COOKIE POLICY

The websites:

Identity and contact details of the Joint Controllers:

Digital360 S.p.A., ICTandStrategy S.r.l., Partners4Innovation S.r.l., with registered office in Milano, via Copernico n° 38 – 20125 and all subsidiary and associated companies of the Digital360 Group, namely:

- FPA S.r.l. with registered office in Roma, via Ostiense n° 92 – 00154

- PINEVENT S.r.l. with registered office in Milano, via Copernico n° 38 – 20125

- IQ Consulting S.r.l. with registered office in Milano, via Copernico n° 38 – 20125

- SERVICEPRO ITALY S.r.l. with registered office in Cernusco sul Naviglio (MI), via Giuseppe Mazzini n° 5 – 20063

Telephone number: 02/92852779, e-mail address: privacy@digital360.it.

Contact details of the Data Protection Officer (DPO): Via Copernico, n° 38, CAP 20125 Milano e-mail: dpo@digital360.it.

Personal Data Processed

Navigation data.

What are the cookies?

Cookies are small text fragments, usually consisting of letters and/or numbers, which are transmitted by the website visited and stored by the software (e.g. a web browser) installed on the device used by the user for browsing. Cookies are then transmitted back to the aforementioned website the next time the user visits.

Cookies make it possible to store information about a user's visits to a website and are a very useful technology, for example to make websites work more efficiently and to provide useful information to website operators. Without cookies, or other similar technologies, websites would have no way of 'remembering' information about visitors, such as how many items the user has placed in their shopping cart or whether or not they are logged in.

Cookies can be classified according to:

• duration: session or persistent cookies

• origin: first party or third-party cookies;

• purpose: technical, analytics or profiling cookies.

Cookies that expire at the end of a browser session (normally when a user closes their browser) are called session cookies and are useful for example to store a user's purchase order or for security purposes, such as when accessing their internet banking or webmail account. Cookies that are stored for a longer period of time (between sessions) are called persistent cookies and are useful e.g. to remember your preferences or to serve you targeted advertising.

The definition of first party or third party refers to the website or domain that installs the cookie. First party cookies are installed directly by the website you are visiting, whereas third party cookies are installed by a domain other than the one you are visiting, for example if the website incorporates elements from other sites, such as images, social media plugins or advertising.

It should be noted that the purposes usually served by a cookie may also be served by other similar technologies, including the use of certain features that allow devices to be identified so that visits to a website can be analysed. In fact, this policy applies to any technology that stores or accesses information on your device. This might include, for example, HTML5 local storage, Local Shared Objects (also called flash cookies) and fingerprinting techniques. In particular, device fingerprinting is a technique that involves combining a range of information in order to uniquely identify a particular device. Examples of the information that device fingerprinting can detect, associate or infer include:

• data derived from the configuration of a device;

• data derived from the use of particular network protocols;

• JavaScript;

• HTTP header information, clock information;

• installed fonts;

• plug-ins installed in the browser.

It is also possible to combine these elements with additional information, such as IP addresses or unique identifiers, etc.

From now on, when referring to cookies, this definition will also include other assimilated technologies.

What are the purposes of the cookies used by this site?

Depending on their purpose, the cookies installed on this website are divided into technical cookies, analytical cookies and profiling cookies.

Technical cookies are necessary for the functioning of the website because they enable functions to facilitate the user's browsing, e.g. the user can access his or her profile without having to log in each time, or can select the language he or she wishes to use to browse the site without having to set it each time.

Technical cookies are considered strictly necessary, because the storage of information is essential to provide a service requested by the user. Therefore, technical cookies cannot be disabled and the users' prior consent is not required for their installation (pursuant to art. 122 of the Privacy Code).

Analytical cookies, which may be first or third party, are installed to collect information on the use of the website. In particular, they are useful for statistically analysing accesses or visits to the site itself and to allow the owner to improve its structure, navigation logic and contents. The information collected (including the IP address, which is masked) is used to carry out statistical analysis in order to improve the use of the site and possibly to make the content more interesting and relevant to the user's wishes.

Analytical cookies are not necessary for the functioning of the website, however, since the IP address is not displayed in clear text the installation of such cookies does not require the user's consent.

Profiling cookies, which may be first or third party, are used to track the user's browsing, analyse their behaviour for marketing purposes and create profiles on their tastes, habits, choices, etc.. In this way it is possible, for example, to send targeted advertising messages in relation to the user's interests and in line with the preferences expressed by the user when browsing online. These cookies also include social cookies.

These cookies can only be installed on the user's terminal if the user has given his or her consent.

Below, you will find for each type of cookie, the name, whether first or third party, the purpose of use and the link to the third party and the duration:

How are cookie preferences managed?

Upon first accessing any page of the Site, a banner will appear containing a short information notice and the cookie preference panel/button through which you can accept all cookies. The user has the possibility to select/deselect individual categories of cookies. Consent to the use of cookies is recorded with a special "technical cookie".

Cookie Center

However, users can also express their preferences regarding cookies through the settings of the browser used. By default almost all web browsers are set to automatically accept cookies, but users can change the default configuration through the settings of the browser used, which allow to delete/remove all or some cookies or block the sending of cookies or limit them to certain sites.

Disabling/blocking cookies or deleting them may affect the optimal use of some areas of the site or prevent certain features, as well as affect the operation of third party services.
The configuration of cookie management depends on the browser used. Below are instructions and links to guides on how to manage cookies for the main desktop browsers:

Microsoft Edge: click on the icon with the three dots in the top right-hand corner and then on 'Settings'. From the menu on the left, select 'Cookies and site permissions' and adjust your cookie settings. Below is a link to more information:

https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

Google Chrome: click on the icon with the three dots in the top right-hand corner and then on 'Settings'. Select 'Advanced' and in the 'Privacy and security' section click on 'Site settings'. Then adjust your cookie settings by selecting 'Cookies and site data'. Here is a link to more information:

https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies

Mozilla Firefox: click on the icon with the three horizontal bars in the top right-hand corner and select "Options". In the window, select "Privacy and Security" to adjust your cookie settings. Here is a link to more information:

https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=Enabling+and+disabling+cookies&redirectlocale=en-USe

Apple Safari: select "Preferences" and then "Privacy" to adjust your cookie settings. Here is the link to get more information:

https: //support.apple.com/en-gb/guide/safari/sfri11471/mac

Opera: select the icon with the three horizontal bars at the top right and then "Advanced". Select "Privacy & Security" and then "Site Settings". From the "Cookies and site data" section, adjust your cookie settings. Here is a link to more information:

https://help.opera.com/en/latest/web-preferences/#cookies

For browsers other than those listed above, it is necessary to consult the corresponding guide to find out how to manage cookies.

Mandatory Data Provision

The personal data processed through the installation of both technical and analytical cookies (since the IP address is not displayed in clear text) are necessary to ensure proper navigation within the site.

It is optional to give consent to the installation of profiling cookies. Your personal data will only be processed by these cookies with your express consent in the manner indicated above.

Personnel authorised to process data

The data may be processed by the employees of the company departments responsible for pursuing the above-mentioned purposes, who have been expressly authorised to do so and who have received adequate operating instructions.

Data Recipients

The data may be processed by external subjects operating as data controllers such as, by way of example, authorities and supervisory and control bodies and, in general, by subjects, also private, entitled to request the data, Public Authorities that make an express request to the Joint Controllers for administrative or institutional purposes, in accordance with the provisions of the national and European regulations in force, as well as persons, companies, associations or professional firms providing assistance and consultancy.

The data may also be processed, on behalf of the Joint Controllers, by external subjects designated as data processors, who are given appropriate operating instructions. These subjects are essentially included in the following categories:

a) companies that offer e-mailing services;

b) companies that offer maintenance services for the website and information systems;

c) companies that offer support in carrying out market studies;

d) companies that provide management and maintenance services for the database of the Joint Controllers;

e) companies offering management services for the marketing automation platform.

Your personal data may be processed, if you give your explicit consent, by third parties to whom they are communicated.

Transfer of personal data to countries outside the European Union

Data collected using cookies may be transferred outside the European Union, to countries whose level of data protection has been deemed adequate by the European Commission pursuant to Article 45 of the GDPR.

Furthermore, personal data may be transferred to non-EU countries, and in particular to the United States (by way of example, Google, Hubspot, Social Networks), upon signature of the Standard Contractual Clauses adopted/approved by the European Commission pursuant to Art. 46, 2, lett. c) and d).

A copy of the adopted guarantees may be obtained by writing an e-mail to the following address: privacy@digital360.it.

Data collected using all other cookies will not be further disseminated.

Rights of the data subject - Complaint to the supervisory authority

By contacting the Joint Controllers by e-mail at privacy@digital360.it, data subjects may request access to the data concerning them, their deletion, the rectification of inaccurate data, the integration of incomplete data, the restriction of processing in the cases provided for by Article 18 GDPR, as well as the opposition to processing, for reasons related to their particular situation, in cases of legitimate interest of the Joint Controllers.

Moreover, the data subjects, in the event that the processing is based on consent or contract and is carried out by automated means, have the right to receive in a structured, commonly used and machine-readable format the data, as well as, if technically feasible, to transmit them to another controller without hindrance.

Data subjects have the right to withdraw their consent at any time for marketing and/or profiling purposes, as well as to object to the processing of their data for marketing purposes, including profiling in connection with direct marketing. If the data subject prefers to be contacted for such purposes exclusively by traditional means, he/she may object only to receiving communications by automated means.

Data subjects have the right to lodge a complaint with the competent supervisory authority in the Member State where they usually reside or work or in the State where the alleged infringement occurred.

Last update: January 2021