Cookie Policy

1. guarantee and optimise the navigation and use of the website, also according to the criteria selected by the user (e.g. language, products, etc.);
2. improve the use of the website, through the analysis of data/information in aggregate and anonymous form.

During browsing, minimal amounts of information are collected in the devices used (whether computers or mobile devices) in small text files – specifically called “cookies” – which are stored in the directories used by the user’s web browser, for periods that vary according to need and generally range 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 sites (session cookies) or later, even after days (persistent cookies). Cookies are stored by the individual browser on the specific device being used (computer, tablet, smartphone) according to the user’s preferences.

Cookies can be classified according to:

• duration: session or persistent cookies;
• provenance: first-party or third-party cookies;
• nature: technical, analytical or profiling cookies.

With regard to duration, cookies that expire at the end of a browser session (normally when a user closes their browser) are called 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 are stored for a longer period of time (between sessions) are called persistent cookies and are useful, for example, for remembering user preferences or providing targeted advertising.

With regard to the provenance, 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 other than the one the user is visiting, for example when the website incorporates elements from other sites, such as images, social media plug-ins or advertising.

With regard to the nature, in accordance with the “Guidelines on the use of cookies and other tracking tools” adopted by the Italian Supervisory Authority and in force since 10 January 2022, the classification of cookies carried out by SNAITECH on its website is as follows:

• technical cookies: 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 company service expressly requested by the contractor or the user to provide such service” (see art. 122, paragraph 1 of the Privacy Code), this category includes both “strictly necessary” cookies used for navigation or to provide a service requested by the user and “functional or functionality” cookies or those that allow optimising the functionality of the site (for example, to remember the choices made by the user). Technical cookies do not require consent;
• analytics cookies: they are used, for example, to evaluate the effectiveness of a service or to help measure the “traffic” of a website (e.g. the number of visitors also possibly divided by geographical area, time slot of the connection or other characteristics). Analytics cookies generally require consent, unless they are used only for the collection of data in an aggregated or anonymised manner. In such cases, as specified by the Supervisory Authority, analytics cookies can be equated with technical cookies and, therefore, it is not necessary to obtain consent for their installation. In this case, SNAITECH uses anonymised third-party cookies (our partner is: Google http://www.google.com/policies/privacy/), in particular the updated version of Google Analytics 4 (so-called GA4), with the default setting that only provides for the collection of granular data on location and device;
• profiling cookies: these cookies store specific information about the user, tracking their online browsing activities. The data thus collected is used to build “profiles” used for commercial purposes, through the sending of personalised advertising messages based on the tastes and preferences expressed on the network by the profiled user. Profiling cookies require consent.

• guarantee and optimise the navigation/ use of the website, also following criteria selected by the user (e.g. language, products, etc.);
• improve the use of the same, through the analysis of data/information in aggregate and anonymous form.

Third Parties act as Data Controllers, therefore: they are required to adopt policies on the protection of personal data, to which reference is made in order to know the information relating to data processing.

9.1. TECHNICAL COOKIES

a) Strictly necessary cookies

b)Anonymised analytics cookies

1. a) the right to access their personal data, obtaining evidence of the purposes, the categories of data involved, the recipients to whom they may be disclosed, the applicable storage period, the existence of automated decision-making processes (art. 15 GDPR 2016/679);
2. b) the right to obtain the rectification of inaccurate personal data or to have incomplete data completed (art. 16 GDPR 2016/679);
3. c) the right to obtain the erasure of data (art. 17 GDPR 2016/679);
4. d) the right to obtain the restriction of processing (art. 18 GDPR 2016/679);
5. e) the right to receive in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, if the conditions required by law are met (art. 20 GDPR 2016/679);
6. f) the right to object to the processing and to withdraw their consent, without affecting the lawfulness of processing based on consent before its withdrawal (art. 21 GDPR 2016/679);
7. g) the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her (art. 22 GDPR 2016/679).

In addition, the Data Subject has the right to lodge a complaint with the Supervisory Authority, pursuant to art. 77 of GDPR 2016/679, following the procedures and instructions published on the official website of the Authority at www.garanteprivacy.it, as well as to appeal to the competent courts, pursuant to articles 78 and 79 of GDPR 2016/679.

Exercising any of these rights is not subject to any formal constraint and is free of charge. If the requests of the Data subject are manifestly unfounded or excessive, in particular because of their repetitive nature, the Controller may:

– charge a reasonable fee taking into account the administrative costs incurred in providing the information or communication or taking the action requested; or

– refuse to act on the request.

In accordance with art. 12, paragraph 3, GDPR 2016/679, the Data Controller will provide feedback to the Data Subject without undue delay and, in any case, at the latest within one month of receipt of the request. This period may be extended by two months, if necessary, taking into account the complexity and number of the requests (in this situation, the Controller will inform the Data Subject of any such extension within one month of receiving the request, together with the reasons for the delay).

Without prejudice to Article 11 of European Regulation 2016/679, if the Data Controller has reasonable doubts about the identity of the natural person making the request referred to in Articles 15 to 22 GDPR 2016/679, it may request additional information necessary to confirm the identity of the Data Subject.

• EU Regulation 2016/679 (GDPR);
• European Directive 2009-136-EC (so-called ePrivacy Directive) and subsequent amendments, as transposed into national law under art. 122 of Italian Legislative Decree 30 June 2003, No. 196 and subsequent amendments (“Privacy Code”);
• contained in the relevant documents issued by Working Group, Article 29 on data protection (“WP29”) and subsequently called the European Data Supervisory Board (“EDPB”), in particular the “Opinion 04/2012 on cookie consent exemption” of 7 June 2012 and the “Guidelines 05/2020 on consent pursuant to Regulation 2016/679” of 4 May 2020;
• contained in Provision No. 229 of 8 May 2014 by the Superisory Authority for the protection of personal data;
• referred to in the “Guidelines on the use of cookies and other tracking tools” of the Supervisory Authority, which entered into force on 10 January 2022;
• the European Commission’s adequacy decision of 10 July 2023 on the “EU-US Data Privacy Framework”.

The Data Controller reserves the right to revise, modify or update this cookie policy at any time, also in the light of changes and/or new national and European legislation on the protection of personal data. Therefore, please consult the dedicated section regularly to check the most recent version of the document, referring to the date of last revision at the bottom of the document.