Dear Customer,

We wish to inform you that our site uses cookies to offer you an optimized and personalized web service. With this policy, we want to inform you about how and for what purposes we use cookies.

1. Definition of “COOKIES”

Cookies are short fragments of text (letters and / or numbers) that allow the web server to store information about the client (the browser, i.e. Internet Explorer, Chrome, Firefox, Opera …) to be reused during the same visit to the site called session cookies, or later on, even after days using persistent cookies. Cookies are stored, according to user preferences, by the single browser on the specific device used (computer, tablet, smartphone). Similar technologies for example, web beacons, clear GIFs and all forms of local storage introduced with HTML5, can be used to collect information on user behavior and the use of services. A cookie cannot retrieve any other data from the user’s hard drive or transmit computer viruses or acquire email addresses. Each cookie is unique to the user’s web browser. Some of the functions of cookies can be delegated to other technologies. The term ‘cookie’ refers to cookies and all similar technologies.

Based on the characteristics and use of cookies, various types of cookies can be identified:

Strictly necessary technical cookies

These are cookies that are essential for the proper functioning of a website and are used to manage various services related to websites, such as a login or access to reserved functions on the sites. The duration of cookies is strictly limited to the work session or they can be used for a longer time period in order to remember the visitor’s choices. Disabling strictly necessary cookies can compromise the experience of using and browsing the website.

Analysis (analytics) and performance cookies

These are cookies used to collect and analyze the traffic and use of a website anonymously. These cookies, without identifying the user, could allow for detection if the same user returns and connects to the site at different times. They also allow the monitoring of the system and improve its performance and usability. The deactivation of these cookies can be carried out without any loss of functionality and will be discussed in detail later.

Profiling cookies

These are permanent cookies used to identify (anonymously or not) user preferences and improve their browsing experience. For more information on these cookies, please visit the appropriate section on the website www.garanteprivacy.it/cookie.

2. Purpose of processing and purposes of technical session cookies

The cookies used on the Site have the sole purpose of carrying out computer authentication or monitoring sessions and storing specific technical information regarding users who access the servers of the Data Controller that manages the Site. In this perspective, some operations on the Site could not be performed without the use of cookies, which in such cases are therefore technically necessary. By way of example, access to any reserved areas of the Site and the activities that can be carried out there would be much more complex to carry out and less secure without the presence of cookies that allow you to identify the user and maintain identification within the scope of the session.

Pursuant to Article 122, paragraph 1, of the Privacy Code (in the wording in force following the entry into force of Legislative Decree 69/2012), “technical” cookies can be used even without the consent of the interested party. Among other things, the same European body that brings together all the Privacy Authorities from the various Member States (the so-called “Article 29” Group) clarified in article 4/2012 (WP194) entitled “Exemption from consent for the use of cookies “which are cookies for which it is not necessary to obtain the user’s prior and informed consent:

1) cookies with data compiled by the user (session identifier), for the duration of a session or persistent cookies limited to a few hours in some cases;

2) authentication cookies, used for the purposes of authenticated services, for the duration of a session;

3) user-centric security cookies, used to identify authentication abuses, for a limited persistent duration;

4) session cookies for multimedia players, such as cookies for “flash” readers, lasting a session;

5) session cookies for load balancing, lasting one session;

6) persistent cookies for customizing the user interface, lasting a session or little more;

7) cookies for sharing content through third party social plug-ins, for members of a social network who have logged in.

The Data Controller therefore informs that the technical cookies (such as those listed above) are operational on the Site, which are necessary to navigate the Site since they allow essential functions such as authentication, validation, management of a browsing session and fraud prevention. They could also allow  : to identify whether the user has had regular access to the areas of the site that require prior authentication or user validation and the management of sessions relating to the various services and applications or the storage of data for access in a secure mode or the functions of control and prevention of fraud.

For maximum transparency, a series of technical cookies and cases of specific operation in a generic way on the Sites are listed below:

• cookies placed in the user’s / contractor’s terminal directly such as session cookies used to “fill the cart” in online bookings on the Site, authentication cookies, cookies for multimedia content such as flash players that do not exceed the duration of the session, personalization cookies (for example, for the choice of the navigation language, recall of ID and complete password by entering the first characters, etc); They will not be used for other purposes.

• the cookies used to statistically analyze accesses / visits to the site (so-called “analytics” cookies) that exclusively pursue statistical purposes, not for profiling or marketing, and collect information in aggregate form without the possibility of tracing the identification of the individual user. In these cases, since the current legislation requires that the data subject be provided with a clear and adequate indication of the simple ways to oppose (opt-out) to their installation for analytics cookies (including any anonymization mechanisms of the cookies themselves) , we specify that it is possible to deactivate analytics cookies as follows: open your browser, select the settings menu, click on the Internet options, open the privacy tab and choose the desired cookie blocking level. If you want to delete the cookies already saved in the memory, simply open the security tab and delete the history by ticking the “delete cookies” box.

Third party cookies

By visiting a website, you may receive cookies from sites managed by other organizations (“third parties”) that may be in Italy or abroad. An example present on most websites is the presence of YouTube videos, Google API, use of Google Maps, and the use of “social plugins” for Facebook, Twitter, Google+ and LinkedIn. These sections of the website are generated directly by the aforementioned sites and integrated into the host site page. The most common use of social plugins is aimed at sharing content on social networks in order to increase the visitor’s user experience. The presence of these plugins involves the transmission of cookies to and from all sites managed by third parties. The management of the information collected by “third parties” is governed by the relevant information to which reference should be made.

3. Responsibility for the operation of Third Party Cookies

In this regard, reference is made to the provisions of the General Provision of the Privacy Guarantor on cookies dated 8 May 2014:

“There are many reasons why it is not possible to place the obligation on the publisher to provide a policy and obtain consent to the installation of cookies within its site, even for those installed by “third parties”. In the first place, the publisher should always have the tools and the economic-legal capacity to take on the obligations of third parties and should therefore also be able to verify from time to time the correspondence between what is declared by the third parties and the purposes they actually have and pursue with the use of cookies. This is made very difficult by the fact that the publisher often does not directly know all the third parties that install cookies through their site and, therefore, not even the logic underlying the related processing. In addition, it is not uncommon for the publisher and third parties to interfere with subjects who play the role of concessionaires, making it very complex for the publisher to control the activities of all those involved. Third-party cookies could then be modified over time by third-party suppliers and it would be impractical to ask publishers to keep track of these subsequent changes as well. “

As indicated by the Privacy Guarantor, this Site does not have the ability to control third-party cookies if it uses third-party services such as YouTube, Google Maps, “social media buttons”, etc, for which only third parties are responsible. Furthermore, we remind the user that it is possible for the user to cancel and block the operation of cookies at any time by also using plugins for the browser and changing their settings as indicated in the various manuals contained in the browsers.

4. Mandatory or optional consent for the use of cookies that do not pursue marketing purposes

It is not mandatory to obtain consent to the use of only technical, third-party or analytical cookies similar to technical cookies. Their deactivation and / or denial of their use will result in the impossibility to properly navigate  the Site and / or the inability to use the services, pages, features or content available there.

5. Details of the Data Protection Office

The Data Protection Office is IL SALOTTO DI PENELOPE S.R.L. C.F. / P.IVA 03743381208 located in Via San Felice, 116 – 40122 Bologna (BO).

6. Exercise of rights by the interested party

With particular reference to the rights of users regarding cookies, some links are provided below for further information:

AboutCookies.org: for more information on cookies and how they affect the browsing experience.

Youronlinechoices.com: for a broad view on cookies, best practices and the use of targeted advertising through the use of cookies.

The Cookie section on www.garanteprivacy.it/cookie to learn about the best practices provided by the Guarantor for the protection of personal data.

7. Rights of the interested party

At any time, you can exercise, pursuant to articles 15 to 22 of EU Regulation no. 2016/679, the right to:

to. request confirmation of the existence or not of your personal data;

b. obtain information on the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be communicated and, when possible, the retention period;

c. obtain the correction and deletion of data;

d. obtain the limitation of the treatment;

is. obtain data portability, i.e. receive them from a Data Protection Office, in a structured format, commonly used and readable by an automatic device, and transmit them to another Data Protection Office r without impediments;

f. oppose the treatment at any time and also in the case of treatment for direct marketing purposes;

g. oppose an automated decision-making process relating to natural persons, including profiling;

h. withdraw consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation;

i. send a written complaint to a supervisory authority, Guarantor for the processing of personal data Piazza di Monte Citorio n. 121 00186 ROME Fax: 06.69677.3785 Telephone switchboard: 06/696771 E-mail: garante@gpdp.it PEC: protocol@pec.gpdp.it

You can exercise your rights by sending an official and documentable communication using one of the following channels:

– Registered handwritten certified mail to be delivered at the registered office of the Data Protection Office;

– Sending an e-mail with notification of successful delivery and reading to the email address of the Data Protection Office company.

Before providing you with information, or modifying any information, it may be necessary to verify your identity, answer some questions and fill in an official request form that will be provided to you by the owner himself. An answer will be provided in the shortest time possible.