to the normal navigation and enjoyment of the same. They are not used for any further purposes and are usually installed directly by the Website Owner (so-called of First Party). Without the use of such cookies, some operations could not be performed or would be more complex and/or less secure.
(b) Anonymized analytical cookies
Analytical cookies, which can be first- or third-party, are installed to collect information about the use of the website. In particular, they are useful to statistically analyze accesses or visits to the website itself and to allow the owner to improve its structure, navigation logic and content.
In this case, these are anonymized cookies (so-called Third-Party cookies – our partner is: Google http://www.google.com/policies/privacy/) which, in accordance with the reference legislation – “Guidelines on the use of cookies and other tracking tools” approved by the Italian Data Protection Authority and in force since January 10, 2022 – are considered in the same way as “technical cookies”, therefore, the legal basis is contractual and therefore the acquisition of users’ consent is not required for their installation.
In addition, following the Italian Data Protection Authority’s June 9, 2022, ruling on the “non-compliance of Google Analytics 3 (c.d GA3) with the GDPR,” EPIQA has adopted the updated version Google Analytics 4 (c.d GA4), with the default setting that provides only the collection of granular location and device data.
**NOTE: We are constantly monitoring the ongoing regulatory review of Google Analytics and related data use and, therefore, this section may be subject to updates as a result of new national or European measures/rulings on the matter** |
| 7.RETENTION PERIOD
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a)Strictly necessary cookies
| Name |
Functionality of the cookie |
Retention period |
Geographic locations |
Does the website work without such cookies? |
| CookieConsent |
Stores the user’s cookie consent status for the current domain |
1 year |
EU |
YES |
| td |
Registers statistical data on users’ behaviour on the website. Used for internal analytics by the website operator. |
Session |
US |
YES |
| _wpfuuid |
Registers a unique ID for the visitor in order for the website to recognize the visitor upon re-entry. |
11 years |
EU |
YES |
| elementor |
Used in context with the website’s WordPress theme. The cookie allows the website owner to implement or change the website’s content in real-time. |
Persistent |
EU |
YES |
| wp-wpml_current_language |
Designates the country code that is calculated based on the user’s IP address. Used to determine what language should be used for the visitor. |
Session |
EU |
YES |
b) Anonymized analytical cookies
| Name |
Functionality of the cookie |
Retention period |
Geographic locations |
Does the website work without such cookies? |
| _ga_# |
Used by Google Analytics to collect data on the number of times a user has visited the website, as well as dates for the first visit and most recent visit. |
2 years |
USA |
YES |
| _ga |
Records a unique ID used to generate statistical data on how the visitor uses the website. |
2 years |
USA |
YES |
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| 8.THIRD-PARTY COOKIES FOR INTERACTION WITH SOCIAL NETWORKS AND/OR EXTERNAL PLATFORMS |
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These cookies are installed/transmitted by Third Parties (who act as Data Controllers by adopting their own data protection policies, to which you are referred to learn about the information inherent to the processing of personal data) through a website other than the one you are currently visiting and cannot be inhibited by the website owner.
This category includes, for example, cookies that enable a series of interactions with social networks (e.g., Facebook/Meta) and/or other external platforms, if there are dedicated sections on the pages of the relevant website (e.g., “Like” buttons and/or widgets). |
| 9.COOKIE MANAGEMENT FROM BROWSER SETTINGS |
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However, users can also express their preferences about browser cookies through the browser’s settings. By default, almost all web browsers are set to automatically accept cookies, but users can change the default configuration through the settings of the browser they use, which allow them to disable and/or delete all or some cookies or block cookies from being sent or limit them to certain websites. Disabling cookies or deleting them may affect the optimal use of certain areas of the website or prevent certain functionality, as well as affect the operation of third-party services. The configuration of cookie management depends on the browser used. For further details, please refer to the instructions within each browser used (e.g., Chrome, Firefox, Edge, Safari, Opera, etc.). |
| 10.TRANSFER OF DATA ABROAD |
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Personal data will not be transferred abroad to countries outside the EU which do not assure adequate levels of data protection. |
| 11.COMPULSORY OR OPTIONAL SUBMISSION OF DATA AND CONSEQUENCES OF NON-DISCLOSURE |
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The submission of personal data processed through the installation of technical cookies is mandatory for the purposes indicated in the reference paragraph (“Purposes of the processing”). |
| 12.RIGHTS OF DATA SUBJECTS (ARTICLE 15–22 OF THE GDPR) |
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In relation to the processing of your personal data, where the necessary conditions are met, you have the right to request EPIQA S.r.l. to confirm the existence of personal data concerning you, to obtain access to personal data and its rectification, cancellation, limitation of processing and portability to another Data Controller if allowed. We inform you that you always have the right to lodge a complaint with the Data Protection Authority to exercise your rights or any other matter relating to the processing of your personal data. The aforementioned rights may be exercised by means of a request sent to the Data Controller by email or registered letter to the above-mentioned addresses. |
| 13.REGULATIONS AND REQUIREMENTS REGARDING THE PROCESSING OF PERSONAL DATA THROUGH COOKIES |
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The contents herein comply with the provisions:
– EU Regulation 2016/679 (GDPR),
– of European Directive 2009-136-EC, which requires operators of websites that use cookies or other tracking technologies to inform the user about the types of any cookies used by the website,
– contained in Provision No. 229 of May 8, 2014, from the Italian Data Protection Authority,
– recalled in the “Guidelines on the use of cookies and other tracking tools” of the Italian Data Protection Authority, which came into force on January 10, 2022.
The Data Controller – in the face of further regulatory provisions, decisions/opinions on the subject – will provide where necessary to update the Cookie policy. |
