Cookie Policy

1. What are cookies and tracking tools

Cookies are text strings (or similar identifiers) that “first-party” sites or “third-party” entities store on the user’s device for technical, statistical, or tracking/profiling purposes. DB

2. Applicable regulatory framework (updated to 2025)

• Art. 122 of the Italian Privacy Code (implementation of the ePrivacy directive) Normattiva

• GDPR (consent, transparency, accountability, privacy by design/default) DB

• Cookie guidelines of the Garante (Provv. 231/2021 – G.U. 09/07/2021) DB+2DB+2

• EDPB Guidelines on consent (no implied consent, requirements of freedom and unambiguity) EDPB +1
  Note 2025: the proposed ePrivacy Regulation (2017) has been withdrawn; the current ePrivacy framework remains applicable (directive and national implementing laws). EUR-Lex+2European Parliament+2

3. Types of cookies used on this Site

The Site may use:

English Translation:
A) Technical (necessary) cookies
They are used to “carry out the transmission” or to provide a service requested by the user; they do not require consent, but must be indicated in the privacy notice. DB
https://www.dirittobancario.it/wp-content/uploads/sites/default/files/allegati/gazzetta_ufficiale_09_luglio_2021_n._163._delibera_garante_privacy_10_giugno_2021..pdf

B) Analytics cookies

• They can be assimilated to technical cookies only if they meet minimization conditions (aggregate statistics, single site/app, IP masking for third parties, prohibition of combination/further transmission according to applicable settings). DB

• In other cases, they require consent.

C) Profiling / marketing cookies and other non-technical identifiers
Used to track behaviour and deliver targeted advertising; they require prior consent. DB +1

4. Cookie banner: minimum configuration (when non-technical cookies are present)

If the Site uses non-technical cookies, an “immediate pop-up” banner is shown on first access with:

• short information (technical +, prior consent, profiling/tracking and purposes)

• link to the full privacy/cookie policy

• warning that closing (X) maintains default settings (technical only)

• commands: close (X) without consent, accept all, and access to an area for granular choice + possibility of subsequent modification (e.g., link in the footer). DB+1

(Good operational practice: also include “Reject all” at the first level, consistent with free and unconditioned choice.) EDPB+1

5. Re-presentation of the banner and duration of choices

English translation:
The banner must not be shown again in an intrusive manner after a refusal, except in specific cases (e.g. …). English translation:
changes in the processing conditions; technical impossibility of knowing whether a cookie has already been stored; or at least 6 months have elapsed since the previous display).
DB

6. Scrolling and cookie wall

• Scrolling: by itself not suitable for collecting consent, unless it is part of a more articulated process with a positive unequivocal action that can be recorded and documented. DB+1

• Cookie wall (“take it or leave it”): generally unlawful, except for particular cases to be evaluated (equivalent alternative access without consent). DB+1

7. How to manage or revoke consent

You can at any time:

• modify preferences via ⟦link “Review cookie preferences” (footer)⟧

• delete cookies from the browser (see Section 9).
  Consents must be recorded and demonstrable (accountability). DB

8. Cookie list (to be completed)

Fill in this table with the actual cookies (you can export them from CMP or cookie scanner).

9. Cookie management via browser (standard text)

You can also manage cookies from the browser settings (block/delete existing cookies). Procedures vary by browser and version.

10. Third parties (to be completed)

If you use third-party services, indicate here:

• ⟦Google Analytics / GA4⟧ – ⟦third-party information link⟧

• ⟦Meta Pixel⟧ – ⟦link⟧

• ⟦YouTube/Vimeo embeds⟧ – ⟦link⟧

• ⟦Google Ads / TikTok / etc.⟧ – ⟦link⟧

(Only include what is actually active on the Site.)

11. Contacts

For privacy and cookie inquiries: ⟦privacy@domain.com⟧.