Cookie policy - Giunti Psychometrics - Corporate international

Extended policy on the use of cookies

Simplified arrangements to provide information and obtain consent regarding cookies – 8 May 2014 – (published in the Official Journal no. 126 of 3 June 2014) Register of Measures no. 229.

Privacy policy for the operation of cookies – Article 13 of Legislative Decree 196/03 and Article 14 of EU Regulation 679/16

Below we shall inform you, in a transparent manner, on the operation of so-called cookies on this Website (hereinafter referred to as the “Website”).

Definition of “cookies”

Cookies are small text files sent by the Website to the user’s terminal (usually to the web browser), in which specific information is stored so it can be re-transmitted to the Website the next time the same user visits it. A cookie cannot retrieve any other data from the user’s hard drive nor transmit computer viruses or acquire email addresses. Each cookie is unique to the user’s web browser. Some cookie functions can be delegated to other technologies. The term “cookie” or “cookies” shall refer to cookies and all similar technologies.

Purpose of the data processing and purpose of technical session cookies

The cookies used on the Website are used for IT authentication or session monitoring purposes and to store specific technical information concerning users who access Giunti Psychometrics’. servers. It may not be possible to carry out certain operations on the Website without the use of the cookies, which in such cases are therefore technically necessary. For example, access to restricted areas of the Website and the activities that can be carried out in such areas would be much more complex and less secure without the presence of cookies that make it possible to identify the user and maintain their identification during the current session. Pursuant to Article 122, paragraph 1 of the Privacy Code (in the current version following the entry into force of Legislative Decree no. 69/2012) “technical” cookies can be used even in the absence of the user’s consent. Giunti Psychometrics S.r.l. therefore gives notice that the Website uses technical cookies that are necessary to navigate it, which facilitate the use of essential functions such as authentication, validation, management of browsing sessions and fraud prevention. Such cookies, for example, make it possible to: identify whether the user has had regular access to the areas of the Website requiring prior authentication, facilitate user validation and management of sessions relating to the various services and applications available, enable data retention for secure access and provide fraud control and prevention functions. For maximum transparency, a series of technical cookies and specific operational cases applicable to the Website are listed below: • cookies stored on the user’s / contractor’s terminal directly (which shall not be used for other purposes) such as session cookies used to “fill the cart” as part of online reservations made on the Website, authentication cookies, cookies relating to multimedia content such as flash players that do not exceed the duration of the session, customisation cookies (for example, for selecting the navigation language, ID and password retrievals completed after the user types the first characters, etc); • cookies used to statistically analyse access / visits to the Website (so-called “analytics” cookies) used exclusively for statistical purposes (and not for profiling or marketing purposes) and which collect information in aggregate form, without the ability to identify the individual user. In such cases, since the current legislation in force stipulates that for analytics cookies the interested party shall be provided with clear and adequate information on simple ways to oppose their use / installation (opt-out), including any mechanisms of anonymisation of the same cookies, we hereby specify that it is possible to disable Google analytics cookies as follows: open your web browser, select the settings menu, click on Internet options, open the privacy tab and select the desired cookie blocking level. If you wish to delete cookies that have already been stored in memory, open the Security tab and delete the browser history by selecting “Delete cookies”.

Purpose of the data processing and the use of cookie for marketing analysis

In addition to technical cookies, we hereby inform you that Giunti Psychometrics S.r.l., also uses other types of cookies on this Website (deriving from specific services provided by companies operating in the sector), not classified as “technical” and which focus on the analysis of behaviour for marketing purposes. Below, for each cookie operating on our Website, information is provided on the type of cookies used through third-party services, the relative purposes, retention period as well as the third parties who retain the information and access it.

Third parties who retain and access user information collected using cookies

Link to the Websites where the relative Privacy Policy is published: – Google Inc, for statistical analysis and reporting purposes. – Facebook Inc, for profiling purposes. Personal data collected using cookies can be processed, automatically or using IT systems, for the following purposes specified below, as required by the General Provision of the Authority for the Protection of Personal Data laying down the guidelines to combat spam: commercial promotion, advertising, solicitation of purchase behaviour, market research, surveys (by phone, online or using paper forms), statistical processing (in identifying form), and for marketing purposes in a broad sense (including with respect to prizes, games and competitions or other reward initiatives not covered by the provisions referred to in the Decree of the President of the Republic no. 430/2001) of products and/or services related to Giunti Psychometrics S.r.l., hereinafter collectively referred to as “Data Processing for Marketing Purposes”). By providing their consent to the use of cookies and to the related Data Processing for Marketing Purposes, the data subject / interested party specifically takes note of such promotional, commercial and marketing purposes, in a broad data processing sense (including the consequent management and administrative activities) and expressly authorises the aforementioned processing pursuant to Article 23 and Article 130 of the Privacy Code (as the Company may use means for the processing of personal data for marketing purposes, such as email, fax, sms, mms, automatic systems without operator intervention and similar, including electronic platforms and other telematic means). Pursuant to the General Provision of the Authority for the Protection of Personal Data “Consent to the processing of personal data for “direct marketing” purposes using traditional and automated contact tools”, the data subjects should specifically note that: 1. The eventual consent for the Company to send data subjects commercial and promotional communications, on the basis of Article 130, paragraphs 1 and 2 of the Privacy Code and of Article 22 of EU Regulation 679/16 (i.e. through the use of email, fax, sms, mms, automatic systems without operator intervention and similar, including electronic platforms and other telematic means) shall involve the receipt of such communications, not only through these automated contact methods, but also through traditional methods such as paper mail or calls made by an operator; 2. The data subject’s right to object to the processing of his/her personal data for “direct marketing” purposes through the aforementioned automated contact methods, shall in any case extend to the traditional ones and, even in this case, the data subject shall be entitled to exercise this right in part, as provided for in Article 7 , paragraph 4 and Article 21 of EU Regulation 679/16, both with respect to certain means used as well as to certain types of data processing; 3. The data subject who does not intend to provide his/her consent as per the terms described above, shall be entitled to express their wish to receive communications for the aforementioned marketing purposes exclusively through traditional contact methods, where provided for: this right can be exercised free of charge by sending a simple email to privacy@giuntipsy.com and/or to the Data Protection Officer, Avv. Victoria Parise privacy@giuntipsy.com. For the purposes of the principle of fulfilment of privacy obligations by the data controller, in compliance with the principles of simplification of the same obligations (Article 2 of the Privacy Code) and pursuant to the General Provision of the Authority for the Protection of Personal Data entitled “Consent to the processing of personal data for “direct marketing” purposes using traditional and automated contact tools”, we hereby inform you that the specific consent formula shall be unitary and comprehensive and shall refer to all possible data processing means for marketing purposes, pursuant to Articles 23 and 130 of the Privacy Code and Article 7 of EU Regulation 679/16, without prejudice to the possibility for the data subject to notify the Company, by sending an email to privacy@giuntipsy.com, of a different intention regarding the use of certain means and not of others to receive marketing communications, subject to prior consent. Moreover, also for the purposes of the principle of fulfilment of privacy obligations by the data controller, in compliance with the principles of simplification of the same obligations, we also inform you that the specific consent formula shall be unitary and comprehensive and shall refer to all possible data processing means for marketing purposes explained here (without this multiplying the consent formulas for each distinct marketing purpose pursued by the data controller), without prejudice to the possibility for the data subject to also subsequently notify the Company of the desire to pursue a different selection regarding their consent or refusal of consent for individual marketing purposes. To proceed with Data Processing for Marketing Purposes it is mandatory to acquire a specific, separate, expressed, documented, preventive, informed, free and completely optional consent from the data subject. Consequently, where the data subject decides to give such consent, he/she must be informed and aware that the purposes of the data processing pursued are of a specific commercial, advertising, promotional and marketing nature, broadly speaking. In the interest of complete transparency, we thereby inform you that your personal data shall be collected and subsequently processed based on the specific provisions of consent: 1. to send data subjects who have given their informed consent advertising and informative materials (e.g. Newsletters), of a promotional or otherwise of a commercial nature, pursuant to Articles 23 and 130 of the Privacy Code and Article 7 of EU Regulation 679/16; 2. to carry out direct sales or placement activities of the products or services offered by the Company; 3. to send commercial information and interactive sales communications, also pursuant to Article 58 of Legislative Decree 206/2005 via email; 4. to carry out studies, research and market statistics; 5. to send unsolicited commercial communications in accordance with Article 9 of Legislative Decree no. 70 of 9 April 2003, for the implementation of the so-called Directive on Electronic Commerce 2000/31/CEE and subsequent amendments, which provides that unsolicited commercial communications must be immediately and unequivocally identifiable as such and indicating that the recipient of the message can object to receiving such communications in the future. With reference to receiving the company newsletter by email, to which you have given your consent, we also inform you that the electronic content of such promotional communications may be assisted by software (such as cookies or web beacons) designed to provide the Company with a series of parameters including: the date/time the Newsletter was opened, the Newsletter pages viewed, the links clicked within the Newsletter, links to the Company’s websites directly from the Newsletter. These parameters, which shall not constitute profiling of the recipient, are intended to provide the Company with certain statistics concerning reservations for services generated from different sources. Thus, by granting their optional consent, the data subject specifically takes note of and authorises these additional and possible secondary types of data processing. Where the data subject has given his/her consent to authorise Giunti Psychometrics S.r.l. to pursue all the different data processing purposes referred to in points 1 to 5 above, he/she shall nonetheless remain free to withdraw their consent, at any time, by sending without any formalities a clear communication to that effect to the Company at privacy@giuntipsy.com and/or to the Data Protection Officer, Avv. Victoria Parise privacy@giuntipsy.com. Following the receipt of such opt-out request, the Company shall promptly proceed to the removal and deletion of data from the databases used for Data Processing for Marketing Purposes and shall inform any third parties to whom the data has been communicated to do the same. The mere receipt of the opt-out request shall automatically serve as confirmation of the completion of the same.

Communication and dissemination of personal data collected using cookies within the scope of Data Processing for Marketing Purposes

For the same purposes referred to in points 1 to 5 of the previous paragraph, Giunti Psychometrics S.r.l. informs that the data may also be communicated to third commercial partners (Third Parties). Consent to Data Processing for Marketing Purposes by the Company in a capacity of Data Controller, where provided by the interested party, does not cover the different and further data processing for marketing purposes represented by the communication to third parties of the data for the same purposes. To proceed with this external communication the Company shall acquire from the data subject an additional informed consent, separate, ulterior, documented, expressed and entirely optional in nature. As indeed clarified in the General Provision of the Authority for the Protection of Personal Data laying down the guidelines to combat spam: 1. in relation to the disclosure to third parties for marketing purposes in general, the communication or transfer of personal data to third parties for marketing purposes cannot be based on the acquisition of a single and general consent by the interested parties for such purposes; 2. a Data Controller who intends to collect personal data of data subjects in order to also communicate (or transfer) such data to third parties for their promotional purposes. Must first issue to them an appropriate Privacy Policy that also identifies each of the third parties or, alternatively, indicate the categories (goods or product related) to which they belong; 3. the Data Controller must acquire a specific consent for the communication (and/or transfer) of personal data to third parties for promotional purposes; such consent must also be distinct from that requested by the same Data Controller to carry out the promotional activity in question; 4. where the data subject provides the aforementioned consent for communication of their personal data to third parties, these shall be able to carry out promotional activities in relation thereto, using the automated methods referred to in Article 130, paragraphs 1 and 2 of the Privacy Code and Article 22 of EU Regulation 679/16, without having to acquire a new consent for the promotional purpose. Pursuant to the General Provision of the Authority for the Protection of Personal Data laying down the guidelines to combat spam, third party recipients of data subjects’ personal data for the subsequent Data Processing for Marketing Purposes can be identified with reference to the following goods or products categories: publishing, providers and suppliers of electronic communications services, Internet service providers, advertising agencies, companies providing insurance and financial services, companies operating in the food and catering, clothing, ICT hardware and software sectors, banks and credit institutions, travel agencies, companies offering services in the tourism sector, companies offering personal goods and services, including healthcare goods and services, suppliers of goods and services in the electricity and gas sector. Your personal data shall be disclosed.

Mandatory or optional nature of consent for the operation of cookies used for marketing purposes

Method for the provision of consent. Particular attention is drawn to the fact that the provision of consent to the use of cookies that pursue marketing purposes, as well as the related and subsequent Data Processing for Marketing Purposes and the distinct consent for the communication of personal data collected using cookies to third parties for Processing for Marketing Purposes, for the purposes and based on the methods described above, are completely optional (and subsequently revocable without any formalities); moreover, failure to provide such consent shall not determine consequences other than the impossibility for Giunti Psychometrics S.r.l. and for any third party to proceed with the above mentioned data processing for marketing purposes. In case of refusal of marketing consent, there shall be no interference and/or consequence to the ability to access the Website. Giunti Psychometrics S.r.l. uses third party services (as mentioned above). Alternatively, the user can set their preferences regarding the use of cookies using their web browser settings. By modifying web browser settings, it is possible to accept or decline cookies or to receive a warning before accepting a cookie from the website being visited. Cookies can also be removed by deleting the contents of the “cookies” folder used by the web browser. Each browser has different procedures for managing cookies. Specific instructions for the most commonly used browsers are provided below:
Internet Explorer: http://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-11
Google Chrome: https://support.google.com/accounts/answer/61416?hl=it
Apple Safari: http://support.apple.com/kb/HT1677?viewlocale=it_IT
Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
Disabling Flash cookies: https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager02.html
Please also remember that by disabling cookies in the web browser, the user may not be able to use all the interactive features available on a Website.

Third party cookies

During the navigation of the Website, the user can also receive cookies from other websites of web servers (so-called “third-party” cookies). This is due to the fact that the Website may contain elements such as, for example, images, maps, sounds or specific links to web pages on other domains residing on a server other than the one where the requested page is found. In other words, these cookies are set directly by operators of websites or servers other than the Website itself. These cookies can be sent to the user’s browser by third-party companies directly from their websites, which can be accessed by browsing the Giunti Psychometrics Sr.l. Website. In such cases, the Company is an extraneous party to the operation of these cookies, which are the responsibility of the third-party companies in question. As indeed clarified by the Authority for the Protection of Personal Data: “The obligation to inform the user about the use of cookies and, where appropriate, to obtain the prior consent thereof, falls upon the manager of the website who uses such cookies, in a capacity of Data Controller. Where a website allows the transmission of “third party” cookies, the Privacy Policy and the acquisition of consent normally fall under the responsibility of the third party. When accessing a website that allows the use of third-party cookies or when accessing the content supplied by third parties, the user must be properly informed thereof, albeit in the simplified manner provided for by applicable law, and, in any case, before the cookies are downloaded to the user’s terminal”. Specifically for the purpose of information transparency required to the managers of the “first part website” (namely the Website managed by Giunti Psychometrics S.r.l.), where “third-party cookies” operate, we hereby inform you that the following third-party cookies are used on the Website.

Statistical analysis

The services contained in this section allow the Data Controller to monitor and analyse traffic data and can be used to track user behaviour.- Google Analytics (Google Inc.) Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, to prepare reports on the corresponding activities and to share them with other Google services. Google may use the Personal Data collected to contextualise and personalise the advertisements of its own advertising network. Personal data collected: Cookies and usage data. Place of processing: USA – Privacy Policy – Opt Out

Interaction with external social networks and platforms

These services facilitate interactions with social networks or other external platforms, directly from the pages of this Application. The interactions and the information acquired through this Application are subject to the User’s privacy settings for each individual social network. In the event that a social network interaction service has been installed, it is possible that, even in the case of Users who do not use the service, the latter shall collect traffic data relating to the pages on which it is installed.- Like button and Facebook social widgets (Facebook, Inc.) The Like button and Facebook social widgets are services that facilitate interaction with the Facebook social network, provided by Facebook, Inc. Personal data collected: Cookies and usage data. Place of processing: USA – Privacy Policy.

Remarketing and Behavioural Targeting

These services enable this Application and its partners to communicate, optimise and serve ads based on the past use of this application by the user. This task is accomplished by tracking Usage Data and through the use of Cookies, information that is subsequently transferred to the partners to which the remarketing and behavioural targeting activities are linked. Facebook Remarketing (Facebook, Inc.) Facebook Remarketing is a Remarketing and Behavioural Targeting service provided by Facebook, Inc., which links this application’s activities with Facebook’s advertising network. Personal data collected: Cookies and usage data. Place of processing: USA – Privacy Policy

Displaying content from external platforms

These services facilitate the display of content hosted on external platforms, directly from the pages of this Application and interacting with them. In the event that a service of this type has been installed, it is possible that, even in the case of Users who do not use the service, the latter shall collect traffic data relating to the pages on which it is installed. YouTube Video Widget (Google Inc.) YouTube is a video content display service provided by Google Inc. which allows this Application to integrate such content on its pages. Personal data collected: Cookies and usage data. Place of processing: USA – Privacy Policy Data Controller and Data Processors. The identification details of the company acting in a capacity of Data Controller with respect to the data subject’s personal data (the list of Data Processors is available at the Data Controller’s headquarters) are as follows: Giunti Psychometrics S.r.l. Via Frà Paolo Sarpi, 7/A, 50136, Florence (FI), Italy VAT no.: 00421250481 Tel. +39 055 623 6501 Fax +39 055 669446

Address for exercising the data subjects’ rights pursuant to Article 7 of the Privacy Code and Articles 12 to 22 of EU Regulation 679/16: privacy@giuntipsy.com and/or the Data Protection Officer, Avv. Victoria Parise privacy@giuntipsy.com.

Third-party websites and services

The Website may contain links to other websites that have their own Privacy Policies, which may be different from that adopted by the Company’s Website and which the Company is therefore not responsible for.

How to disable cookies in main web browsers through configuration

Chrome

Launch the Chrome Browser
Click on the menu found in the browser toolbar located to the side of the navigation URL entry window
Select Settings
Click on “Show Advanced Settings”
In the “Privacy” section click on the “Contents settings” button.
In the “Cookie” section it is possible to modify the following settings regarding cookies:
- Allow local data to be set o Keep local data only until you quit your browser
- Block sites from saving any cookies
- Block third-party cookies and website data anage exceptions for certain websites
- Delete one or all cookies