Cookie Policy
Dear Visitor (hereinafter referred to as “You” or the “User”),
The present document contains information on technologies through which www.fondazioneinvernizzi.it (hereinafter referred to as the “Site”) can achieve the purposes described below. Through said technologies Fondazione Romeo ed Enrica Invernizzi (hereinafter referred to as the “Data Controller” or the “Foundation”) can collect and save information (e.g. through the use of cookies) or use resources (e.g. by executing a script) on the User’s device when the User interacts with the Site.
As so-called cookies are used on our Site for different purposes, the Controller collects and processes certain personal data about the User. Pursuant to Article 13 of EU Regulation 2016/679 of 27th April 2016 on the protection of individuals with regard to the processing of personal data (hereinafter referred to as the “Regulation”), the present policy explains how we collect such data, for what purposes and what your rights are.
Some cookies (so-called own or first-party cookies) are conveyed and controlled directly by the Controller, while other cookies (so-called third-party cookies) are conveyed and controlled by third parties. In the present policy You will find links to the policies published by said third parties, which we ask You to read carefully.
If You are not familiar with cookies, please read the present policy and the Site general privacy policy carefully so that You can be aware of your choices.
The Foundation takes into the utmost consideration the right to privacy and protection of personal data of its Users. For any information on the present cookie policy, Users may contact the Foundation at any time, as follows:
– By sending a registered letter with return receipt to the Controller’s registered office in Corso Venezia, 32 – Postal code 20121 Milan, Italy;
– By sending an e-mail to: info@fondazioneinvernizzi.it
The Data Controller has not identified a Data Protection Officer (DPO), in that it is not subject to the designation obligation provided for in Article 37 of the Regulation.
A. WHAT COOKIES ARE AND WHAT THEY ARE USED FOR
Cookies are small text files that sites visited by a User send directly to his/her terminal (usually to the browser), where they are stored and then transmitted to the same sites when the same user visits them again (so-called first-party cookies). While browsing a site, a user may also receive cookies from different sites or web servers on his/her terminal (so-called third-party cookies); this happens because the website the user visits may include elements such as, for example, images, maps, sounds, specific links to web pages of other domains residing on servers other than the one on which the requested page is located. In other terms, they are cookies set by a website other than the one that the user is currently visiting.
Cookies may have a lifetime limited to one single browsing session (so-called session cookies), in which case they are automatically deactivated when the user closes his/her browser; or they may have a pre-established expiry date, in which case they will remain stored and active on the user’s hard disk until said expiry date, continuing to collect information over the course of several browsing sessions (so-called permanent cookies).
Cookies are used for different features. Some are necessary to enable the User to browse the Site and take advantage of its features (so-called technical cookies). Others are used to obtain statistical information, whether aggregated or not, about the number of users accessing a site and how the site is used (so-called tracking or analytics cookies). Finally, others are used to trace your consumer profile and display advertisements on the site that may be of interest to You, as they are consistent with your preferences and consumption habits (so-called profiling cookies).
To learn about the different categories of cookies in more detail, continue reading the present policy. Find out how they work and what they are used for, and freely choose whether to consent to their use or prevent it.
B. TECHNICAL COOKIES
Technical cookies are used on the Site for the sole purpose of making it possible for You to browse the Site and to use its features. They are always first-party cookies, as they are directly conveyed by us on the Site.
Certain technical cookies are essential to provide You with an optimal browsing experience or to allow You to authenticate yourself on the site (so-called browsing cookies). Browsing cookies are generally session cookies and are therefore automatically disabled once You close your browser.
Certain technical cookies are essential to provide You with an optimal browsing experience or to allow You to authenticate yourself on the site (so-called browsing cookies). Browsing cookies are generally session cookies and are therefore automatically disabled once You close your browser. Other technical cookies are useful for You to store certain preferences (e.g. language or country of origin) so that You do not have to reset them on your subsequent visits (so-called functionality cookies). This is why functionality cookies are often persistent cookies, as they remain stored on your computer even after You close your browser, until their expiry date or until You decide to delete them.
The following technical cookies are currently used on the Site:
Cookie Name | Cookie category | Cookie function | Storage time |
cookie_consent_status | first-party technical cookie | It stores user preferences regarding cookie consent. | 12 months |
In accordance with the current privacy legislation, your prior consent is not required for the installation of such cookies. You are of course free to block the installation of technical cookies by changing the settings of your browser (read paragraph E, no. 1 to find out how to do this). Please note, however, that by blocking the installation of technical cookies, or by subsequently deleting them, your ability to access the Site, to use all or part of it, to enable or disable certain features or to receive certain services may be wholly or partly impaired.
C. TRACKING OR "ANALYTICS" COOKIES
Analytics cookies are used on the Site to collect statistical information, in aggregate form or otherwise, on the number of users accessing the Site and how they visit the Site.
Analytics cookies on this Site are third-party cookies, as they are not directly conveyed by us, they are by third parties. They are therefore not installed directly by the Foundation, they are by third parties.
The following third-party analytics cookies are installed on the Site without your prior consent, because they are less invasive as they are anonymised, as third parties cannot access disaggregated analytics data at IP address level (in other words, by using these cookies, third parties cannot trace your identity).
Other third-party analytics cookies are, on the other hand, installed on the Site only with your prior consent, because they are not anonymised, as third parties can access disaggregated analytics data at IP address level (in other words, by using these cookies, third parties could theoretically trace your identity through your IP address):
Cookie Name | Cookie category | Link to policy / instructions on opt-out | Storage time |
_GA | third-party analytics cookie – permanent | It registers a unique ID that is used to generate statistical data on the use of the site by the user. | 2 years |
_GA_# | third-party analytics cookie – permanent | It is used by Google Analytics to collect data on the number of times the user visits the site, on his/her first visit and on his/her most recent visit. | 2 years |
For this reason, when You access the Site, a special banner is displayed prominently that informs You that third-party analytics cookies are used on the Site and that You may consent to the use of cookies by clicking on the relevant button. If You consent to the installation of cookies in this way, we will keep track of your consent by means of a technical cookie. In this way, we will not show You the cookie banner on your subsequent visits to the Site. Please note that if You delete this technical cookie from your browser in the manner set out in paragraph E, no. 1) below, the record of your consent will be lost and the cookie banner will be displayed again on your next visit to the Site.
You are of course free to block the installation of analytics cookies at any time, without compromising in any way your ability to visit the Site and enjoy its content.
Please read the third-party cookie policies carefully by following the links in the table above to learn how to do it.
D. HOW TO MANAGE AND BLOCK COOKIES
Several options exist to manage, disable and delete cookies.
(1) Change your browser settings
Follow the instructions provided by the manufacturer of the browser You use to find out how to manage, disable or delete all (technical and analytics) cookies:
• Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
• Chrome: https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies
• 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/
Make your choices carefully. If You indiscriminately block all cookies, including technical cookies, without providing a specific exception for the Site, You may no longer be able to browse the Site or use some or all of its features. In addition, if You delete all cookies from your browser, technical cookies may also be removed and, therefore, You may remove the preferences that You have set when using the Site or You may no longer be able to find the products or services in your shopping cart.
(2) Use interactive tools provided by third parties
To disable third-party cookies, please consult the privacy policies of third parties that install analytics cookies (see paragraph C above) or profiling cookies (see paragraph D above) to learn about the other tools available to You to manage, disable and delete cookies, and more generally to object to their use. Remember that if You disable third-party cookies, (i) You will object to their use not only on the Site but also on all Internet sites on which they are used and (ii) your ability to browse the Site and use its features will not be affected in any way.
E. PROCESSING METHODS
As outlined in the introduction to the present policy, the Foundation may collect and process some of your personal data through cookies that it places directly on the Site (first-party cookies). We will process your data only by electronic means, in a fully automated manner and without human intermediation. Therefore, our employees and collaborators will never have access to the content of your personal data obtained through cookies, which means that they will never be able to access and/or have PII (Personally Identifiable Information), i.e. information from which You can be directly identified.
Some of our employees and collaborators, appointed by us as data processors, may carry out maintenance work on the computer systems that host your data, but they will never be able to access their actual content. Your personal data may be stored on servers managed by third parties (e.g. suppliers of IT systems) or may be managed by parties specialising in online advertising, which act as data processors based on a specific appointment in writing given by the Foundation. We inform You that, in compliance with conditions and guarantees provided for by the Regulation, your data may be transferred to countries outside the European Economic Area, which may not offer a degree of privacy and personal data protection that compares to that guaranteed by Italian and European privacy laws, but in cases where the Foundation act as Data Controller, it will take the utmost consideration of data security, therefore it will manage such transfers with all due care and guarantees. Your personal data will not be disclosed to third-party data controllers and will not be disseminated.
Specifically, for the provision of Google Analytics service, the Foundation’s provider, Google Ireland Limited, may transfer pseudonymous personal data of the Site Users outside the EEA, based on the so-called Standard Contractual Clauses and, in particular, to the United States, taking additional measures to ensure that this is done in accordance with the Regulation itself. Further information on additional security measures applied by Google Ireland Limited for transfers of personal data outside the European Union can be found in the following resources made available by the provider: ‘Regarding international data transfers in Google Analytics’ (see link: https://support.google.com/analytics/answer/11609059) and ‘Safeguards for international data transfers with Google’s advertising and analytics products’ (see link: https://services.google.com/fh/files/misc/safeguards_for_international_data_transfers.pdf). In view of the scope of the processing, the type of data processed and the risks of the processing carried out by the provider, the Foundation has deemed additional security measures as appropriate that the provider guarantees to take to protect personal data processed on behalf of the Foundation.
F. YOUR RIGHTS
To exercise your rights, or to obtain additional information or clarification in relation to the present cookie policy, please contact the Foundation as follows:
– By sending a registered letter with return receipt to the Controller’s registered office in Corso Venezia, 32 – Postal code 20121 Milan, Italy;
– By sending an e-mail to: info@fondazioneinvernizzi.it
The Data Controller has not identified a Data Protection Officer (DPO), in that it is not subject to the designation obligation provided for in Article 37 of the Regulation.
Pursuant to the Regulation, the Foundation informs You that Users have the right to obtain information on (i) the origin of personal data; (ii) the purposes and processing methods; (iii) the logic applied if processing is carried out with the aid of electronic instruments; (iv) identification details of the data controller and data processors; (v) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of such data in their capacity as data processors or subjects in charge of processing.
Furthermore, Users have the right to obtain:
a) access, update, rectification or, when they are interested, integration of the data;
b) cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data for which storage is not necessary in relation to the purposes for which the data were collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their content, to the entities to whom or which the data were communicated or disseminated, unless such requirement proves to be impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
Furthermore, Users have:
a) the right to withdraw their consent at any time, if processing is based on their consent;
b) (where applicable) the right to data portability (the right to receive all personal data relating to them in a structured, commonly-used and machine-readable format), the right to restriction of the processing of personal data and the right to cancellation (“right to be forgotten”);
c) the right to object:
I. in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of collection;
II. in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communications;
d) if they consider that the processing concerning them is in breach of the Regulation, the right to lodge a complaint with a Supervisory Authority (in the Member State where they have their habitual residence, in the Member State where they work or in the Member State where the alleged breach has occurred). The Italian Supervisory Authority is Garante per la protezione dei dati personali, based in Piazza Venezia, n. 11, 00186 - Rome (RM), Italy (www.garanteprivacy.it).
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The Foundation shall not be deemed as liable for updating all the links displayed in the present cookie policy, therefore, whenever a link does not work and/or is not updated, Users shall acknowledge and accept that they shall always refer to the document and/or section of websites referred to in that link.