Cookie Policy

This document has been drawn up by Nctm Studio Legale, with registered office in via Agnello 12, Milan (hereinafter, “Nctm” or the “Controller”), as data controller for the processing of personal data, pursuant to Article 13 of Regulation (EU) 2016/679, collected during the navigation of the website www.nctm.it (hereinafter, the “Site”).

The information below complies with the provision issued by the Italian Data Protection Authority on 8 May 2014, containing Simplified procedures for the information and to gain consent to use cookies (hereinafter, the “Cookies Provision”). Nctm wishes to inform users that its Site uses cookies in order to improve their navigation experience.

 

Data Controller

The Data Controller is Nctm Studio Legale, with registered office in Via Agnello 12, 20121 Milan, tel. +39 02 725 511, e-mail info@nctm.it. The updated list of any data processors is available at the Controller’s offices.

 

What are Cookies?

Cookies are small text files used to compile statistics concerning the use of the Site, to understand navigation experiences and the visitors’ possible requirements. Data collected through cookies are used to improve the navigation experience and the Site performance in the future.

Cookies can be divided into two categories:

  • first-party cookies”, set directly by the domain and/or editor of the website visited by the user; and/or
  • “third-party cookies”, set by a domain other than the one of the website being visited by the user.

Cookies may be further divided based on the purposes for which they are used: some of them offer an improved navigation experience, remembering visitors’ choices regarding specific settings (the so-called “technical cookies”) and hence ensure enhanced functionalities, while others allow to monitor the user’s navigation also in order to send advertisements and/or to offer services in line with the user’s preferences (“profiling cookies”).

 

a) First-party cookies

This Site uses technical cookies, and in particular:

  1. Navigation or session cookies: which are required for normal browsing within the Site and to properly use the relevant services. They are not stored in the user’s computer and expire when the browser session is closed;
  2. Functional cookies: which are solely used to improve and speed up the browsing of the Site, by remembering certain user’s choices (such as language preferences);

These types of cookies ensure the normal navigation and use of the Site, and allow to properly enjoy the contents published by Nctm or to log in to access reserved areas. Such cookies also allow to collect aggregate information on number of users and how they visit the Site, as well as information relating to the language selected during navigation.

Cookies do not collect personal information on visitors, and personally identifiable data, if any, will not be stored. Users may refuse the use of cookies. However it should be noted that by totally disabling browser cookies, the user may not be able to use all interactive functions offered by the browser.

With regard to these cookies, the Cookies Provision imposes an opt-out regime. Users have the right to be informed, by means of this information notice prepared by the Controller, and may as well decide to refuse their consent to the use of such instruments.

 

b) Third-party cookies

When a user is navigating some cookies that are not directly controlled by the Controller may be stored on his/her device, for example when the user visits a page including contents of a third party website. Moreover, the Site uses third-party profiling cookies. With regard to these cookies, the user’s consent  will be deemed to have ben given every time the user clicks the “Accept” button present in the banner appearing in the homepage. In any case, users may subsequently withdraw their consent to the installation of said cookies.

Said cookies, the so-called “third party cookies”, may be divided into:

  • Analytical cookies, used to collect and analyse statistical information on the number of users and on the visits to the Site. The disabling of such third party cookies does not affect the use of the Site;
  • Widgets/Plugin: some widgets and plugin made available by social networks (such as, by way of example only and without limitation, LinkedIn button or the display of YouTube videos directly within the websites where the user is navigating) may use their own cookies to facilitate the interaction with the reference site. Their disabling does not affect the use of the Site, unless for the possibility of quick sharing of contents and/or of displaying multimedia contents present therein;
  • Profiling cookies: used to collect information concerning preferences and habits expressed by the user during the navigation and hence to make advertisements published by third parties more captivating and focused.

This Site uses Google Analytics, a web analysis service provided by Google, Inc. (hereinafter, “Google”). Google Analytics uses cookies, which are text files placed on the devices used by users in order to analyse how they use the Site. Anonymous and aggregate information generated by the cookie on how users use the Site will be transmitted to and stored in Google servers in the United States.

Google will use such information for the purpose to track and examine the use of the Site, to compile reports on the Site activities for Site managers and to provide other services relating to the activities of the Site and to Internet use.

In order to understand how Google cookies actually work, as well as to be able to refuse one’s consent to the use of such files, reference should be made to relevant information drawn up in such respect by Google, which can be found at the following link http://www.google.com/intl/it_ALL/analytics/learn/privacy.html.

 

Giving consent

In line with the provisions of the legislation in force, when first accessing the Site (homepage or any other page thereof), Nctm will ask for the user’s consent, pursuant to Article 4, paragraph 1, of the GDPR,  to send the cookies indicated above as follows:

  • clicking the “Accept” button or the “X” closing button in the banner that will be displayed;
  • clicking on any other element of the Site web page, even using the scroll, outside said banner;
  • accessing at any time, both on the occasion of the first visit to the Site or afterward via the specific link provided by the Data Controller, this extended information notice (“Cookies Policy”) and disabling the use of Cookies.

In all other cases and on any subsequent visit to the Site, the user may access this information (by clicking the “Cookies Policy” link at the bottom of the Site homepage) and refuse the consent to the installation of cookies in the ways described above. We repeat that the user’s consent is only necessary for the installation of third-party cookies.

 

Limiting or disabling the use of Third-party Cookies

The Site uses Cookibot, to allow users to manage cookie preferences, as well as to amend and/or remove any third-party profiling and analytical cookies.

 

Rights of access, to erasure, to restriction and to data portability

Data subjects have the rights under Articles 15 to 20 of the GDPR. By way of example, every data subject will have the right :

a) to obtain confirmation as to whether or not Data concerning him or her are being processed;
b) where Data are being processed, to obtain access to the Data and to the information relating to the processing as well as to request a copy of the Data;
c) to obtain the rectification of inaccurate Data and to have incomplete Data completed;
d) where any of the conditions provided for by Article 17 of the GDPR exists, to obtain the erasure of the Data concerning him or her;
e) in the cases provided for by Article 18 of the GDPR, to obtain restriction of processing;
f) to receive the Data concerning him or her in a structured, commonly used and machine-readable format, and to transmit it to another controller, if technically feasible.

 

Right to object

Every data subject has the right to object at any time to the processing of Data concerning him or her carried out for the purposes of the legitimate interests pursued by the controllers. In case of objection, the controller shall no longer process his or her Data unless the controller demonstrates legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

 

Right to withdraw consent

If the consent is necessary for the processing of the Data, every data subject shall also have the right to withdraw his or her consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. The consent may be withdrawn by writing an email to the address: info@nctm.it.

 

Right to lodge a complaint with the Supervisory Authority

Moreover, every data subject has the right to lodge a complaint with the Data Protection Supervisor if the data subject considers that his or her rights under the GDPR are infringed, according to the methods indicated on the Data Protection Supervisor website at the address: www.garanteprivacy.it.

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