COOKIE POLICY

Types of Data Processed, Purposes of Processing, and Legal Basis

Through the website, different types of personal data are collected and processed for various purposes. We can only process your data for certain purposes and, in any case, always in the presence of a legal basis that allows us to do so. Specifically, we process:

1. Navigation Data and Cookies

Cookies are small amounts of data, often containing a unique anonymous identifier code, which are sent to the visitor’s browser by a web server and are subsequently stored on the user’s hard drive. Cookies are then read and recognized only by the website that sent them each time a subsequent browsing session is carried out. Generally, cookies are used by websites to recognize users within a work session. This website uses technical cookies, namely short text files that are saved on visitors’ devices and stored in specific folders depending on the type of browser used (both on mobile and desktop). Cookies keep track of the actions performed by those who have visited the site, such as closing a pop-up window, and allow, for example, the prevention of the same window from being shown again. These are personal data, the transmission of which is implicit in the use of Internet communication protocols.

The use of cookies is necessary to improve the user’s browsing experience; however, you can also choose to disable them using the specific functionality of the browser you are using. The types of cookies used by the site are: proprietary, session, persistent, profiling, and third-party cookies. Proprietary, session, and persistent cookies process information that is not collected to be associated with identified data subjects, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. These include, for example, IP addresses or domain names of the computers used to connect to the site, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters relating to the user’s operating system and IT environment. Through profiling cookies, data can instead be collected to monitor and profile users during navigation, study their movements and browsing habits, also for the purpose of sending targeted and personalized advertising services. Their use requires the prior acquisition of the free informed consent of the user in accordance with EU Regulation 2016/679. Third-party cookies (Google, Google Analytics Firefox, and Facebook) are created by other sites that own the content and are displayed on the website’s web page being visited. It may happen, in fact, that a web page also contains cookies from other sites and content in various elements hosted on the same page, such as advertising banners, images, videos, maps, or specific links to web pages of other domains that reside on servers different from that on which the requested page is located. In other words, these cookies are set directly by website managers or servers other than this website. In this regard, please refer to the information published on the following sites:

Google: https://www.google.com/intl/en/policies/privacy/ Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences Facebook: https://www.facebook.com/policies/cookies/

To disable the Google Analytics add-on: https://tools.google.com/dlpage/gaoptout?hl=en

Purposes: We use the data collected through proprietary, session, persistent, and third-party cookies solely for the purpose of enabling the operation of the website, obtaining anonymous statistical information about the use of the site through analytics to monitor its correct functioning. The data may be used for security purposes and system administration. Profiling cookies, on the other hand, are intended to create user profiles and are used to send advertising messages in line with the preferences expressed by the user during navigation.

Legal Basis: The processing of data collected through proprietary, session, and persistent cookies is based on the legitimate interest of Holive in ensuring the correct functioning and security of the site and the user’s ability to navigate properly on the site. The processing of data from profiling cookies is based on the express consent obtained through the acceptance of a banner presented to the user as soon as they connect to the website’s URL. In case of refusal to give consent, no commercial communications will be sent to the visitor, and no data will be collected to create user profiles. In any case, each visitor can independently set their computer’s browser to accept/reject all cookies or display a notice whenever a cookie is offered, to evaluate whether to accept it or not. If the user sets their browser to refuse to activate cookies, the quality of the visited pages may be reduced, and the browsing experience may be less effective.

Here are the links to manage cookies independently:

Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11 Google Chrome: https://support.google.com/accounts/answer/61416?hl=en Apple Safari: http://support.apple.com/kb/HT1677?viewlocale=en_US Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences Flash: https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager02.html#118539

2. Data Provided Voluntarily to Send Your Requests through the Appropriate “Forms”

These are personal data that you provide to us when making requests through the appropriate “forms,” such as the “Contact” form (identifying and contact data) or those that we lawfully acquire during your interaction with the website.

Purposes: We process this data to respond to your requests and provide you with the assistance and information requested about the services of eugenioriotto.it. Your data may also be used to send you promotional communications via email, WhatsApp, or Telegram.

Legal Basis: The processing is based on the legitimate interest of eugenioriotto.it in providing website services and responding to users’ requests, as well as on the express consent for processing for promotional purposes.

Obligatory or Optional Nature of Data Provision

Providing eugenioriotto.it with personal data collected through the website to respond to your requests or to improve the browsing experience is voluntary and optional. Failure to provide it does not limit the use of the site but may make it impossible for eugenioriotto.it to respond to requests for information and informational material. The provision of personal data (personal data, email address, etc.) is necessary to carry out your request for information. Failure to provide this data may therefore constitute, depending on the case, a legitimate and justified reason for not fulfilling the request for information and/or booking of facilities. Depending on the case or, if necessary, the obligatory or optional nature of data communication will be indicated from time to time, sometimes adding a (*) next to the obligatory information, i.e., only data necessary for the provision of services and purchase of products on the website. Failure to provide optional personal data will not entail any obligation or disadvantage.

How We Process Your Data

Data processing mainly occurs electronically and, if necessary, with paper materials that can also be carried out with manual tools.

Security Measures We Adopt to Process Your Data

We guarantee that the processing of your data takes place with the utmost security: we have indeed adopted physical, computer, and organizational measures suitable for ensuring the protection of your data.

Categories of Recipients of Your Personal Data

Eugenioriotto.it communicates the personal data of website users only within the limits permitted by law and in accordance with what is indicated below. In particular, your personal data may be known by the following authorized subjects:

• Employees and consultants, who will act as authorized subjects for processing for the internal organization of business activities. The processing of your personal data by the aforementioned subjects is always carried out within the limits of the purposes for which they were collected, only when strictly necessary to ensure the maximum functionality of our services, and in accordance with the security measures and good practices described in this privacy policy. Your personal data may also be known by the police or the judicial authority, in compliance with the law and upon formal request by such subjects, or if there are reasonable grounds to believe that the communication of such data is reasonably necessary to investigate, prevent, or take action regarding suspected illegal activities or assist state supervisory and control authorities; defend against any claims or accusations from third parties, or protect the security of our website and company; or exercise or protect the rights, property, or safety of eugenioriotto.it, its affiliates, its customers, its employees, or any other entity. Your personal data will not be disclosed in any way.

How Long We Will Retain Your Data

Your data will be retained for no longer than 24 months from the achievement of the purposes for which they are processed or from the granting of your express consent.

Location of Processing

Some of your data may be transferred outside the national territory, to countries located in the European Union, or even outside the European Union. With reference to transfers outside the territory of the European Union to countries not considered adequate by the European Commission, Holive adopts appropriate and adequate security measures to protect your personal data. Consequently, any transfer of your data to countries located outside the European Union will take place, in any case, in compliance with appropriate and adequate guarantees for the purpose of transfer, pursuant to applicable legislation and, in particular, Articles 45 and 46 of EU Regulation 679/2016.

Your Rights

You can always exercise the rights provided for in the Regulation by sending us an email to the following address: info@eugenioriotto.it The rights recognized by the Regulation are as follows:

• request access to personal data and information about them; rectification of inaccurate data or integration of incomplete data; erasure of personal data concerning you (where one of the conditions set out in Article 17, paragraph 1 of the GDPR applies and subject to the exceptions provided for in paragraph 3 of the same article); restriction or objection to the processing of your personal data (where one of the cases set out in Article 18, paragraph 1 of the GDPR applies);
• request and obtain from the Data Controller – in cases where the legal basis for processing is consent, and it is carried out by automated means – your personal data in a structured, commonly used, and machine-readable format, also for the purpose of transmitting such data to another data controller (i.e., the right to data portability);
• object at any time to the processing of personal data in certain circumstances;
• object to the use of your data through automated decisions, including profiling.
• withdraw consent at any time, only for cases where processing is based on your consent for one or more specific purposes and concerns common personal data (e.g., date and place of birth or residence), or special categories of data (e.g., data revealing racial origin, political opinions, religious beliefs, health status, or sexual life). Processing based on consent carried out prior to its withdrawal remains lawful;
• lodge a complaint with the supervisory authority (Personal Data Protection Authority – www.garanteprivacy.it).

We will provide you with information within 15 days of your request, unless this would prejudice the rights and freedoms of others (e.g., another person’s confidentiality or intellectual property rights) or unless there are legal obligations preventing us from doing so. Naturally, we will inform you in case we are unable to fulfill your request for such reasons.

Thank you for reading this information. For any request or clarification, please write to us at the following address: info@eugenioriotto.it

This cookie policy may be amended in the future in relation to any changes regarding the processing, legislative updates, or simply to make it even more transparent. Therefore, we kindly ask you to periodically review it.