Cookie policy.

For the purposes of this Cookie Policy:

1. «cookies» means portions of data, typically in the form of alphanumeric strings, that the websites visited send to the user's terminal (usually the browser), where they are stored to be retransmitted to the same sites on the user's subsequent visits;
2. «assimilable technologies» or «passive identifiers» means the further tracking techniques capable of identifying the user or the user's device, such as, by way of example, local storage, session storage, web beacons, pixel tags, device fingerprinting and any further techniques that achieve effects analogous to cookies in terms of accessing or storing information on the user's terminal;
3. «first-party cookies» means cookies installed directly by the Controller;
4. «third-party cookies» means cookies installed, through the Site, by parties other than the Controller, in relation to which such parties act as independent controllers or joint controllers, as the case may be.

The Site uses only first-party technical cookies and — subject to the prior acquisition of valid consent provided by the user through the short-notice banner — analytics cookies and further tracking tools, in accordance with the distinctions set out below.

3.1. Technical cookies

This category includes cookies used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information-society service explicitly requested by the user to deliver that service. They do not require the user's prior consent, pursuant to Article 122 of the Privacy Code and the Garante's Provision of 10 June 2021. The legal basis for the related processing is, as regards the GDPR, the Controller's legitimate interest under Article 6(1)(f), consisting in the technical need to deliver the requested service.

Technical cookies are in turn divided into:

• navigation or session cookies, intended to ensure normal browsing and use of the Site (allowing, for example, authentication, storing the language or accessibility preferences, managing the cart of a request);
• strictly anonymised first-party analytics cookies, used directly by the Controller to collect aggregated information on the number of users and how they visit the Site, provided that they are subject to measures that reduce the identifying power of the cookies pursuant to paragraph 5.1 of the Garante's Provision of 10 June 2021 (such as, in particular, masking the significant octets of the IP address and the absence of cross-referencing with other data);
• functionality cookies, which allow the user to browse on the basis of a set of selected criteria (such as language or products selected for purchase) in order to improve the service provided.

3.2. Third-party analytics cookies

As a rule, the Controller does not use third-party analytics cookies. Should such tools be introduced, their installation will be preceded by the acquisition of freely given, specific, informed and unambiguous consent pursuant to Articles 4(11) and 7 of the GDPR, expressed through the cookie preferences panel made available on the Site.

3.3. Profiling cookies

These are cookies used to attribute to specific, identified or identifiable subjects particular actions or recurring behavioural schemes in the use of the features offered (patterns) in order to group the various profiles into homogeneous clusters of differing breadth, so that the Controller may, among other things, tailor the provision of the service in an increasingly personalised way and send targeted advertising messages. The installation of profiling cookies requires the user's prior, freely given, specific, informed and unambiguous consent. As at the date of adoption of this Cookie Policy, the Controller does not install profiling cookies of its own.

3.4. Third-party cookies

Third-party cookies may be installed through the Site when the user views pages containing embedded content originating from third parties (for example, videos published on external platforms). With reference to such cookies, the third parties act as independent controllers or, as the case may be, as joint controllers pursuant to Article 26 GDPR; accordingly, the detailed information on the methods of processing, the purposes and the legal bases is set out in the corresponding notices issued by the respective controllers, to which full reference is made.

The following is the named list of cookies and assimilable technologies installed on the Site, together with their purpose, nature and duration. The list may be subject to change; users are invited to consult this Cookie Policy and the preferences management panel accessible from the Site periodically.

No first-party or third-party profiling cookie is installed in the absence of the user's prior consent. Any subsequent changes to the set of tracking tools used will be reflected in this list and, where they introduce processing subject to consent, will be preceded by a renewed acquisition of such consent.

On first access to the Site, the user is presented with a short-notice banner that contains no discriminatory mechanisms between the choice options nor any pre-selected options, through which it is possible to: (i) consent to the installation of all tracking tools subject to consent; (ii) refuse their installation; (iii) access the detailed preferences panel to express granular choices in relation to the various categories of tools.

In line with the Garante's Provision of 10 June 2021, closing the banner by means of the «X» command or by simply scrolling the page does not amount to the user's consent; the choices expressed by the user, whether to accept or to refuse, are recorded and retained by the Controller for a period not exceeding six months, after which the banner will be presented again on the next access.

The user may amend their choices at any time by accessing the cookie preferences panel through the «Manage cookie preferences» link made available at the foot of each page of the Site. The withdrawal of consent will take effect only for the future and will not affect the lawfulness of the processing carried out before the withdrawal, pursuant to Article 7(3) GDPR.

Irrespective of the choices expressed through the preferences panel, the user may, at any time, configure their browser to refuse, accept or delete the installed cookies. It should be noted, however, that disabling technical cookies may impair the correct use of the Site.

Operating instructions for managing cookies are available on the official websites of the respective browser providers, by way of example:

• Google Chrome — «Settings» › «Privacy and security» › «Cookies and other site data»;
• Mozilla Firefox — «Settings» › «Privacy & Security» › «Cookies and Site Data»;
• Apple Safari — «Settings» › «Privacy» (desktop version) or «Settings» › «Safari» › «Privacy & Security» (mobile version);
• Microsoft Edge — «Settings» › «Cookies and site permissions»;
• Opera — «Settings» › «Advanced» › «Privacy & security» › «Cookies».

The user is informed that deleting cookies from their browser will result in the deletion of the cookie in which the expressed choices are stored, with the consequence that, on the next access, the short-notice banner will be presented again.

The personal data collected through first-party cookies are processed by the Controller's authorised personnel and by the parties designated as processors under Article 28 GDPR, in particular providers of hosting, statistical analysis and IT security services, operating, as a rule, within the European Economic Area.

In the absence of current providers established in third countries, no non-EU transfers of personal data arising from the use of the installed cookies are taking place. Should a transfer to a third country become necessary due to future infrastructure updates, the Controller will first verify the existence of one of the conditions for lawfulness provided for in Chapter V of the GDPR and will update this Cookie Policy accordingly.

With reference to the processing described in this Cookie Policy, the data subject is entitled to the rights set out in Articles 15 to 22 of the GDPR, listed in detail in section no. 08 of the Privacy Policy, including the right to lodge a complaint with the Italian Data Protection Authority (Piazza Venezia no. 11, 00187 Rome — garante@gpdp.it — www.gpdp.it) or to bring proceedings before the competent judicial authority.

The exercise of these rights is free of charge and may take place at any time by written communication to the email address accounts@atlanticanalytics.it or to the postal address of the Controller's registered office.

The Controller reserves the right to make changes to this Cookie Policy in light of regulatory developments, measures of the supervisory authority, the introduction of new tracking tools or functional requirements of the Site. Changes will be made known by publishing the updated version on the Site, indicating the effective date. Where the changes entail the introduction of processing subject to the user's consent, such consent will be requested again before the relevant tools are installed. Users are invited to consult this Cookie Policy periodically.

For any request, communication or exercise of rights concerning the protection of personal data relating to the cookies installed on the Site, the data subject may contact the Controller at the following email address: accounts@atlanticanalytics.it, or at the postal address of the registered office indicated above. The Controller will respond to the requests received within one month of their receipt, subject to the extensions permitted by applicable law.