Extended information on the use of cookies

Pursuant to Articles 6 and 7 of the EU Regulation 2016/679, as well as in accordance with the Measure no. 229 of May 8, 2014 and by the Guidelines cookies and other tracking tools of June 10, 2021 (published in the Official Gazette No. 163 of July 9, 2021) issued by the Italian Data Protection Authority, on this page the Data Controller, Enginius S.r.l. (hereinafter, “Company,” “Organization,” or “Owner”), with registered office in Largo Oratorio, 13 – 15076 Ovada (AL) and operational headquarters in Via Scarsellini 119, Torre B – 16149 Genoa, Italy, e-mail: info@enginius.com, provides users of the website https://www.enginius.com/ with information regarding the cookies used and/or proposed for storage.

This extended information on the use of cookies (hereinafter referred to as “cookie policy”) must be transposed by taking care to have read, in a separate document, the privacy policy ex art. 13 European Union Regulation 2016/679 on the protection of personal data (GDPR), which can be consulted in the appropriate section https://enginius.com/privacy-policy/ present on the website https://www.enginius.com/, in the footer of the home page.

The purpose of said cookie policy is to describe the elements required by law, as well as the characteristics and purposes of the cookies installed by the website https://www.enginius.com/ include the updated link to the disclosures and consent forms of the third parties with which the Owner has entered into agreements for the installation of cookies through its site and finally recall the possibility for the user to manifest his or her options on cookies also through the settings of the browser used.

What are cookies

Recital 30 GDPR states that “Natural persons may be associated with online identifiers produced by the devices, applications, tools, and protocols used, such as IP addresses, temporary markers (cookies), or other identifiers such as tags Radio frequency identification. Such identifiers can leave traces that, particularly when combined with unique identifiers and other information received by servers, can be used to create profiles of individuals and identify them“.

Cookies are text files that sites visited by users send to their devices. These files are stored within them to be retransmitted, at a later time, to the same source sites on a subsequent visit (so-called user tracking). Cookies can be deposited within the user’s device either directly from the website the user is visiting(first-party site) or from a different website(third-party site), since within each website there may be elements (images, maps, sounds, specific links to web pages in other domains, etc.) that may reside and/or take the user to links located on servers different from those delivering the first-party site. By storing cookies, the user can personalize the enjoyment of some website content by saving their own preferred settings. This makes it possible to associate specific online behaviors with the user and thus classify them (profiling). For example, it is possible to set up a cookie for recognition of the user registered on the site without the user having to proceed, on the occasion of a new visit, to a new authentication(login).

Cookies are pseudonymous data, that is, personal data where identifying elements have been replaced by other elements (such as text strings and numbers). By cross-referencing this data with other information, it is possible to arrive at the identification of the person, or rather the unique identification of the device used for online access and navigation.

Taxonomy proposed by the Guarantor

In Measure no. 229 of May 8, 2014 and in the Guidelines of June 10, 2021, the Data Protection Authority proposes a taxonomy that identifies two categories of cookiesbased on two possible processing purposes:

1. Technical Cookies
2. Profiling cookies

Technical Cookies

They serve to perform navigation and/or provide a service to the user. They are not used for any further purposes and are normally installed directly by the Website Owner. Without the use of such cookies, some operations could not be carried out or would be more complex and less secure, such as home-banking activities (viewing account statements, bank transfers, bill payments, etc.), for which cookies, which allow the user’s identification to be made and maintained within the session, are indispensable. For these reasons, these cookies do not require the acquisition of consent.

Profiling cookies

They are used to track the user’s web browsing and create profiles on tastes, habits, choices, etc. With these cookies, advertising messages can be delivered to the user device in line with the preferences already expressed by the same user when browsing online.

User consent for the installation of cookies on the device

The expression of consent to the storage of cookies depends on the purposes for which the cookies are used and whether they fall under“ technicalcookies ” or” profilingcookies .” For the installation of technical cookies , no consent is required from users while, in the case of third-party cookies it is necessary, among other things, to provide appropriate information(ex art. 12 and 13 GDPR). Regarding, on the other hand, only profiling cookies, the same can be installed on the user’s device only if the user has expressed his or her free, voluntary, specific and unequivocal consent after being adequately informed.

Moreover, with the new Guidelines, it has been established that the mechanism for acquiring consent online must first and foremost ensure that, by default, when a website is first accessed, no cookies or other tools other than technical ones are placed within the user’s device, nor is any other active (e.g., third-party cookies ) or passive (e.g., fingerprinting) tracking technique used.

For profiling cookies there is the need for consent to be requested through a distinguishable banner on the web page, through which users are offered the option to continue browsing without being tracked in any way, such as by closing the banner by clicking on the characteristic X to be inserted in the upper right corner.

Analytical Cookies

The Garante clarified that these cookies can be assimilated to technicalcookies, in terms of information and consent, only if:

• They are used only to produce aggregate statistics and in relation to a single site or mobile application;
• It is masked, for third-party ones, at least the fourth component of the IP address;
• Third parties refrain from combining analytics cookies, thus minimized, with other processing (customer files or statistics of visits to other sites, for example) or passing them on to further third parties. However, it is permissible for third parties to produce statistics with data from multiple domains, websites, or apps attributable to the same publisher or business group.

As they are similar to technical cookies, analytics cookies can also be used in the absence of the prior acquisition of the consent of the data subject.

Cookies installed on this site

Interaction with online survey platforms

Hotjar Poll & Survey widgets (Hotjar Ltd.)

Interaction with social networks and external platforms

Linkedin social button and widgets (LinkedIn Corporation)

Twitter Tweet button and social widgets (Twitter, Inc.).

Facebook’s Like button and social widgets (Facebook, Inc.).

Viewing content from external platforms

YouTube Video Widget (Google Ireland Limited)

Google Maps Widget (Google Ireland Limited)

Heat mapping and session recording

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Anonymized statistics services

Google Analytics with anonymized IP (Google Ireland Limited)

Statistics

Google Tag Manager

Google Analytics Data Monitoring 4

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.).

Google Ads Conversion Monitoring (Google Ireland Limited)

Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

Advertisement

Facebook Audience Network (Facebook, Inc.)

Google Ads Similar Audience Segments (Google Ireland Limited)

Remarketing and behavioral targeting

Facebook Remarketing (Facebook, Inc.)

Facebook Custom Audiences (Facebook, Inc.).

Remarketing with Google Analytics (Google Ireland Limited)