The rules on the use of cookies and other similar tools (web beacon/web bug, clear GIF, etc.) in terminals (personal computers, notebook, tablet pc, smartphoneetc.) used by users, has recently been amended following the implementation of the directive 2009/136 which amended the e-Privacy Directive (2002/58/CE) and the provision "Identification of simplified procedures for the information and acquisition of consent for the use of cookies - 8 May 2014?

Cookies are small text files that are sent to your terminal (usually your browser), where they are stored and then retransmitted to the same sites the next time the same user visits. Cookies are used to perform computer authentication, session tracking and store specific information about users accessing the server and are usually present in the browser of each user in very large numbers.

Cookies on the domain

  • They allow you to navigate efficiently from one page to another on the website.
  • They store the user name and preferences entered.
  • They allow you to avoid entering the same information (such as username and password) several times during and visit.
  • They measure Users' use of services in order to optimise the browsing experience and the services themselves.
  • They present targeted advertising information according to the interests and behaviour expressed by the User while browsing.

These functionalities are divided into several categories:

  1. Technical cookies
  2. Analytical cookies

Below are the types of cookies used on the website.

  • Technical cookies

They are necessary for certain areas of the site to function properly and include persistent cookies and session cookies. Without these cookies, the site or portions of the site may not function properly. Therefore, they are always used, regardless of user preference.

  • Analytical cookies

They are used to collect information about the use of the site.

The Data Controller uses this information for statistical analysis, to improve the site and simplify its use, as well as to monitor its correct operation.

This type of cookies collect information in a way aggregated and anonymous on the activity of users browsing the domain

These cookies are installed directly by the owner and, since they are used for functional and analytical purposes ("analytics cookies"), their installation does not require express consent but only notification of the existence of such tools.

List of systems used:

  • Google Analytics: for more information please refer to the privacy policy of the instrument.
  • HotJar: For more information, please refer to the privacy policy of the instrument.

Rights of the data subject

How to disable technical and analytical cookies?

We would like to reiterate that consent does not have to be explicit for this type of cookie. They can be blocked as indicated in the following paragraphs but this may prevent you from using certain parts of the site.

In accordance with Article 12 et seq. of the G.D.P.R., you can object to the saving of this type of cookie in the following ways.

The way it works, as well as the options for restricting or blocking cookies, can be adjusted by changing the settings on your internet browser.

Most Internet browsers are initially set to accept cookies automatically, but you can change these settings to block cookies or to be notified whenever cookies are sent to your device.

There are several ways to manage cookies, so please refer to your browser's instruction manual or help screen to see how to adjust or change your browser settings.

You can change the default configuration and disable cookies (i.e. block them permanently) by setting the highest level of protection. Below is the path to follow to manage cookies from the following browsers:

If you use different devices to view and access the Sites (e.g., computer, smartphone, tablet, etc.), you should ensure that each browser on each device is adjusted to reflect your cookie preferences. To delete cookies from your smartphone/tablet's Internet browser, you should refer to the user manual for your device.

Cookie policy and consentFrequently asked questions

1. What are cookies?

Cookies are small text files that sites visited by users send to their terminals, where they are stored and then transmitted to the same sites the next time they visit. Third-party cookies, on the other hand, are set by a website other than the one the user is visiting. This is because on each site there may be elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the site visited.

2. What are cookies used for?

Cookies are used for different purposes: performing computer authentication, monitoring sessions, storing information about specific configurations of users accessing the server, storing preferences, etc.

3. What are 'technical' cookies?

These are cookies that serve to carry out navigation or to provide a service requested by the user. They are not used for any other purpose and are normally installed directly by the website owner.

Without the use of such cookies, certain operations could not be carried out or would be more complex and/or less secure, such as home banking activities (viewing account statements, bank transfers, paying bills, etc.), for which cookies, which allow the user to be identified and maintained during the session, are indispensable.

4. Are analytics cookies 'technical' cookies?

No. The Guarantor (cf. measure of 8 May 2014) specified that they can be assimilated to technical cookies only if they are used for site optimisation purposes directly by the owner of the site itself, who may collect information in aggregate form on the number of users and how they visit the site. Under these conditions, analytics cookies are subject to the same rules on information and consent as technical cookies.

5. What are 'profiling' cookies?

These are cookies used to track the user's navigation on the Internet and create profiles on their tastes, habits, choices, etc. These cookies can be used to transmit advertising messages to the user's terminal equipment in line with the preferences already expressed by the user when surfing online.

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

It depends on the purposes for which the cookies are used and, therefore, whether they are 'technical' or 'profiling' cookies.

The installation of technical cookies does not require the user's consent, while it is necessary to provide information (art. 13 of the Privacy Code). Profiling cookies, on the other hand, can only be installed on the user's terminal if the user has given his consent after being informed in a simplified manner.

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

As established by the Garante in the provision indicated in question 4, the information is to be provided on two levels.

The moment a user accesses a website (on the home page or any other page), a banner should immediately appear containing a first 'short' notice, a request for consent to the use of cookies and a link to more 'extensive' information. On this page, the user can find more detailed information on cookies and choose which specific cookies to authorise.

8. How should the banner be designed?

The banner must be large enough to partially cover the content of the web page the user is visiting. It must only be possible to remove it by active user intervention, i.e. by selecting an element from the page below.

9. What information must the banner contain?

The banner must specify that the site uses profiling cookies, possibly including 'third-party' cookies, which allow advertising messages to be sent in line with the user's preferences.

It must contain a link to the extended information notice and an indication that, via that link, it is possible to refuse consent to the installation of any cookies.

Please note that if you choose to continue by "skipping" the banner, you consent to the use of cookies.

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

In order to keep track of the consent acquired, the owner of the site can make use of a special technical cookie, which is not particularly invasive and does not in turn require further consent.

In the presence of such 'documentation', it is not necessary for the short information notice to be re-proposed at the user's second visit to the site, without prejudice to the possibility for the latter to deny consent and/or modify, at any time and in an easy manner, his/her options, for example by accessing the extended information notice, which must therefore be linkable from every page of the site.

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

No. Site owners always have the option of using methods other than the one identified by the Guarantor in the measure mentioned above, provided that the chosen methods meet all the requirements of validity of consent required by law.

12. Does the obligation to use the banner also apply to owners of sites that use only technical cookies?

No. In this case, the owner of the site may provide the information to users in the manner it deems most appropriate, for example, by including the relevant information in the privacy policy indicated on the site.

13. What should the 'extended' information notice contain?

It must contain all the elements required by law, describe analytically the characteristics and purposes of the cookies installed by the site and allow the user to select/deselect individual cookies.

It must include an up-to-date link to the notices and consent forms of third parties with whom the controller has entered into agreements for the installation of cookies through its site.

Finally, it should recall the possibility for the user to express his or her options on cookies also through the settings of the browser used.

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

The owner of the website installing profiling cookies.

For third-party cookies installed through the site, the information and consent obligations are incumbent on the third parties, but the owner of the site, as technical intermediary between them and users, is required to include in the "extended" information notice the updated links to the third parties' information and consent forms.

15. Should the Garante be notified of the use of cookies?

Profiling cookies, which usually persist over time, are subject to mandatory notification, whereas cookies that serve different purposes and fall under the category of technical cookies do not have to be notified to the Garante.

16. When do the measures prescribed by the Garante in its order of 8 May 2014 come into force?

The Garante has provided for a transitional period of one year from the publication of the measure in the Official Gazette to allow those concerned to bring themselves into line. This period will end on 2 June 2015.