Privacy and cookie policy

The owner of the processing of your data is Digital360 S.p.A., having its registered office in Milan (MI), viale Bodio n. 37 - 20158, e-mail address privacy@digital360.it (hereinafter, "Owner").

The Holder's DPO can be reached at the following contact point: dpo@digital360.it.

1. Navigation data
   The computer systems and software procedures responsible for the operation of this website acquire, in the course of their n ormal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.
   This category of data includes the IP addresses or domain names of the computers and terminals used by the users who connect to the site, the addresses in URI/URL (Uniform Resource Identifier/Locator) notation of the resources requested, the time of the request, the method used in submitting 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 computer environment.
   These data, necessary for the use of web services, are also processed to:
   • obtain statistical information on the use of the services (most visited pages, number of visitors per time slot or daily, geographical areas of origin, etc.);
   • control the proper functioning of the services offered;
   • exercise and/or defend the Company's rights in court, including in the event of the detection of any crimes by the judicial authorities.
2. Data provided voluntarily by the user
   In order to use certain services, the provision of personal data is necessary, in relation to which please refer to the specific information pursuant to Article 13 of the GDPR provided at the time of collection.
3. Cookies
   The Site uses cookies.
   What are cookies
   Cookies (or markers) are small text files created by the web server on the user's device when accessing a particular site for the purpose of storing and transporting information.
   These markers are sent by the web server to the user's device (usually to the browser) and stored so that it can recognize that device on each subsequent visit. Cookies, in fact, are sent back from the user's device to the site on each subsequent visit.
   First-party and third-party cookies
   Cookies can be installed, however, not only by the same operator of the site visited by the user(first-party cookies), but also by a different site that installs them through the first site(third-party cookies) and is able to recognize them. This happens because on the site visited there may be elements (images, maps, sounds, links to web pages of other domains, etc) that reside on servers other than that of the site visited.
   Pursuant to the provisions of the Measure, for cookies installed by third parties, the obligations of information and, if the conditions are met, of consent fall on the third parties; the owner of the site, as technical intermediary between the third parties and users, is required to include
   in the extended disclosure updated links to the third parties' disclosures and consent forms.
   Technical, analytical and profiling cookies
   Based on purpose, cookies are distinguished into technical cookies and profiling cookies.
   Technical cookies are installed 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 subscriber or user to provide such service" (see Art. 122, co. 1, of the Privacy Code).
   They are usually used to enable efficient navigation between pages, store user preferences, store information about specific user configurations, perform user authentication, etc.
   Technical cookies can be divided into navigation cookies, used for the purpose of recording data useful for normal navigation and enjoyment of the website on the user's computer (allowing, for example, to remember the preferred page size in a list) and cookies
   functional, which allow the website to remember choices made by the user in order to optimize its functionality (for example, functional cookies allow the website to remember a user's specific settings, such as country selection and, if set, login status
   permanent).
   Some of these cookies (called essential or strictly necessary) enable functions without which certain operations would not be possible.
   Pursuant to the aforementioned Art. 122, para. 1, Privacy Code, the use of technical cookies does not require users' consent, but only requires the obligation to inform users.
   Pursuant to the Provision, technical cookies are assimilated - and, therefore, for their installation, the users' consent is not required - the so-called analytics cookies if:
   
   1. made and used directly by the operator of the site first party (without, therefore, the intervention of third parties) for the purpose of optimization of the same
      same to collect aggregate information on the number of users and how they visit the site itself, as well as
   2. made and made available by third parties if:
      1. used by the first party site for purely statistical purposes, if appropriate minimization measures are taken to reduce its identifying power (for example, by masking appropriate portions of the IP address) and used only for the production of aggregate statistics and in relation, as a rule, to a single site or mobile application, so as not to allow tracking of the navigation of the person using different applications or browsing different websites;
      2. the third parties, who provide the web measurement service to the site, do not combine, enrich or cross-reference the data, even minimized as above, with other information such third parties have (e.g., customer files or statistics of visits to other sites) or pass it on to other third parties.
   Profiling cookies, on the other hand, are used to track the user's browsing, analyze their behavior for marketing purposes and create profiles on their tastes, habits, choices, etc. so as to transmit targeted advertising messages in relation to the user's interests and in line with the
   preferences manifested by the latter in online browsing.
   Such cookies can only be installed on the user's terminal if the user has given his or her consent.
   Persistent and session cookies
   Based on their duration, cookies are distinguished into persistent, which remain stored, until they expire, on the user's device, unless removed by the user, and session cookies, which are not stored persistently on the user's device and vanish when the browser is closed.
   Cookies used by the Owner
   Technical Cookies
   The Company uses Cookies for specific and limited purposes; specifically, to provide the user with easier navigation, for internal security purposes, system administration.
   This type of Cookies cannot be disabled and for their installation, as indicated above, the prior consent of users is not required pursuant to Article 122 of the Privacy Code.
   Anonymized analytical cookies
   The Data Controller uses Google Analytics, a web analytics service provided by Google Inc. to identify which pages are most viewed by visitors to the Site, how long they stayed within the Site, and their geographical area of origin. For more details and
   information you can visit the following link: https://support.google.com/analytics/answer/1011397.
   The analytical cookies used, suitably anonymized (by masking significant portions of the IP address), allow the collection of aggregate information on the number of users and how they visit the Site without being able to identify the individual user. For more details and information you can visit the following link: https://support.google.com/analytics/?hl=it#topic=3544906
   Users can selectively disable the action of Google Analytics by installing the appropriate component provided by Google on their browser (by downloading a specific browser plug-in available at this link: https://tools.google.com/dlpage/gaoptout).
   These cookies are not necessary for the operation of the Site, but they are essential to check its effectiveness or to help measure its "traffic", i.e. the number of visitors also possibly broken down by geographic area, time of connection or other characteristics.
   Properly anonymized analytical cookies are equated with technical cookies, and for that reason users' prior consent is not required.
   Profiling cookies
   The Company uses cookies for marketing purposes, used to track visitors on the Site, analyze their behavior for marketing purposes and create a profile regarding tastes, habits and choices. The purpose is to present advertisements that are relevant and engaging to the individual user and therefore of greater value to third-party publishers and advertisers.
   Users' consent is required for the installation of such cookies.
   For a list of cookies installed on the Site, see the table at the end of this document.

Profiling cookies will be installed on your devices only with your consent, expressed by selecting the "Accept All" button or by clicking on "More options", selecting the categories of cookies and clicking on "Save and Exit". Consent to the use of cookies is recorded with a special "technical cookie."
You can always change your choice by clicking on the "Cookie center" button on each page of the Site.
However, users can also manifest their options on cookies through the settings of the browser they use. Even if the web browser used by the user is set to automatically accept cookies, the user can change the default configuration through the settings menu, deleting and/or removing all or some cookies, blocking the sending of cookies or restricting it to certain sites. Disabling, blocking cookies or deleting them may affect the optimal use of certain areas of the Site or prevent certain features of the Site, as well as affect the operation of third-party services. Below are links to guides to cookie management for major browsers:

• Microsoft Internet Explorer
• Microsoft Edge
• Google Chrome
• Mozilla Firefox
• Safari

The data will be processed by employees of the corporate functions and collaborators of the Controller deputed to the performance of activities aimed at the pursuit of the above-mentioned purposes, who have been expressly authorized for processing and have received specific operational instructions.

The data may also be processed, on behalf of the Data Controller, by third parties, designated as Data Processors in accordance with Article 28 of the GDPR, such as natural and/or legal persons who carry out activities functional to the pursuit of the aforementioned purposes (e.g. service providers
for the management of the Site, such as system outsourcers, companies that deal with connectivity services to the internet network, companies that offer support in the realization of market studies, companies that perform CRM management and maintenance services and companies that offer services
management of the marketing automation platform).
In addition, the data may be disclosed to autonomous data controllers, such as authorities and supervisory and control bodies entitled to request/receive the data, as well as to any providers (or third parties or vendors) listed in the above tables containing the list of cookies.

Data may be transferred to entities established outside the European Union (EU) or the European Economic Area (EEA), in particular to the United States, a country deemed adequate by the European Commission within the limits of the "EU-US Data Protection Framework" of July 10, 2023.
Where such entities are located in a country without an adequacy decision, standard contractual clauses (SCCs) will be stipulated as per Art. 46 co. 2 lett. c) of the GDPR, a copy of which can be obtained by contacting the Company at the contact point listed in para. 1.
For more information, if third parties are mentioned in the table below, see the links to the relevant disclosures.

Data subjects may exercise against the Data Controller the rights recognized in Articles 15-22 of the GDPR and in particular:

1. request access to the data concerning them and the information referred to in Article 15 (purpose of processing, categories of personal data, etc.);
2. request deletion in the cases provided for in Article 17 if the Data Controller no longer has the right to process them1;
3. obtain the rectification of inaccurate data or the integration of incomplete data;
4. obtain the restriction of processing (i.e., the temporary subjecting of data to the sole operation of storage), in the cases provided for in Article 18 GDPR2;
5. object at any time, easily and free of charge, for reasons related to the particular situation, to the processing of data carried out on the basis of the legitimate interest of the owner;
6. to receive in a structured, commonly used and machine-readable format the data, as well as, if technically feasible, to transmit them to another data controller without hindrance, if the processing is based on consent or contract and is carried out by automated means has the right.

In order to exercise these rights, they may contact the Data Controller at any time by sending the request by e-mail indicated in Art. 1.
Data subjects have the right to lodge a complaint with the Privacy Guarantor or, in any case, with the competent supervisory authority in the Member State in which they usually reside or work or in the State where the alleged violation occurred.

Last updated: november 2025