- Data Controller: TEA S.p.A., with registered office in Via Ponchielli, n. 7 – 20129 Milan | Tax Code, VAT and registration number in the Register of Companies of Milan 03844300966, Italy, Data Controller, hereinafter “Data Controller”, who can be contacted at DPO@centroilcentro.it, informs you that information is collected relative to the use of the site through cookies. When a user visits the site, we send cookies to their device which are stored uniquely by your browser. With the new Regulation (EU) 2016/679 (“GDPR”) on the protection of personal data, we are required to inform you on how your data collected through cookies will be used.
What are cookies, what are they used for and who installs them? Cookies are small strings of text that the Internet sites you visit send to your device (e.g. PC, tablet, smartphone…) where they are stored and/or read by the browser and which allow the browser to send information to the person who installed the cookies in order to offer you optimal browsing, produce statistics on the visits, offer you customised content and targeted advertising. The cookies are held in various elements hosted on the site’s page (for example advertising banners, images, videos. etc.).
When browsing on this site, you may receive the following cookies on your device:
– first party cookies: these are cookies sent by the Data Controller’s site, that you are visiting,
– third party cookies: these are cookies sent by a different site than the one you are visiting, which installs its own cookies through the Data Controller’s site.
The Data Controller is responsible for the management and responsibility of the first party cookies, while for the third party cookies the Data Controller does not have any control either on the activity of the third party, or on the possibility that it may change them over time. As regards the third party cookies, the Data Controller acts as intermediary and, in that capacity, refers to the statements of the third party, which can be reached through a specific link located next to each of the cookies indicated in the special area which can be reached from the banner or is located at the end.
Other tracking tools. Like the cookies, other tracking tools are being developed that make it possible to pursue the same goals. These tracking tools can be catalogued according to a series of different criteria; however, the principal grouping criterion remains that of the purpose for which they are used: technical or commercial. Among these tools there are for example the pixels, the fingerprinting tools, etc.
a) What is the purpose of this Cookie Information Note?
In compliance with the provisions of the current legislation regarding the protection of personal data (in particular the Regulation (EU) 2016/679 on the protection of personal data “GDPR” and the European and Italian legislation on cookies) we would like to inform you regarding the processing of your personal data collected through the cookies (and possibly other tracking tools similar to them) also of third parties.
The processing will be based on the principles of correctness, lawfulness and transparency, as well as the protection of your confidentiality and the protection of your rights.
b) Who is the Data Controller? How to contact him?
The Data Controller of your personal data is the company TEA S.p.A., with registered office in Via Ponchielli, n. 7 – 20129 Milan | Tax Code, VAT and registration number in the Register of Companies of Milan 03844300966, Italy, (hereinafter the Data Controller). The Data Controller can be contacted at the address indicated above or at the following email address: firstname.lastname@example.org.
c) Which cookies use this site? For what purpose, on what legal basis? Is it mandatory to provide the data? What happens if I don’t provide them?
The cookies used by this site can be classified into the following categories: 1) Technical cookies, which are used to make the site function, and the 2) Profiling cookies, which are used to track the behaviour of the user to analyse it in order to offer them services based on their preferences. Following are the relative details:
1. 1. Technical Cookies, which do not require your consent
The cookies listed below fall into this category and have the purposes respectively indicated:
– Browsing or session cookies, which are used to guarantee the normal browsing and use of the website (allowing, for example, to complete a purchase or perform authentication to access reserved areas);
– Anonymised analytics cookies, they are cookies used to gather information, in aggregate form and therefore not referable to the individual, relative to the number of users on the pages most visited, the locations from which we connect, etc. to process statistics on the service and on the use of the site. These cookies may also be third party. In this case, however, the Data Controller must have made them anonymous (e.g. through anonymising their IP or masking part of it) and must not allow the third party to cross-reference the information collected through the site with others already in their possession.
– Functionality cookies, which allow the user to browse depending on a series of criteria selected (for example, the language, the products selected for purchase) in order to improve the service provided to them.
Legal Basis. For technical cookies the legal basis resides in the execution of a contract or pre-contractual measures (art. 6.b of the GDPR) since they are necessary to make the site and the service usable by the users. The use of these cookies does not require your consent.
Need for the conferment of the data and consequences. The conferment of the data collected through the cookies described above is not mandatory; however, it is necessary in order to connect to the site and the supply of the service. With partial or total absence of that conferment, the site cannot be used or there might be problems using it. The list of the Technical Cookies used by this site with the relative characteristics (e.g. characteristics, storage time of the data etc.) is available in the special area which can be reached from the banner or is located at the end.
2. Profiling Cookies and other tracking tools which require your consent
The Profiling Cookies and the other tracking tools can be:
– First party: installed directly by the Data Controller on his site.
– Third party: installed on the Data Controller’s site by a third party subject. On the third party cookies, and the other third party tracking tools (e.g. Facebook pixel, social plug-in. fingerprinting tools, Google tag, etc.) the Data Controller does not have any control either on the activity of the third party, or on the possibility that it may change them over time. In that sense, the Data Controller acts as intermediary. In that capacity, he refers to the statement of the third party, which can be reached through a specific link located next to each of the cookies indicated in the special area which can be reached from the banner or is located at the end.
The Profiling Cookies and the other tracking tools make it possible to follow and track, through automated tools, the behaviour of the user while he is browsing on the Internet. Their purpose is to lead back to certain subjects, identified or identifiable, specific actions or behavioural patterns recurring in the use of the functionalities offered (pattern) for the grouping of the various profiles within homogeneous clusters of various scale, in order to make it possible for the Data Controller or the third parties, among other things, also to make the supply of the service increasingly customised beyond what is strictly necessary for the provision of the service, as well as to send targeted advertising messages, namely in line with the preferences expressed by the user during the online browsing.
The non-anonymised analytics cookies are also profiling cookies used by the third party, when the Data Controller has not made them anonymous (e.g. did not make the IP anonymous) and/or when he allows the third party to cross-reference the information gathered with other information that they already have.
Legal Basis. The use of Profiling cookies (including the non-anonymised analytics) and other tracking tools may only occur with your consent, which forms the legal basis of the processing of the data collected through those cookies, in conformity with the provisions of art. 6.a of the GDPR. You can give or revoke your consent at any time by operating directly in the special area which can be reached from the banner or is present in the footer of the page.
Need for the conferment of the data and consequences. Failure to confer data as a result of your failure to provide your consent to those cookies and other tracking tools does not have any consequence for you in terms of browsing on the site and its use but entails the impossibility of sending you advertising messages on services and goods in line with your preferences and your real interests expressed during your browsing online.
d) How to manage the consent of the cookies?
You can manage your consent relative to the individual categories of cookies by operating directly in the special area which can be reached from the banner or is present in the footer of the site.
e) Are the personal data transferred outside the European Union (EU)?
Your data collected through cookies will not be transferred by the Data Controller outside the EU. As regards the third parties who collect data through this site with their cookies or tracking tools, you must check those transfers on their information sheets.
f) How long are the data stored?
The storage period of the data collected through the use of the cookies is indicated in the list of cookies used by this site available in the special area which can be reached from the banner or is located at the end.
g) Who can learn your data? To whom do we communicate them?
The data collected through the cookies:
- can be used by the partners authorised by the Data Controller, such as for example the individuals assigned to the maintenance and management of the site, to marketing and to the administration.
- They can also be used by possible third parties (services, infrastructures, IT suppliers involved in the management and supervision of the site etc.) who operate on behalf of the Data Controller and have been duly appointed processing managers as provided by art. 28 of the GDPR.
- In addition, the data can be transferred to third parties authorised by law to access your data such as, for example, law enforcement and public administration.
- Lastly, with your consent they can also be used by the third parties who install their cookies through the Data Controller’s site.
h) What are your rights as interested party?
The GDPR grants the following rights relative to your personal data which you can exercise within the limits and in conformity with the provisions of the legislation:
- Right of access to your personal data (art. 15);
- Right of correction (art. 16);
- Right of cancellation (right to be forgotten) (art. 17);
- Right of limitation of processing (art. 18);
- Right to the portability of the data (art. 20);
- Right of objection (art. 21): the interested party has the right to object at any time, for reasons connected to his particular situation, to the processing of the personal data that concern him based on legitimate interest, including profiling based on it. The Data Controller refrains from the processing unless he can demonstrate the existence of legitimate mandatory reasons for proceeding with the processing which prevail over the interests, the rights and the freedom of the interested party or to verify, exercise or defend a right in court;
- Right to object to a decision based solely on automated processing (art. 22);
- Right to revoke, at any time, the consent given, without prejudicing the lawfulness of the processing based on the consent given before the revocation.
You can obtain this by sending a written request addressed to the Data Controller at the postal address or through email, as indicated previously. In addition, you have the right to file a complaint with the Personal Data Protection Authority (www.garanteprivacy.it), if you believe that the processing of your data is contrary to the legislation in force (art. 77) or to file a case in court (art. 79).
i) Data Protection Officer (DPO)
The Data Controller has designated a Data Protection Officer (DPO) who you can contact for all questions relative to the processing of your personal data and to exercise the rights attributed to you by the GDPR (art. 38.4). The contact details of the DPO are as follows: email@example.com.
j) How are the personal data protected?
The personal data will be processed both with electronic instruments and without the use of electronic instruments, using technical and organisational security measure adequate for the nature of the data to ensure their integrity and confidentiality and to protect them against the risks of unlawful intrusion, loss, alteration, or disclosure to third parties not authorised to process them.
k) Social plug in
We wish to inform you that on the pages of our site that you are visiting there may be plug-ins installed provided by third parties (e.g. like buttons, comments, share and other functions typical of social networks and platforms such as for example: Facebook, Instagram, Youtube, Linkedin, Twitter, Snapchat, etc.).
These plug-ins will allow your browser to recall contents of the supplier of the plug-in and to transfer the personal data that concern you to him (including for example the pages visited, purchases made, time spent, identifiers of the device and the browsing, likes, comments, shares, etc.). This processing activity involves collection and communication through transmission of your personal data and requires your consent.
Data and Source of the data
You may have reached this website / app by clicking on links or advertising contents of the Data Controller present on the websites of third parties or social networks. In that case, that third party website will send us certain personal data (IP address and other identification, origin, advertising campaign, statistics relative to the campaign, etc.) relative to the fact that you have shown interest in our advertising.
This information, if you gave us prior valid consent, can be used by us to send you our advertising or promotional communications.
Co-ownership of the campaign
If the re-marketing advertising campaign on which you clicked was carried out on the Facebook platforms (Facebook, Instagram and apps belonging to the Audience Network of Facebook) or through its tools (Facebook stories, Instagram stories, Messenger stories, news feed, news, feed, marketplace, video. etc.), the processing relative to the selection of the target and the selections of the methods for sending contents of the advertising campaign was (and will be) carried out under co-ownership with Facebook Ireland Limited (in this document “Facebook”), based in 4 Grand Canal Square, Grand Canal Harbour, Dublin 2.
Elements of the agreement
Facebook: Every detail relative to the co-ownership agreement and the respective responsibilities is available at the following link: https://www.facebook.com/legal/controller_addendum. Below is the Facebook privacy information link https://www.facebook.com/about/privacy. Facebook will be responsible for managing the operating requests of the rights of the interested parties pursuant to articles 15-20 of the GDPR relative to the personal data stored by Facebook after the joint Processing.
The activities of sending promotional contents to sites, apps or platforms of the third party co-owners or their partners will be performed by them only if your have provided the due consent. Not knowing the recipients of this advertising which will be sent by third parties, the information for which we are responsible is provided to you in this document when you connect to our website / app.
The Data Controller reserves the right to modify and update at any time this information document. The changes will apply starting from their publication.
Here below you will find the links to the websites, policies and forms to deny your consent to third parties cookies with whom we conclude agreements and which send cookies through our website:
|THIRD PARTY KEEPING USER’S INFORMATION||LINK TO THE THIRD PARTY POLICY||LINK TO THE CONSENT FORM OF THE THIRD PARTY|
|Link||Log into your account. Privacy section.|