1. Data Controller
The Data Controller is MV Luxury Group s.r.l., with registered office in Piazza San Giorgio 2, Milan (MI), 20123 – Italy, Tel. (+39) 02.843.422.75, e-mail firstname.lastname@example.org (hereinafter the “Data Controller” or “MV”).
2. Browsing data
In the course of their normal operation, the IT systems and procedures used to operate the Site automatically acquire certain personal data relating to Data Subject browsing, including environmental variables, the transmission of which is implicit in the use of internet communication protocols. This category of data includes, but is not limited to:
- The IP addresses of the computers operated by Users accessing the service;
- The quantity of accesses;
- The pages viewed;
- The date and time when access took place;
- What URL the browser was before it displayed our page;
- The type of browser;
- The operating system used.
Except as specified below, merely visiting the Site and its sections does not imply the processing of the User’s personal data.
3. What are Cookies
Cookies are strings of text that websites (publishers or “first parties”) visited by the User, or different sites or web servers (“third parties”) place and store – directly, in the case of publishers, and indirectly, i.e. through publishers, in the case of “third parties” – in a terminal available to the User.
Cookies can have different temporal characteristics and can therefore be classified according to their duration, or else subjectively. In this regard, it is possible to distinguish between:
- persistent cookies, i.e. cookies that remain stored, until they expire, on the user/visitor’s device. They are used in order to facilitate browsing within the Site and the proper use thereof; to facilitate access to services that require authentication, for statistical purposes; to know which areas of the Site have been visited, as well as, in some cases, for optimal management of pages and advertising spaces; or to deliver content and advertising in line with the choices made by browsers.
- session cookies, i.e. cookies that are not stored persistently on the User’s device and that disappear when the browser is closed. They are used for the purpose of transmitting the session identifiers necessary to enable safe and efficient exploration of the Site.
- first-party cookies, i.e. those generated and managed directly by the webmaster. They may be either persistent or session cookies.
- third-party cookies, i.e. cookies generated and managed by third parties other than the Data Controller and unrelated to the Site. They may be either persistent or session cookies.
In addition, cookies can also be classified in relation to the processing purposes pursued by the individual cookie. In this perspective, it is possible to distinguish between:
- technical cookies, i.e. cookies used for the sole purpose of “carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contracting party or user to provide such service” (see Article 122(1) of the Italian Privacy Code). Technical cookies are necessary and help to make a website usable by enabling basic functions such as page browsing and access to protected areas of the Site. The Site cannot function properly without these cookies.
- statistical cookies, i.e. cookies aimed at collecting information, in aggregate form, on the Users of the Site and similar to technical cookies provided that: (i) they are only used to produce aggregate statistics and in relation to a single site or mobile application; (ii) at least the fourth component of the IP address is masked for third-party cookies; (iii) third parties refrain from combining analytics cookies, thus minimized, with other processing methods (customer files or statistics of visits to other sites, for example) or from passing them on to other third parties (without prejudice to the possibility for third parties to produce statistics with data relating to multiple domains, websites or apps that can be traced back to the same publisher or group of undertakings). This is without prejudice to the right of the Data Controller to carry out, on its own initiative, the mere statistical processing of data relating to the Site and to several domains, websites and apps that can be traced back to it, including by use of unencrypted data in compliance with the purpose limitation;
- profiling (or non-technical) cookies, i.e. cookies used to link specific actions or behavioral patterns recurring in the use of the functionalities offered to specific identified or identifiable subjects, in order to group the different profiles within homogeneous clusters of different sizes, so that it is also possible to modulate the provision of the service in an increasingly customized way, as well as to send targeted advertising messages, i.e. in line with the preferences expressed by the User during web browsing.
4. Cookies used by the Site and their purposes
The Site uses the following technical, statistical (similar to technical) and profiling cookies:
|Type of Cookie||Cookie Name||Supplier||Purpose||Duration|
|Technician||wpml_browser_redirect_test||Part One||Collects data on the language used in the User’s browser.||Session duration|
|Technician||_icl_visitor_lang_js||Part One||Collects data on the language used in the User’s browser.||Session duration|
|Non-Technical||_gat_gtag_UA_163121973_1||Third Parties (Google Inc.)||Traffic Statistics and Analysis||1 minute|
|Non-Technical||_gat||Third Parties (Google Inc.)||Statistics and Analysis. Used by Google Analytics to restrict the number of requests.||1 day|
|Non-Technical||_gali||Third Parties (Google Inc.)||Statistics and Analysis.||2 years|
|Non-Technical||_gid||Third Parties (Google Inc.)||Statistics and Analysis. Records a unique ID used to generate statistical data on how the visitor uses the website.||24 hours|
|Non-Technical||_ga||Third Parties (Google Inc.)||Statistics and Analysis. Used to distinguish unique users.||2 years|
|Non-Technical||SIDCC||Third Parties (Google Inc.)||Marketing.||6 months|
|Non-Technical||SID||Third Parties (Google Inc.)||Marketing and Security. Used for the provision of advertisements and for retargeting.||6 months|
|Non-Technical||APISID||Third Parties (Google Inc.)||Stores user preferences and information every time the user visits web pages containing containing maps extracted from Google Maps.||2 years|
|Non-Technical||SAPISID||Third Parties (Google Inc.)||Marketing. Saves certain user preferences and adjusts the ads that appear on Google Search.||2 years|
|Non-Technical||SSID||Third Parties (Google Inc.)||Marketing. Saves certain user preferences and adjusts the ads that appear on Google Search.||2 years|
|Non-Technical||HSID||Third Parties (Google Inc.)||Marketing and Security. Saves certain user preferences and adjusts the ads that appear on Google Search. Used by Google to prevent fraudulent activity.||6 months|
|Non-Technical||NID||Third Parties (Google Inc.)||Security, analysis and statistics, functionality and advertising purposes.||6 months|
|Non-Technical||__Secure-1PSIDCC||Third Parties (Google Inc.)||Used for advertising targeting purposes and for profiling visitor interests in order to display relevant and customized Google ads.||2 years|
|Non-Technical||__Secure-1PSID||Third Parties (Google Inc.)||Used for advertising targeting purposes and for profiling visitor interests in order to display relevant and customized Google ads.||2 years|
|Non-Technical||__Secure-1PAPISID||Third Parties (Google Inc.)||Used for advertising targeting purposes and for profiling visitor interests in order to display relevant and customized Google ads.||2 years|
|Non-Technical||__Secure-3PSID||Third Parties (Google Inc.)||2 years|
|Non-Technical||__Secure-3PSIDCC||Third Parties (Google Inc.)||2 years|
|Non-Technical||1P_JAR||Third Parties (Google Inc.)||Marketing, tracking and retargeting purposes.||30 days|
|Non-Technical||DV||Third Parties (Google Inc.)||Marketing. Used to collect site statistics, track the conversion ratio and customize Google ads.||1 day|
|Non-Technical||OTZ||Third Parties (Google Inc.)||Aggregated user analysis||1 day|
|Technician||AEC||Third Parties (Google Inc.)||Security. Used by Google to prevent spam, fraudulent activity and abuse. Ensures that requests within a browsing session are made by the user and not by other sites.||6 months|
|Technician||SOCS||Third Parties (Google Inc.)||Used to store user choices related to cookies||13 months|
|Technician||SEARCH_SAMESITE||Third Parties (Google Inc.)||Security. Used to mitigate the risk of data loss due to requests from other sites, as well as to provide protection against fraudulent cross-site requests.||2 years|
|Technician||CONSENT||Third Parties (Google Inc.)||Used to store user choices related to cookies||2 years|
The installation of non-technical cookies is subject to the prior express consent of the User within the appropriate banner by clicking: (i) the “Accept All” button, or (ii) on the “Accept Selected” button after having selected “Statistics and Analysis” and/or the “Marketing and Advertising” by clicking on the list of individual cookie categories. If (i) the banner is closed without the User having previously made any selection, (ii) the User selects the “Reject” button or (iii) the “Accept Selected” button without having previously activated the button relating to the “Statistics and Analysis” item and/or the “Marketing and Advertising” item, then non-technical cookies, including those of Google Analytics, will not be installed on the User’s computer, and Site browsing will continue with the default settings, which contemplate the exclusive use of technical cookies.
Acceptance of the installation of Google Inc. technical cookies is subject to the express consent of the User in one of the ways described above. Acceptance of the installation of Google’s analytics or profiling cookies also necessarily implies acceptance of the Google technical cookies described in the table above.
By clicking on the “Accept only necessary cookies” button or by closing the cookie banner without selecting any button, the User acknowledges that the Site will only proceed to install the first-party technical cookies necessary to ensure the correct operation and use of the Site.
Mere scrolling or browsing within the Site does not under any circumstances constitute an expression of consent to the use and installation of tracking tools, with the exception of first-party technical cookies only.
The User can always change his or her choices regarding the installation of cookies. The footer of each page of the Site contains the heading “Cookie preferences” which, when clicked, makes it possible for the User to open the banner to express his or her consent with regard to cookies and change his or her choices at any time.
The Site may request that the User make a new choice of his or her cookie preferences when:
- one or more conditions of data processing change significantly and therefore the banner also fulfils a specific and necessary purpose of providing information precisely with regard to those changes;
- it is impossible for the webmaster to be aware of the fact that a cookie has already been previously stored on the device in order to be transmitted again, during a subsequent visit by the same User, to the website that generated it (for example, in the event that the User chooses to delete the cookies legitimately installed on his or her device without the webmaster having any way of keeping track of the User’s wish to maintain the default settings and thus to continue browsing without being tracked);
- at least six months have elapsed since the previous submission of the banner.
With regard to the non-technical cookies of Google Analytics, the Data Controller adopts appropriate tools to reduce their identifying power, including by masking significant portions of IP addresses, through the anonymization tool offered by Google and better described at the following link: https://support.google.com/analytics/answer/2763052?hl=it.
The installation of Google’s analytics and profiling cookies implies the transfer of data, including personal data, from the Data Subject’s browser to Google Inc., headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and their storage and archiving on the Company’s servers. The installation of Google cookies will therefore result in the transfer of data collected, including personal data, to the United States, hence outside the territory of the European Union.
Under current EU law, the United States is a third country that does not provide an adequate level of protection under Article 45 GDPR and does not offer a similar level of data protection and protection of Data Subjects’ rights as within the EU. In particular, data, including personal data, collected by Google from Data Subjects residing in the EU will be accessible by the Federal Law Enforcement Agencies of the US Government.
By expressing his or her consent to the installation of non-technical cookies by clicking (i) on the “Accept All” button on the cookie banner, or (ii) on the “Accept Selected” button after having selected the item “Statistics and Analysis” and/or the item “Marketing and Advertising” from the list of individual cookie categories, the User acknowledges this situation and the associated risks, and expressly accepts and authorizes the transfer of the personal data collected by the non-technical cookies of Google to the United States pursuant to Article 49(1)(a) GDPR.
Further information on the characteristics and purposes of third-party cookies referable to Google Inc. is available at the following links: (i) https://policies.google.com/technologies/cookies#types-of-cookies; and (ii) https://business.safety.google/adscookies/?hl=it.
5. Legal basis for data processing
5.1 Legal basis for the processing of data collected via technical and statistical cookies (both similar)
Technical cookies are necessary and contribute to the usability of the Site, enabling its basic functions such as page browsing and access to the relevant protected areas. The Site cannot function properly without these cookies. The processing of personal data collected by means of technical cookies is based on the legitimate interest of the Data Controller and does not require the prior consent of the User, since without such processing the Site could not be made available in full working order.
5.2 Legal basis for the processing of data collected via non-technical cookies
Pursuant to Article 122 of Legislative Decree No. 196/2003, the only legal basis for the processing of data collected through non-technical first- or third-party cookies is the express, free and informed consent of the User, to the exclusion of any other legal basis.
Consent is optional in relation to all non-technical cookies. In the latter case, failure to provide consent will preclude the processing of the relevant personal data and will only make it impossible for the Data Controller to provide a customized service.
Users may give or withhold their consent to the use of non-technical cookies for the purpose of analyzing the performances of the Site or for profiling purposes through the specific banner displayed when they first access the Site.
With regard to the transfer of personal data to the United States, inherent in the use of Google cookies, the legal basis is the express, free and informed consent of the User pursuant to Art. 49(1)(a) GDPR.
6. Deleting cookies
Since cookies are normal text files, they can be accessed using word processing programs. In any case, each User can independently set his or her device’s browser so that it accepts or rejects all cookies or displays a warning each time a cookie is proposed, in order to be able to evaluate whether or not to accept it.
If the User sets his or her browser to refuse the enabling of cookies, the quality of the Site pages visited may be reduced and the browsing experience may be less effective.
Below are links to the main browsers containing instructions on how to manage cookies:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=it;
- Mozilla Firefox: https://support.mozilla.org/it/kb/protezione-antitracciamento-avanzata-firefox-desktop;
- Internet Explorer: https://support.microsoft.com/it-it/windows/eliminare-e-gestire-i-cookie-168dab11-0753-043d-7c16-ede5947fc64d
- Safari: https://support.apple.com/it-it/guide/safari/sfri11471/mac
Google Analytics allows users to disable cookies by installing the opt-out tool provided by Google on their browser. This tool is available and can be downloaded at the following link https://tools.google.com/dlpage/gaoptout.
7. Interactions with third-party sites and platforms
The Site contains interaction icons which, on being clicked, redirect the User to the page/profile of the Data Controller present on the social network related to the icon.
The Data Controller has no power over how third-party platforms operate, the data they collect and the use of this information by the third-party provider.