Cookie Policy

Dear Visitor (hereinafter, “You” or the “User“),

This web page is owned by the company Refine Direct S.r.l., having its registered office in Via Copernico, n. 38, Milano, VAT No. and Fiscal Code No. 09419240966, registered with the Company Register of Milan under No. 2089021 (hereinafter, “We” or the “Company”).

Our Company carries on the activity of digital advertising, delivering advertising through e-mails and/or banners.

Considered the above, we are a third party in relation to the website and/or the e-mail where you are coming from (the “Website of Origin”)

Since when you visit the Website of Origin, we install profiling cookies on your browser, we hereby aim at explaining to You what cookies are and how they are used.

Through the technology of Refine, it is possible that other cookie (so-called third-party cookies) or Mobile Advertising ID are installed and controlled by third subjects. This policy includes links to the policies published by such third parties. We hereby invite you to read such policies carefully.

If You are not familiar with cookies and Mobile Advertising ID, please read carefully this policy and the general privacy policy of the Website of Origin, in order to make your choices consciously.

The Company takes the utmost account of the right to privacy and protection of personal data of its Users. For any information related to this Cookie Policy, Users may contact the Controller at any time by sending a registered letter with return receipt.

Users may also contact the Data Protection Officer (RPD or DPO) of the Company, the contact data of which is reported below: Avv. Lapo Curini Galletti, e-mail dpo [@] refine.direct .

The Company collects and processes your personal data by means of these cookies or Mobile Advertising ID. With this information notice, we hereby explain to You how We collect such data, for which purposes and what your rights are, also pursuant to the Legislative Decree No. 196 of 30 June 2003 (the “Privacy Code”) and to Article 13 of the General Data Protection Regulation, Regulation (EU) 2016/679 (the “GDPR”).

A. What cookies are and what they are for

The cookies are small text files that the websites visited by a user send directly to its terminal (usually, to the browser), where they are memorised to be transmitted to the same websites at the following visit of the same by the same user (the so called first party cookies). During the web surfing of a website, a user may receive on its terminal also cookies of other websites or of other web servers (the so called third parties cookies); this happens because there may be elements on the visited website, such as images, maps, sounds, links to specific web pages of other domains that are on servers other than the server on which the requested page is placed. In other words, such cookies are set up on a website other than the one that is currently visited.

The cookies may have a duration limited to a single session of navigation on the browser (the so called session cookies), and, in such event, they deactivate automatically once the browser is closed by the user; or may have a predetermined duration and, in such event, they will remain memorised and active on your hard disk until the expiry date, thus continuing collecting information during different sessions of navigation on the browser (the so called permanent cookies).

The cookies are used for several purposes. Certain cookies are necessary in order to allow You to surf websites and benefit of their functionalities (the so-called technical cookies). Other cookies are used in order to obtain statistical information, whether in aggregate or not, about the number of users accessing the websites and how the websites are used (the so-called monitoring cookies or analytics). To the end, other cookies are used in order to track your consumer profile and make You viewing advertisings that may be of interest for You, since complying with your preferences and your consumer habits (the so-called profiling cookies).

The Mobile Advertising ID are technically ID on mobile applications, which may be reset by users. Refine does not have the control on a Mobile Advertising ID and will access to it until it will be changed by the mobile device or by the user.

B. The technical cookies

The technical cookies are used on the Website for the sole purpose to make You able to surf the Website and allow You to use its functionalities. They are first party cookies, since they are conveyed directly by us on the Website.

Certain technical cookies are essential to offer You an optimal surfing experience or in order to allow You to authenticate on the Website, for example in order to make a purchase on the Website or to enter into your reserved area (the so-called surfing cookies). The surfing cookies are normally session cookies and, therefore, once the surfing browser is closed, are automatically deactivated.

The technical cookies are useful in order to allow You to memorise your preferences (for example, the language or the Country) without setting up the same at the following visits (the so-called functionalities cookies). For such reason, the functionalities cookies are often lasting cookies, since they remain memorised on your computer also after the closure of the surfing browser, until the scheduled expiry date or until when you decide to eliminate the same.

The following technical cookies are actually used:

Cookie’s denomination Cookie’s category Cookie’s function
wordpress_xxxx

wp_settings-xxxx

catAccCookies

Cookie tecnico:
– di navigazione

– di funzionalità

Cookies necessari al software WordPress con cui è realizzato il sito, utilizzati per funzioni tecniche di login, preferenze nel pannello, configurazione di sezioni e interfaccia del Sito, mantenere le impostazioni dell’utente.

As provided under the privacy law actually in force, the installation of such cookies does not require your prior consent. You are clearly free of blocking the installation of technical cookies, amending the settings of your browser (read paragraph E, No. 1, to know how to make it). Please consider, however, that blocking the installation of the technical cookies, or eliminating the same thereafter, the possibility to access the Website, to benefit of the same in whole or in part, to enable or disable certain functions or to receive certain services may be compromised in whole or in part.

C. Profiling cookies

The profiling cookies or Mobile Advertising ID are used to create a user’s profile, based on the preferences and likings showed by You during the navigation on Internet and to make You display advertisings consistent with your profile. In such way, the advertisings that You will display on the Website of Origin and the other websites that host our cookies could be more of interest for You. The Company chooses also to use cookies which register your activity, for example click and/or the opining of an e-mail, and always with the aim of offering you a better service.

Your prior consent is requested in order to install such cookies or to analyse the Mobile Advertising ID, as provided pursuant the current privacy law. For such a reason, when you access the Website of Origin a specific banner is displayed, informing you that (i) profiling cookies are used on the Website of origin and that (ii) closing the banner, surfing on the home page or clicking whatever element on the home page outside the banner, You are giving your consent to the use of cookies. In some cases, the Website of Origin may ask you to give an explicit consent to the storing of these cookies, for example by requesting you to click on a specific acceptance button. For further information, please read the cookie policy of the Website of Origin.

In the event that you express your consent to the use of cookies or to the analysis the Mobile Advertising ID in this way, the publisher of the Website of Origin may track your consent by means of a specific technical cookie. In this way, the publisher of the Website or Origin will avoid you displaying the cookies banner during your following visits of the Website of Origin. Please take into account that, in the event that you remove from your browser such technical cookie with the modalities set forth under the following paragraph D, No. 1), the track of your consent would be lost and, therefore, the cookies banner will be displayed again during your following visit to the Website of Origin.

You are clearly free to block the installation of profiling cookies in any moment whatsoever and this will not compromise in any manner whatsoever the possibility to visit the Website of Origin and benefit of its contents.

Our profiling cookies are installed directly by the Company when you visit the Website of Origin. Such cookies are lasting ones and have a maximum duration of 12 months. The first party profiling cookies used are them specified in the following table, together with the indication of the modalities to use in order to oppose to their installation:

Cookie’s denomination Cookie’s category
rd – cookie di profilazione di prima parte

–  permanente

For disabling such profiling cookies please amend your browser’s settings (please see paragraph D, No. 1) or use the following procedures:

Insert your e-mail address:

When you press the button OptOut you will receive an e-mail to the e-mail address you indicated which contains a link in order to confirm the OptOut. Once opened the link, the OptOut is confirmed.

The automated disabling method will be implemented soon; in the meantime, you may check the paragraph D in order to understand how to remove cookies.

Using the interactive button to block our profiling cookies, You will receive in any case a technical cookie in order to memorise your preference. Please consider that, removing all the cookies from the browser, also this technical cookie could be removed and, therefore, you would have to express again your choice to block such cookies using the procedure indicated in this privacy notice.

The following profiling cookies are installed by third parties, which act as autonomous data controllers (third parties cookies). The third parties profiling cookies used on the Website are the specified in the following table, together with the link to the policies created by their developer:

Cookie of Cookie’s name Cookie’s category Link to the policy
Adform Adform – cookie di profilazione di terza parte

–  permanente

http://site.adform.com/privacy-policy/en/
Google reCAPTCHA PREF, NID, HSID, APISID, SID – cookie di profilazione di terza parte

–  permanente

https://policies.google.com/privacy

Third party profiling cookies

The greater part of the profiling cookies is installed by third parties that act as autonomous data controllers (third parties cookies). The third parties profiling cookies used on the Website are the specified in the following table, together with the link to the policies created by their developer:

Cookie’s name Cookie’s category Link to the policy
Adform – cookie di profilazione di terza parte

–  permanente

http://site.adform.com/privacy-policy/en/
Appnexus – cookie di profilazione di terza parte

–  permanente

https://www.appnexus.com/platform-privacy-policy
Google – cookie di profilazione di terza parte

–  permanente

https://policies.google.com/technologies/types
Adobe – cookie di profilazione di terza parte

–  permanente

https://www.adobe.com/it/privacy/cookies.html
Facebook – cookie di profilazione di terza parte

–  permanente

https://www.facebook.com/about/privacy/
MediaMath – cookie di profilazione di terza parte

–  permanente

http://www.mediamath.com/cookie-notice/
The Trade Desk – cookie di profilazione di terza parte

–  permanente

https://www.thetradedesk.com/general/privacy
Active Agent – cookie di profilazione di terza parte

–  permanente

http://www.active-agent.com/de/unternehmen/datenschutzerklaerung/
Amazon – cookie di profilazione di terza parte

–  permanente

https://www.amazon.com/gp/help/customer/display.html/ref=a20m_us_fnav_prvcy?ie=UTF8&nodeId=468496
PubMatic – cookie di profilazione di terza parte

–  permanente

https://pubmatic.com/legal/privacy-policy/
Rubicon – cookie di profilazione di terza parte

–  permanente

https://rubiconproject.com/privacy/
LiveRamp – cookie di profilazione di terza parte

–  permanente

https://liveramp.com/privacy/

D. How to manage the cookies and oppose to their use

There are several options to manage, disable and remove the cookies.

(1) Modify your browser settings

Please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies (technical, analytics and profiling):

(2) Use our interactive instruments

In order to disable the first part profiling cookies, which means those installed directly by us, you can simply use the interactive button that is displayed under Paragraph C of this privacy notice.

In order to disable the third parties cookies, please see the privacy policies of those third parties installing profiling cookies (see paragraph C above) in order to know the other instruments available to you for managing, disabling and removing cookies and, more in general, to oppose to their use. Please be reminded that, by disabling third parties cookies, (i) you are opposing to their use not only on the Website of Origin, but on all the Internet websites on which such cookies are used and (ii) the possibility to surf on the Website of Origin and use its functionalities will not be jeopardised in any manner whatsoever. When you disable the third parties cookies, you will however display the banner on the cookies on the Websites’ home page; but, in such event, closing the banner and surfing the home page or clicking an element whatsoever outside the banner, you will not receive any third party cookie you have duly disabled.

(3) Mobile Advertising ID

In order to opt-out, on the majority of the devices such as iPhone, iPad or Android devices, we suggest you refer to the device’s setting and to the instructions given by the manufacturer. Below we will give you illustrative information exclusively to provide you general information, for which we decline whatsoever responsibility or guarantees on the functioning and update.

  • Apple iOS

Open device’s setting, then go to the section “Privacy” -> “Location Services” -> “System Services” and modify the option “Location-Based iAds” selecting “off”.
Open device’s setting, then go to the section “Privacy”  “Advertising” and modify the option “Limit Ad Tracking” selecting “on”.
In order to reset your Advertising ID on iOS, open device’s setting, then go to the section “Privacy” -> “Advertising” and select “Reset Advertising Identifier”.

  • Android

Open Google’s setting and select Ads. Then select “Reset advertising ID” and choice “Opt out of interest-based ads”.

E. Processing methods and data retention timing

As highlighted under the preamble of this Cookie Policy, the Company collect and process certain personal data by means of the cookies. The Company acts as data controller of such data, in compliance with the provisions of the GDPR. Please note that we will process your data with electronic instruments only, in a much automatized manner and without any human intermediation. Therefore, our employees and co-workers will never access the content of your personal data obtained by means of cookies, meaning that they will never be able to see and/or have any direct Personally Identifiable Information (PII), that is information from which it will be possible to identify you directly.
Certain employees of ours and coworkers, appointed by us as persons in charge of the processor, could make maintenance operations on IT systems that host your data, without the possibility to access their actual contents. The personal data could be memorised on servers managed by third parties (for example, providers of IT systems) or may be managed by online marketing specialised subjects, acting as external data processors on the basis of a specific written appointment by the Company. We hereby inform you that, complying with the requirements and the guarantees provided under the law, your data could be transferred to Countries outside the European Economic Union that could not guarantee a level of privacy and personal data protection equal to the level of protection guaranteed by the Italian and European privacy laws, but as Controller we take the utmost account of the right to security and protection of personal data of our Users, therefore we will process such transfers with all due care and guarantees. Your personal data will not be transferred to third parties, nor will be disseminated.

F. Your rights

In order to exercise your rights, or to obtain any other information or clarification in relation to this Cookie Policy, please contact the Company by means of:
• registered letter with return receipt to the registered offices of the Company;
• by sending a certified e-mail (PEC);
• using the contact form available clicking here

Pursuant to the Regulation, the Company informs that Users have the right to obtain indication:
(i) of the origin of personal data;
(ii) the purposes and methods of the processing;
(iii) the logic applied in the event of processing carried out with the aid of electronic instruments;
(iv) of the identification details of the Controllers and Processors;
(v) the subjects or categories of subjects to whom the personal data may be communicated or who may come to know them as Processors.

Furthermore, Users have the right to obtain:
a) access, updating, rectification or, when interested, integration of data;

b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right.

Furthermore, Users have:

a) the right to withdraw consent at any time, if the processing is based on their consent;

b) (and, if its is applicable) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by automatic device), the right to limit the processing of personal data and the right to cancel (“right to be forgotten”);

c) the right to oppose:
i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
iii) qualora i dati personali siano trattati per finalità di marketing diretto, in qualsiasi momento, al trattamento dei Suoi dati effettuato per tale finalità, compresa la profilazione nella misura in cui sia connessa a tale marketing diretto;

d) if they believe that the processing that concerns them violates any Privacy Laws, the right to lodge a complaint with a Supervisory Authority (if a European citizen, in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred). The Italian Supervisory Authority is the Garante per la protezione dei dati personali, located in Piazza Venezia, n. 11, 00187 – Rome (RM) (http://www.garanteprivacy.it/).

***

The Controller is not responsible for updating all links that can be viewed in this Cookie Policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to such link.