Cookie policy

1. Introduction 

This cookie policy refers exclusively to the site https://www.gsdinternational.com/ (the “Site”) and forms an integral and substantive part of the same site’s Privacy Policy available at this link and must be read in conjunction with it.

2. Contact details of the Data Controller and Data Protection Officer (DPO)

The Data Controller of the processing activities of the data collected through the Site is GSD Sistemi e Servizi S.c. a r.l., with registered office in Milan (Milan), Via Spadolini no. 4 (hereinafter "GSDSS" or "Data Controller"), who can be contacted, for any information concerning the processing of personal data, at the following address: amministrazione.gsdss@grupposandonato.it. 

The Data Controller has appointed a Data Protection Officer ("DPO"), who can be contacted at the following email address: rpd.gsdss@grupposandonato.it.

3. Definitions, characteristics and application of regulations 

Cookies are small text files that a site, when visited by a user (“Data Subject”), sends and stores on the user’s computer or mobile device, to be subsequently sent back to the site upon the user’s next visit. Through the use of cookies, a site can record a user’s actions and preferences (such as, for example, login data, the preferred language, character size and other viewing settings, etc.) and, in this way, there is no need for the user to re-enter this information when he/she returns to the site or when he/she moves from one page of the site to another. Cookies, therefore, are used to perform computer authentication, to monitor sessions and to record information about the activities of a user who accesses a site. Cookies may also contain a unique identifying code that enables the user to be tracked as he/she browses the site. Tracking is done for statistical and/or advertising purposes.

As a user browses one site, the user may receive “first-party cookies” where installed directly by the Data Controller, but also cookies from other, different sites or web servers (so-called "third-party cookies"). Some operations may not work properly without the use of cookies which, in certain cases, are technically necessary for the site to function.

There are various types of cookies, with each type having its own particular characteristics and functions, and cookies can remain on the user’s computer or mobile device for different periods of time: so-called ”session cookies”, which are automatically deleted when the user’s browser is closed; so-called ”persistent cookies”, which stay on the user’s device until a pre-set expiry date. 

On the basis of the existing regulations in Italy, the use of cookies does not always require the user’s express consent. Specifically, “technical cookies” do not need such consent. These cookies are used for the sole purpose of transmitting data over an electronic communications network, or to the extent strictly necessary to provide a service which has been explicitly requested by the user. In other words, these cookies are essential for the site to work properly or are needed to perform an activity requested by the user. 

Amongst these technical cookies, which do not require a user’s consent in order to be used, the Italian Data Protection Authority (Garante per la protezione dei dati personali) (see Simplified arrangements to provide information and obtain consent regarding cookies of May, 8 2014 and “Cookies and other tracking tools guidelines of June 10,2021”) also includes so-called “first-party analytical cookies” and “anonymized third-party analytical cookies”. 

For the so-called "Profiling cookies", on the other hand, are those cookies used to build a profile of the user in order to send him/her advertisements which are consistent with the preferences expressed as he/she browses the internet; for such cookies to be deployed the user’s consent is required. 

4. Types of cookie used by the Site 

The Site uses the following first party and third party types of cookies: 

• Technical cookies – browsing or session – that are strictly necessary for the Site to work properly or to allow the user to access content and services requested. 

• Analytical cookies that allow the website manager to understand how the site is used by users. These cookies do not collect any information about the user’s identity nor any personal data. Information is processed in an aggregated and anonymous form. 

In detail, the cookies sent directly through the Site are given below:

5. How to view and change cookies through your web browser 

The user may select which cookies to accept by following the relevant procedure in the Settings relative to cookies section below, as well as accepting, blocking and deleting cookies (in whole or in part) through the specific browser functions: however, if all or some cookies are disabled, it may result in the Site not being accessible or in some services or certain features not being available or not working properly and/or the user may have to modify or re-enter certain information or preferences each time that he/she visits the Site. 

For more information on how to set cookie preferences through a browser, see the relative instructions: 

• Internet Explorer 

• Firefox 

• Chrome 

• Safari 

The user may decide and specifically indicate which cookies to authorise. 

The user must bear in mind, however, that if technical cookies are not authorised, it might be impossible to use the Site, to view the Site’s content and/or to use the related services. Blocking functional cookies may result in some services or certain features not being available or not working properly and the user may have to modify or re-enter certain information or preferences each time that he/she visits the Site.  

If other, third-party cookies are not authorized, however, this has no effect whatsoever on the functioning of the Site; yet, being cookies sent exclusively by third parties, and given the fact that the website manager has no control over whether and how these cookies are sent to the user’s device, a user can only object to these cookies through the consent forms made available by these third parties, if present, or by changing the settings in his/her browser. Links to the relative privacy policies and to the relevant forms to disable such cookies are given in the section "Types of cookies used by the Site". 

As for cookies sent directly by the website manager, as well as through the procedure made available on this page, the user may block or delete cookies (in whole or in part) through the specific browser functions (in this regard, please see the above).  

The user’s decisions regarding cookies used by the Site will be, in turn, recorded in a special technical cookie having the characteristics given in the specific table on cookies. This cookie may, however, not work properly in certain situations: in this case, the user should delete any unwanted cookies and block their use through his/her browser’s functions.  

For further information regarding the functioning and use of cookies and to make choices regarding them the user may visit the sites: http://www.youronlinechoices.eu or www.allaboutcookies.org. 

The user’s preferences in terms of cookies will have to be reset if different devices or browsers are used to access the Site.

6. Methods of collecting consent to the use of cookies

The Data Controller uses exclusively technical cookies. These categories do not require the User's consent. 

At the moment access to the homepage, is present a Banner which contains a short information in the subject of cookie. The same informs the user about the meaning of their actions. In particular, by clicking on "Accept All" the user consents to the use of cookies and other technologies on the Site, including analytics cookies; by clicking on "Reject All” or “X” in the upper right corner, only technical cookies will be installed; by clicking on "Customize", the User has the opportunity to choose which categories of cookies to install on his device.

7. Transfer of personal data

Personal data collected by means of first-party - i.e., installed by GSDSS - cookies on the Site are not transferred outside the European Union. 

With reference to transfers of personal data made by means of third-party cookies, please refer to the respective data processing policies set out in the links indicated in Section 5 of this Cookie Policy.

8. Categories of recipients of the personal data

Personal Data collected through cookies may be shared with:

• Persons authorized by the Data Controller to process Personal Data (pursuant to Article 29 of the GDPR and 2-quaterdecies of the Privacy Code), in their capacity as employees and/or collaborators, who have received appropriate operational instructions, have committed to confidentiality or are subject to an appropriate legal obligation of confidentiality.
• Persons or companies appointed by the Data Controller to carry out activities strictly related to the pursuit of specific purposes (by way of example but not limited to technical maintenance work on the systems), duly appointed as data processors pursuant to Article 28 of the GDPR. The list of names of the data processors is available to Data Subjects at the Data Controller.
• Subjects, entities or authorities to which the communication of the Data Subject's personal data is obligatory by virtue of legal provisions or orders of the competent authorities.

9. Rights of the Data Subject

Consistent with the provisions of the GDPR, the User has the right to request from the Data Controller, at any time, access to, rectification or erasure of his/her Personal Data or to object to its processing. The law also allows the User to exercise the right to request the restriction of processing in the cases provided for by Article 18 of the GDPR, as well as to obtain in a structured, commonly used and machine-readable format the Personal Data concerning him/her, in the cases provided for by Article 20 of the GDPR. 

Requests can be addressed to the e-mail address in paragraph 2 of this Cookie Policy.

Lastly, you always have the right to lodge a complaint with the competent supervisory authority (Garante per la Protezione dei Dati Personali), in accordance with Article 77 of the GDPR, if you believe that the processing of your Personal Data is contrary to applicable law.