The discipline relating to the use of so-called “cookies” and other similar tools (web beacons / web bugs, clear GIFs, etc.) in the terminals (personal computers, notebooks, tablet PCs, smartphones, etc.) used by users, is it has recently been amended following the implementation of the directive2009/136 which amended the “e-Privacy” directive (2002/58 / EC) and the provision “Identification of simplified procedures for the information and the acquisition of consent for the use of cookies – May 8, 2014”.

Cookies are small text files that are sent to your terminal (usually the browser), where they are stored before being re-transmitted to the same sites at the next visit by the same user. Cookies are used to perform computer authentication, session monitoring and storage of specific information regarding users who access the server and are usually present in each user’s browser in a very large number.

The cookies present on the domain

  • They allow you to efficiently navigate from one page of the website to another.

  • They store the username and preferences entered.

  • They allow you to avoid entering the same information (such as username and password) several times during and the visit.

  • They measure the use of services by Users, to optimize the browsing experience and the services themselves.

  • They present targeted advertising information based on the interests and behavior expressed by the User while browsing.

These features are divided into several categories:

  1. Technical cookies

The types of cookies used on the site are listed

  1. Technical cookies

They are necessary for the proper functioning of some areas of the site and include persistent cookies and session cookies. In the absence of these cookies, the site or some portions of it may not work properly. Therefore, they are always used, regardless of user preferences.

How to disable technical and analytical cookies?

It is reiterated that for this type of cookie the consent must not be explicit. They can be blocked as indicated in the following paragraphs but this operation could prevent you from using some parts of the site.

Pursuant to Article 12 and following of the GDPR, it is possible to oppose the saving of this type of cookie in the following ways.

The operating modes as well as the options for limiting or blocking cookies can be adjusted by changing the settings of your internet browser.

Most Internet browsers are initially set to accept cookies automatically, however the user can change these settings to block cookies or to be warned whenever cookies are sent to his device.

There are several ways to manage cookies, for this purpose it is necessary to refer to the instruction manual or to the help screen of your browser to check how to adjust or change the settings of the same.

In fact, the user is enabled to change the default configuration and disable cookies (i.e. block them permanently), by setting the highest level of protection. Below is the path to follow to manage cookies from the following browsers:

If the user uses different devices to view and access the Sites (for example, computer, smartphone, tablet, etc.), he must ensure that each browser on each device is adjusted to reflect his own cookie preferences. To delete cookies from the Internet browser of your smartphone / tablet it is necessary to refer to the user manual of the device.


Information and consent for the use of cookies

Frequently asked questions


1. What are cookies?

Cookies are small text files that the sites visited by users send to their terminals, where they are stored before being re-transmitted to the same sites on the next visit. The cookies of the so-called “third parties” are, on the other hand, set by a website other than the one the user is visiting. This is because on each site there may be elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the site visited.

2. What are cookies used for?

Cookies are used for different purposes: execution of computer authentication, session monitoring, storage of information on specific configurations regarding users who access the server, storage of preferences, etc.

3. What are “technical” cookies?

These are cookies that are used to browse or provide a service requested by the user. They are not used for other purposes and are normally installed directly by the website owner.

Without the use of these cookies, some operations could not be carried out or would be more complex and / or less secure, such as home banking activities (viewing the account statement, wire transfers, bill payment, etc.), for such as cookies, which allow the identification of the user to be made and maintained during the session, are indispensable.

4. Are analytics cookies “technical” cookies?

No. The Guarantor (cf.provision of 8 May 2014) specified that they can be assimilated to technical cookies only if used for the purpose of optimizing the site directly by the owner of the site, who can collect information in aggregate form on the number of users and on how they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, provided for technical cookies.

5. What are “profiling” cookies?

These are cookies used to track the user’s navigation on the network and create profiles on his tastes, habits, choices, etc. With these cookies, advertising messages can be transmitted to the user’s terminal in line with the preferences already expressed by the same user while browsing online.

6. Is the user’s consent necessary for the installation of cookies on his terminal?

It depends on the purposes for which the cookies are used and, therefore, if they are “technical” or “profiling” cookies.

Users’ consent is not required for the installation of technical cookies, while information must be given (Article 13 of the Privacy Code). Profiling cookies, on the other hand, can be installed on the user’s terminal only if he has given his consent after being informed in a simplified manner.

7. How must the site owner provide the simplified information and request consent to the use of profiling cookies?

As established by the Guarantor in the provision indicated in question no. 4, the information must be set on two levels.

When the user accesses a website (on the home page or on any other page), a banner must immediately appear containing a first “short” information, the request for consent to the use of cookies and a link to access to a more “extended” information. On this page, the user can find more and more detailed information about cookies and choose which specific cookies to authorize.

8. How should the banner be created?

The banner must be large enough to partially cover the content of the web page the user is visiting. It must be able to be eliminated only through an active user intervention, i.e. through the selection of an element contained in the page below.

9. What information must the banner contain?

The banner must specify that the site uses profiling cookies, possibly also from “third parties”, which allow you to send advertising messages in line with user preferences.

It must contain the link to the extended information and the indication that, through that link, it is possible to refuse consent to the installation of any cookie.

It must specify that if the user chooses to continue by “skipping” the banner, he agrees to the use of cookies.

10. How can the acquisition of consent made through the use of the banner be documented?

To keep track of the consent acquired, the owner of the site can use a specific technical cookie, a system that is not particularly invasive and does not in turn require further consent.

In the presence of this “documentation”, it is not necessary for the brief information to be re-proposed on the user’s second visit to the site, without prejudice to the possibility for the latter to deny consent and / or modify, at any time and in a manner easy, your options, for example by accessing the extended information, which must therefore be linkable from every page of the site.

11. Can the online consent to the use of cookies be requested only through the use of the banner?

No. The owners of the sites always have the possibility of resorting to methods other than that identified by the Guarantor in the provision indicated above, provided that the methods chosen meet all the requirements for the validity of the consent required by law.

12. Does the obligation to use the banner also affect the owners of sites that use only technical cookies?

No. In this case, the owner of the site can give the information to users in the manner he deems most suitable, for example, also by inserting the relevant information in the privacy policy indicated on the site.

13. What should the “extended” information indicate?

It must contain all the elements required by law, analytically describe the characteristics and purposes of the cookies installed by the site and allow the user to select / deselect individual cookies.

It must include the updated link to the information and consent forms of the third parties with which the owner has entered into agreements for the installation of cookies through its site.

Finally, it must recall the possibility for the user to express their cookie options also through the settings of the browser used.

14. Who is required to provide the information and request consent for the use of cookies?

The owner of the website who installs profiling cookies.

For third-party cookies installed through the site, the disclosure and consent obligations are imposed on third parties, but the owner of the site, as a technical intermediary between them and the users, is required to include the updated links in the “extended” information to the information and consent forms of the third parties themselves.

15. Should the use of cookies be notified to the Guarantor?

Profiling cookies, which usually persist over time, are subject to the notification obligation, while cookies that have different purposes and fall within the category of technical cookies, do not have to be notified to the Guarantor.

16. When do the measures prescribed by the Guarantor come into force with the provision of 8 May 2014?

The Guarantor has provided for a transitional period of one year starting from the publication of the provision in the Official Gazette to allow interested parties to comply. This period will end on 2 June 2015.