Foreword

This cookie policy has been drafted in accordance with the indications contained in the guidelines of the data protection authority of June 2021, following a period of consultation, and published in July 2021, according to which, in compliance with the provisions of the EU General Data Protection Regulation 2016/679 (GDPR), no cookies, except those of a technical nature, which are to be considered necessary for the operation of the site, may be installed without the user’s prior consent. Consequently, when the user accesses the site for the first time, he/she is shown a banner generated by the cookie bot provider, which has been previously assessed as compliant, in which he/she is allowed to check how many cookies may be installed on the site and of what nature (necessary or profiling), and is asked to choose which of the unnecessary cookies he/she wishes to activate, usually by moving the cursor. For convenience the user is also allowed to make the choice between ‘Accept all’ and ‘Reject all’. As soon as the choice has been made, instead of the window for the expression of consent, which closes, a graphic sign appears in the bottom right-hand corner, upon selection of which the window for the expression of consent reopens. Cookie bot scans the cookies monthly and automatically adjusts the cookie policy.

Data controller and purpose

The C.G.M. consortium, as data controller of the users, called data subjects, informs them that the data controller itself or selected third parties (such as the data controller’s suppliers) may collect and store information about them or may use resources on their device, when the latter interacts with the site, for example in order to save their preferences and settings, to provide targeted advertisements and enable the activation of social media features, and to analyse and to improve the functioning of the site.

Definition of cookies

Cookies are small text files that the sites you visit send and store on your computer or mobile device, where they are stored for six months and then retransmitted to the same sites on subsequent visits.

It is precisely thanks to cookies that a site remembers the user’s actions and preferences (such as login data, chosen language, font size, other display settings etc.) so that they do not have to be indicated again when the user returns to the site or navigates from one page to another. Cookies are therefore used to perform computer authentication, session monitoring and storage of information relating to the browsing preferences of users accessing a site, and may also contain a unique identification code that allows tracking the user’s navigation within the site for statistical or advertising purposes. Certain operations could not be carried out without the use of (technical) cookies, which in certain cases are therefore necessary for the site to function.

In the course of browsing a site the user may also receive on his/her computer tools cookies from sites or web servers other than the one he/she is visiting (called ‘third party’ cookies, it being understood that in this case it is precluded that their use may lead to the identification of the user). Cookies, depending on their characteristics and functions, may remain on the user’s device for different periods of time: for example the session cookie is automatically deleted when the browser is closed, while the persistent cookie remains on the user’s device until a predetermined expiry date.

Under current European law, the use of cookies does not always require the express consent of the user. In particular consent is not required for “technical cookies”, i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communication network, or to the extent strictly necessary to provide a service explicitly requested by the user. In other words, these are cookies that are indispensable for the operation of the site or necessary to perform activities requested by the user.

Technical cookies, which do not require the user’s express consent for their use, include:

• analytics cookies used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site itself or by third parties in aggregate and anonymised form,
• navigation or session cookies (for authentication purposes),
• functionality cookies, which allow the user to navigate according to a set of selected criteria (e.g. language) in order to improve the service rendered.

These cookies are necessary for the proper functioning of the site and to allow the user to navigate on the site, they also make it possible to manage access operations (login) to the sites, record configuration preferences where available, and produce statistical and performance analyses, in aggregate and anonymous form.

For all other cookies that are not strictly necessary for the operation of the site, known as profiling cookies, since they are designed to create profiles of the user and are used to send advertising messages in line with the preferences expressed by the user while surfing the web, the user’s prior consent is required. If consent is given, the user may revoke it at any time via the appropriate window or via the third party web pages available through the appropriate links. These cookies are used, for example, to track the location of the advertisement and to check whether a user has already seen the advertisement, but also to follow the user as he or she browses in order to define his or her profile and present him or her with advertisements linked to personal interests and socio-demographic characteristics.