1. What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

2. What do we use cookies for?

We use cookies to make our website easier to use and to make the content you see more relevant. Cookies allow us to record important information about your visit and this helps us to make the website better for you, and for other visitors.
We also use cookies to create statistics that help us improve the structure and content of our website. We cannot identify you personally from this information.

3. Third party cookies

We use a number of systems that are provided by external suppliers. In some cases they may also set cookies on your device on our behalf when you visit our website.

4. Are the cookie analytics "technical" cookies?

No. The Guarantor (see provision of 8 May 2014) has specified that they can be assimilated to technical cookies only if used for the purposes of site optimization directly by the owner of the site, which can collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, provided for technical cookies.

5. What are "profiling" cookies?

These are the cookies used to track the user's browsing on the web and create profiles on his tastes, habits, choices, etc. With these cookies, advertising messages can be transmitted to the user's terminal in line with the preferences already expressed by the same user in the online navigation.

6. Is the user's consent required for the installation of cookies on his terminal?

It depends on the purposes for which cookies are used and, therefore, if they are "technical" or "profiling" cookies.
For the installation of technical cookies, users' consent is not required, whereas it is necessary to give the information (article 13 of the Privacy Code). Profiling cookies, on the other hand, can only be installed on the user's terminal if they have given their consent after being informed in a simplified manner.

7. How should the site owner provide the simplified information and request consent to the use of profiling cookies?

As established by the Guarantor in the provision indicated in question no. 4, the information must be set on two levels.
When the user accesses a website (on the home page or on any other page), a banner containing a first "short" information must immediately appear. , the request for consent to the use of cookies and a link to access more "extended" information. On this page, the user can find more detailed information on cookies and choose which specific cookies to authorize.

8. How should the banner be created?

The banner must be large enough to partially cover the content of the web page that the user is visiting. It must be able to be eliminated only through an active intervention of the user, that is through the selection of an element contained in the page below.

9. What indications must the banner contain?

The banner must specify that the site uses profiling cookies, possibly also "third parties", which allow you to send advertising messages in line with the user's preferences.
Must contain the link to the extended information and the indication that, through that link, it is possible to refuse consent to the installation of any cookies.
It must clarify that if the user chooses to continue "skipping" the banner, he consents to the use of cookies.

10. How can the acquisition of consent through the use of the banner be documented?

To keep track of the acquired consent, the site owner can make use of a specific technical cookie, a system that is not particularly invasive and that does not require further consent.
In the presence of such "documentation", it is not necessary that the brief information is revived at the second visit of the user on the site, without prejudice to the possibility for the latter to deny consent and / or modify, at any time and easily, their options, for example through access to the extended information , which must therefore be linked to each page of the site.

11. The online consent to the use of cookies can only be requested through the use of the banner?

No. The owners of the sites always have the possibility to resort to different methods from the one identified by the Guarantor in the above-mentioned provision, provided that the chosen methods present all the validity requirements of the consent required by law.

12. The obligation to use the banner also weighs on the owners of sites that use only technical cookies?

No. In this case, the site owner can inform users in the manner he considers most appropriate, for example, also by inserting the relevant information in the privacy policy indicated on the site.

13. What should the "extended" information indicate?

Must contain all the elements required by law, analytically describe the characteristics and purposes of cookies installed by the site and allow the user to select / deselect individual cookies.
Must include the updated link to information and consent forms of the third parties with which the owner has entered into agreements for the installation of cookies through its website.
It must also recall the possibility for the user to express their options on cookies also through the browser settings used.

14. Who is required to provide the information and to request consent for the use of cookies?

The owner of the website that installs profiling cookies.
For third-party cookies installed through the site, the obligations of disclosure and consent weigh on the third parties, but the site owner, as a technical intermediary between these and the users, is required to include in the "extended" information the updated links to the information and consent forms of the third parties themselves.

15. The use of cookies must be notified to the Guarantor?

Profiling cookies, which usually persist over time, are subject to the notification obligation, while cookies that have different purposes and fall within the category of technical cookies, should not be notified to the Guarantor.

16. When do the measures prescribed by the Guarantor come into effect with the provision of 8 May 2014?

The Guarantor has provided for a transitional period of one year starting from the publication of the provision in the Official Gazette to allow interested parties to comply. This period will end on 2 June 2015.