Cookie Policy

Information and consent for the use of cookies


1. What are cookies?

Cookies are small text files that sites visited by users send to their terminals, where they are stored and then transmitted back to the same sites on the next visit. Cookies from so-called "third parties" are, on the other hand, set by a website other than the one the user is visiting. This is because on each site there may be elements (images, maps, sounds, specific links to web pages on other domains, etc.) that reside on servers other than that of the site being visited.


2. What are cookies used for?

Cookies are used for different purposes: performing computer authentication, session tracking, storing information about specific configurations regarding users accessing the server, storing preferences, etc.


3. Is the user's consent required for the installation of cookies on his/her terminal?"

It depends on the purposes for which the cookies are used and, therefore, whether they are "technical" or "profiling" cookies. For the installation of technical cookies, the users' consent is not required, while it is necessary to give the information (art. 13 of the Privacy Code). Profiling cookies, on the other hand, can only be installed on the user's terminal if the user has given consent after being informed in a simplified manner.


4. How should the site owner provide the simplified notice and request consent for the use of profiling cookies?"

As stated by the Guarantor in the order indicated in question no. 4, the disclosure should be set up on two levels. The moment the user accesses a website (on the home page or on any other page), a banner must immediately appear containing an initial "brief" disclosure, a request for consent to the use of cookies, and a link to access a more "extended" disclosure. On this page, the user can find more and more detailed information about cookies choose which specific cookies to allow.


5. How should the banner be made?

The banner must be large enough to partially cover the content of the web page the user is visiting. It must be able to be removed only by active user intervention, that is, by selecting an element contained on the page below.


6. What indications must the banner contain?

The banner must specify that the site uses profiling cookies, possibly including "third-party" cookies, which allow it to send advertising messages in line with the user's preferences.It must contain a link to the extended information notice and an indication that, through that link, it is possible to deny consent to the installation of any cookies.It must specify that if the user chooses to continue by "skipping" the banner, he or she consents to the use of cookies.


7. How can the acquisition of consent made through the use of the banner be documented?

In order to keep track of the consent acquired, the site owner can make use of a special technical cookie, a system that is not particularly invasive and does not in turn require further consent.In the presence of such "documentation," it is not necessary for the short information notice to be repeated on the user's second visit to the site, without prejudice to the possibility for the user to deny consent and/or modify, at any time and in an easy manner, his or her options, for example by accessing the extended information notice, which must therefore be linkable from every page of the site.


8. Can online consent to the use of cookies be sought only through the use of a banner?"

No. Site owners always have the option to use other modalities than the one identified by the Guarantor in the above-mentioned order, provided that the chosen modalities have all the requirements for the validity of consent required by law.


9. Does the obligation to use the banner also apply to owners of sites that use only technical cookies?

No. In this case, the site owner may give the information to users in the manner it deems most appropriate, for example, including by including the relevant information in the privacy policy indicated on the site.


10. What must the "extended" information statement indicate?

It must contain all the elements required by the law, describe analytically the characteristics and purposes of the cookies installed by the site and allow the user to select/deselect individual cookies.It must include the updated link to the disclosures and consent forms of third parties with which the owner has entered into agreements for the installation of cookies through its site.Finally, it must recall the possibility for the user to manifest his or her options on cookies also through the settings of the browser used.


11. Who is required to provide the information and request consent for the use of cookies?

The owner of the website that installs profiling cookies.

For third-party cookies installed through the website, the information and consent obligations fall on the third parties, but the website owner, as a technical intermediary between them and users, is required to include in the "extended" information notice the updated links to the third parties' own information notices and consent forms.


12. Should the Garante be notified of the use of cookies?

Profiling cookies, which usually persist over time, are subject to the notification requirement, while cookies that serve different purposes and fall under the category of technical cookies do not have to be notified to the Guarantor.


13. When do the measures prescribed by the Guarantor in the order of May 8, 2014 come into effect?

The Garante has provided for a transitional period of one year from the publication of the measure in the Official Gazette to allow those affected to come into compliance. This period will end on June 2, 2015.