(Updated as of 6 November 2023)
Dear Visitor (hereinafter, "you" or the "User"),
This website (https://www.gruppodigitouch.it/en, hereinafter the "Website") is owned by Digitouch S.p.A., with its registered office at Viale Vittorio Veneto 22, Milan, Italy, VAT No. 05677200965 (hereinafter, the "Company", "we", "us" or "our").
As our Website uses so-called cookies for various purposes, this Cookie Policy explains what cookies are and how they are used on the Website.
Some cookies (so-called first-party cookies) are placed and controlled directly by us. Through these cookies, the Company collects and processes certain personal data relating to you. In this Cookie Policy, pursuant to Article 13 of Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (the "Regulation") and Legislative Decree No. 196/2003 (the "Privacy Code" and, together with the Regulation, the "Applicable Legislation"), we explain how we collect such data, the purposes for which they are processed, and your rights.
Other cookies (so-called third-party cookies) are placed and controlled by third parties, as further explained below. This Cookie Policy contains links to the privacy and cookie policies published by such third parties, which we encourage you to read carefully.
If you are not familiar with cookies, we encourage you to read this Cookie Policy and the Website's general Privacy Notice carefully, so that you can make informed choices.
The Company places the utmost importance on protecting the privacy and personal data of its Users. For any information relating to this Cookie Policy, Users may contact the Company at any time using one of the following methods:
by sending a registered letter with acknowledgement of receipt to the Company's registered office;
by sending an email to privacy@gruppodigitouch.it;
by contacting the Digitouch Group's Data Protection Officer (DPO) at dpo@gruppodigitouch.it.
Cookies are small text files that the websites visited by the User send directly to the User's device (typically to the browser), where they are stored and subsequently transmitted back to the same websites on the User's next visit (so-called first-party cookies). During browsing, the User may also receive cookies on their device from websites or web servers other than the one being visited (so-called third-party cookies). This occurs because the visited website may contain elements such as images, maps, audio files or links to web pages hosted on servers belonging to different domains. In other words, these are cookies set by a website other than the one the User is currently visiting.
Cookies may remain active only for the duration of a single browsing session (so-called session cookies), in which case they are automatically deleted when the User closes the browser. Alternatively, cookies may have a predefined expiration date, in which case they remain stored and active on the User's device until that date, continuing to collect information during subsequent browsing sessions (so-called persistent cookies).
Cookies are used for different purposes. Some are necessary to enable the User to browse the Website and use its features (so-called technical cookies). Others are used to collect statistical information, either in aggregated or non-aggregated form, on the number of Users accessing the Website and on how the Website is used (so-called analytics or monitoring cookies). Finally, other cookies are used to create a profile of the User and display advertising that may be of interest based on the User's preferences and browsing habits (so-called profiling cookies).
To learn more about these different categories of cookies, please continue reading this Cookie Policy. You will find information on how they work, what they are used for, and you may freely choose whether to consent to their use or to refuse them.
Technical cookies are used on the Website solely to enable you to browse the Website and use its features. They are always first-party cookies, as they are placed directly by us through the Website.
Some technical cookies are essential to provide you with an optimal browsing experience or to allow you to authenticate on the Website, for example when making a purchase or accessing your personal area (so-called navigation cookies). Navigation cookies are generally session cookies and are therefore automatically disabled once you close your browser.
Other technical cookies are useful for allowing you to store certain preferences (for example, your language or country) without having to reset them during subsequent visits (so-called functionality cookies). For this reason, functionality cookies are often persistent cookies, as they remain stored on your device even after you close your browser, until their scheduled expiry date or until you decide to delete them.
The Website currently uses the following technical cookies:
Cookie Name | Cookie Category | Description | Expiry
iclcurrent_language | first-party technical cookie | Stores the selected language | 1 day
wordpress_logged_in_* | first-party technical cookie | Keeps the session active for logged-in users | Session
wordpress_sec_* | first-party technical cookie | Keeps the session active for logged-in users | Session
wordpress_test_cookie | first-party technical cookie | Checks whether cookies are enabled in the browser | Session
As provided for by the Applicable Legislation, your prior consent is not required for the installation of the technical cookies referred to in Section B.1 above. Naturally, you are free to block the installation of technical cookies by changing your browser settings (please refer to Section E, point 1 below for instructions on how to do so). Please note, however, that blocking the installation of technical cookies, or subsequently deleting them, may partially or completely prevent you from accessing the Website, using all or part of its features, enabling or disabling certain functions, or receiving certain services.
Conversely, the installation of cookies and/or tracking tools other than technical cookies (such as profiling cookies) requires your prior consent. For this reason, when you access the Website, a dedicated banner (also known as a Consent Management Platform, hereinafter the "CMP") is displayed, informing you that, subject to your consent, non-technical cookies are used on the Website and that, by clicking the relevant button, you may consent to the use of such cookies.
Should you provide your consent to the installation of cookies in this manner, we will keep a record of your consent by means of a specific technical cookie or through other technical methods associated with the use of the CMP, enabling us to maintain an up-to-date record of the User's choices. In the latter case, the Company may process, for this purpose, metadata relating to the User's granular choices, including whether consent has been given, the specific purposes for which consent has been granted, and the User's decision to continue browsing while maintaining the default settings by clicking the relevant button provided in the CMP.
In this way, we will avoid displaying the cookie CMP again during your subsequent visits to the Website and will keep a record of your choices in accordance with the requirements of the Applicable Legislation.
Please note that, where the Company relies on a technical cookie or other technical means to demonstrate that your consent has been obtained and to maintain an up-to-date record of your choices, if you delete such technical cookie or other tool used for this purpose from your browser, in accordance with the procedure described in Section E, point 1 below, the record of your consent may be lost. As a result, the CMP may be displayed again the next time you visit the Website.
Analytics cookies are used on the Website to collect statistical information, either in aggregated or non-aggregated form, on the number of Users accessing the Website and on how they use it.
Cookie Name | Cookie Category | Description | Expiry
_ga | First-party cookie | This cookie name is associated with Google Universal Analytics, which represents a significant update to Google's most widely used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request on a website and is used to calculate visitor, session and campaign data for website analytics reports. | 13 months
_ga-VB61YL89TN | First-party cookie | This cookie is used by Google Analytics to maintain session state. | 13 months
_ga-MN1R7JRZ80 | First-party cookie | This cookie is used by Google Analytics to maintain session state. | 13 months
_ga-C6ZRVQJWL0 | First-party cookie | This cookie is used by Google Analytics to maintain session state. | 13 months
_cs-c | First-party cookie | This is a session cookie. It is a pattern-type cookie in which a randomly generated 13-digit number is added to the cs prefix. | 13 months
_cs-id | First-party cookie | This is a session cookie. It is a pattern-type cookie in which a randomly generated 13-digit number is added to the cs prefix. | 13 months
_cs-s | First-party cookie | This is a session cookie. It is a pattern-type cookie in which a randomly generated 13-digit number is added to the cs prefix. | 30 minutes
_iub-cs-48900714-uspr | First-party cookie | Cookie used by the cookie banner generated by the Iubenda service to store Users' cookie preferences, as required by the ePrivacy Directive, the GDPR, the CCPA and the LGPD. | 12 months
_iub-cs-20800368-uspr | First-party cookie | Cookie used by the cookie banner generated by the Iubenda service to store Users' cookie preferences, as required by the ePrivacy Directive, the GDPR, the CCPA and the LGPD. | 12 months
Naturally, you are free not to consent to the installation of analytics cookies and to object to their use at any time, without this affecting your ability to visit the Website or use its content in any way. To find out how to do so, please read the third-party cookie policies by following the links provided in the table above.
There are several options available to manage, disable and delete cookies.
1. Change your browser settings
Follow the instructions provided by your browser's manufacturer to learn how to manage, disable or delete cookies:
Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
Safari: https://support.apple.com/it-it/guide/safari/manage-cookies-and-website-data-sfri11471/
Opera: https://help.opera.com/en/latest/web-preferences/
Please make your choices carefully. By indiscriminately blocking all cookies, including technical cookies, without creating a specific exception for the Website, you may no longer be able to browse the Website or use some or all of its features. Furthermore, by deleting all cookies from your browser, technical cookies may also be removed, causing the preferences you have set while using the Website to be lost.
2. Use the interactive tools provided by third parties
To disable first-party profiling cookies, namely those installed directly by us, you may simply use the interactive button(s) available in Section D of this Cookie Policy. Your decision to object to the use of these cookies will not affect your ability to browse the Website or use its features and may be withdrawn at any time by using the same interactive button.
To disable third-party cookies, please refer to the information pages provided by the third parties that install analytics cookies (see Section C above) or profiling cookies (see Section D above) in order to learn about the tools available to manage, disable and delete cookies and, more generally, to object to their use. Please note that, by disabling third-party cookies: (i) you object to their use not only on this Website but on all websites where such cookies are used; and (ii) your ability to browse the Website and use its features will not be affected in any way.
3. Use the website www.youronlinechoices.eu/it/
Your Online Choices is a website managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA). The Italian version is available at www.youronlinechoices.eu/it/ and provides information about behavioural advertising based on profiling cookies (http://www.youronlinechoices.com/it/a-proposito). It also allows internet users to easily opt out of the installation of the main profiling cookies used by advertising operators on websites (http://www.youronlinechoices.com/it/le-tue-scelte). Before using this tool, we recommend that you carefully read the Your Online Choices Terms and Conditions (http://www.youronlinechoices.com/it/condizioni-generali-di-servizio), Frequently Asked Questions (FAQ) (http://www.youronlinechoices.com/it/faqs) and User Guide (http://www.youronlinechoices.com/it/help).
Please use Your Online Choices with due care. Although Your Online Choices includes many of the major companies operating in the online advertising sector, some third parties that install cookies through the Website may not participate in the initiative. Therefore, using Your Online Choices does not guarantee that you will no longer receive third-party cookies while browsing the Website. Please also remember that, if you delete all cookies from your browser, the technical cookies set by Your Online Choices to remember your preferences may also be deleted, causing third-party cookies to become active again.
4. Use the CMP
With regard to the processing of personal data that third-party companies may carry out through cookies on the basis of the User's consent, the User may also use the Consent Management Platform (CMP) implemented on the Website to give or withdraw consent by following the relevant instructions.
As highlighted in the introduction to this notice, the Company may collect and process certain personal data through cookies it places directly on the Website, as well as cookies placed by third parties acting on behalf of the Company on the basis of a specific appointment as data processor pursuant to Article 28 of the Regulation (first-party cookies). The Company acts as data controller for this data, in accordance with the provisions of applicable law.
We will process your data exclusively by electronic means, in a fully automated way and without human intervention. Therefore, our staff will never access the content of your personal data obtained through cookies, meaning they will never be able to access and/or handle PII (Personally Identifiable Information), i.e. information that could directly identify you.
Some of our employees and/or collaborators, appointed by us as data processors pursuant to Article 29 of the Regulation, may carry out maintenance activities on the IT systems hosting your data, without ever being able to access its actual content.
Personal data may be stored on servers managed by third-party providers (e.g. IT system providers) or may be processed by entities specialized in online advertising, acting as data processors pursuant to Article 28 of the Regulation, based on a specific written appointment by the Company.
Your personal data will not be disclosed to third-party data controllers nor disseminated.
Personal data collected by the Company through the technical cookies referred to in section B above will be retained for the time strictly necessary to fulfil the primary purposes described in this notice, or otherwise as required to protect the rights and interests of both users and the Company.
Regarding the duration of cookies themselves, including third-party cookies, and the retention periods of data collected by third parties, please refer to the tables included in this notice.
We inform you that, in compliance with the conditions and safeguards established by the Regulation, your personal data may be transferred to countries outside the European Economic Area (EEA). These countries may not provide a level of privacy and personal data protection comparable to that guaranteed by applicable law. Where the Company acts as data controller, we place the utmost importance on data security and therefore manage such transfers with appropriate safeguards in accordance with applicable law, in particular Articles 45 (Transfers on the basis of an adequacy decision) and 46 (Transfers subject to appropriate safeguards) of the Regulation.
Specifically, for the provision of the Google Analytics service (as referred to in section C above), the Company’s provider, Google Ireland Limited, may transfer users’ pseudonymised personal data outside the EEA on the basis of the so-called Standard Contractual Clauses, in particular to the United States, implementing additional measures to ensure that the transfer complies with the Regulation.
Further information on the additional security measures applied by Google Ireland Limited for the transfer of personal data outside the European Union is available in the following resources provided by the supplier: “Regarding international data transfers in Google Analytics” (available at https://support.google.com/analytics/answer/11609059) and “Safeguards for international data transfers with Google’s advertising and analytics products” (available at https://services.google.com/fh/files/misc/safeguards_for_international_data_transfers.pdf). In view of the scope of processing, the nature of the data processed and the risks associated with the processing carried out by the provider, the Company considers the additional security measures adopted by the provider to be adequate to protect the personal data processed on its behalf.
Please note that some of the third parties listed in the tables of this notice and/or in the CMP may—acting as independent data controllers of data collected via third-party cookies—process personal data collected through cookies installed on this Website from locations outside the European territory. We therefore recommend that you carefully review their respective privacy notices for further details.
To exercise your rights, or to obtain any further information or clarification regarding this cookie policy, please contact the Company using the following methods:
- By sending a registered letter with return receipt to the Company’s registered office;
- By sending an email to: privacy@gruppodigitouch.it;
- By contacting the Data Protection Officer (DPO) of Gruppo Digitouch at the following email address: dpo@gruppodigitouch.it.
In accordance with applicable law, Users have:
1. The right to withdraw consent at any time, where processing is based on consent;
2. The right of access to personal data;
3. (Where applicable) the right to data portability (i.e. the right to receive all personal data concerning them in a structured, commonly used and machine-readable format), the right to restriction of processing, the right to rectification, and the right to erasure (“right to be forgotten”);
4. The right to object:
5. in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if relevant to the purpose of collection;
6. in whole or in part, to the processing of personal data concerning them for the purposes of sending advertising material, direct sales, market research, or commercial communications;
7. where they consider that the processing of their data violates the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State of their habitual residence, place of work, or place of the alleged infringement). The Italian supervisory authority is the Italian Data Protection Authority (Garante per la protezione dei dati personali), located at Piazza Venezia 11, 00186 Rome, Italy (https://www.garanteprivacy.it/web/garante-privacy-en/home_en).
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The Company is not responsible for keeping all links contained in this cookie policy up to date; therefore, whenever a link is not working and/or is outdated, Users acknowledge and agree that they should always refer to the document and/or section of the websites referenced by such link.