Cookies are small text strings that a website can send, while browsing, to the browsing device (be it a PC, a notebook, a smartphone, a tablet, etc.). They are usually managed directly by the browser used for browsing and registered directly on the device. The same website that transmitted them can then read them to find information of various kinds and update.

There are two basic macro-categories, with different characteristics of cookies: technical cookies and profiling cookies.

Technical cookies are generally necessary for the proper functioning of the website and to allow it to be browsed; without them, the user may not be able to view the pages correctly or use some services.

These can be:

• navigation cookies or session cookies, which guarantee normal navigation and use of the website’s services (allowing, for example, to manage all the phases required for the use of a specific service to access restricted areas). These are deleted immediately when you close your browser;
• Analytics cookies, used directly by the site manager to collect information, in aggregate form, on the number of users and how they visit the site.
• functionality cookies, which allow the user to browse according to a series of criteria selected in order to improve the service rendered to the same;
• Persistent cookies remain within your browser for a certain period of time. They are used, for example, to recognize the device that connects to the site, facilitating authentication operations for the user.

Profiling cookies have the task of profiling the user and are used in order to send advertising messages in line with the preferences expressed by the user during his browsing.

Cookies, in general, can be generated and managed directly by the operator of the website on which the user is browsing (first-party cookies), or generated and managed by different parties (third-party cookies).

COOKIES USED BY THIS SITE AND THEIR PURPOSES

WiseTown uses:

• technical navigation or session cookies and persistent cookies for the management of the authentication service at access to some services; authentication cookies will allow the temporary storage of the username and password chosen by the User for access to the various reserved areas of the Site. These are cookies that are necessary for the use of the website, blocking them does not allow them to function;
• analytics cookies used to collect information in aggregate form on the number of Users and how they visit the Site; analytics cookies allow, among other things, the collection and processing of the User’s browsing data, including the IP addresses or domain names of the computers used by Users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, and other parameters relating to the User’s operating system and IT environment; the data are collected for the sole purpose of processing anonymous statistical information on the use of the Site and to verify the correct functioning of the same; navigation data may be used to identify the User only if this is necessary for the detection of computer crimes;
• Third-party cookies are managed 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.

In WiseTown it is possible that there are cookies managed by sites of other organizations aimed at the presence of parts of the page visited generated directly by these sites and integrated into the website/Application; It is also possible that these third parties use these cookies for profiling.

These could be persistent cookies, as they are active until their expiry date (their duration varies depending on the type of cookie) or when they are deleted by the user.

At any time it is possible to obtain information on third-party cookies and authorize, limit or block these cookies through the browser settings and/or the information and consent form made available by the third parties listed below:

• ESRI
• Google Analytics
• LiveAgent

The user can choose to enable or disable cookies by intervening on the settings of their browser according to the instructions made available by the relevant providers. Disabling these cookies may make it impossible for the User to authenticate themselves in order to access the reserved area of the Site.

Browsing without the use of technical and profiling cookies can be carried out through what is called incognito browsing and which is possible with all major browsers.

SOCIAL BUTTONS

On the WiseTown website there are special “buttons” (called “social buttons/widgets”) that depict social network icons (e.g. LinkedIn). These buttons allow users who are browsing to interact with one click directly with the social networks depicted therein. In this case, the social network acquires data relating to the user’s visit, while the Data Controller will not share any browsing information or user data acquired through its site.

DESELECTING AND ENABLING COOKIES

By accessing the site and passing the initial banner containing the brief information, the user has given his/her express consent to the use of the third-party cookies indicated above.

The selection/deselection of individual cookies can be done freely through your browser (by selecting the settings menu, clicking on the Internet options, opening the privacy tab and choosing the desired level of cookie blocking). For more information, please visit the following links: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer. In addition, you can activate the Do Not Track option present in most of the latest generation browsers. Third-party cookies can be disabled by informing themselves through the privacy policy of the third party, through the link indicated above, or by contacting the third party directly. Disabling “third-party” cookies does not affect navigability in any way.

 

LEGAL BASIS AND PURPOSE OF THE PROCESSING

The personal data indicated on this page are processed exclusively for the execution of the services offered through WiseTown.

Pursuant to art. 2-ter of Legislative Decree 196/2003 (Legal basis for the processing of personal data carried out for the performance of a task carried out in the public interest or related to the exercise of public authority), the legal basis for the processing of the data covered by this policy is established by Article 6, first paragraph letter b) of the GDPR, by virtue of which the processing of personal data must be considered lawful when “necessary for the performance of a contract to which the data subject is a party”.

 

DATA TRANSFER

The Data Controller for the services offered through the website/Application uses servers located in the territory of the European Union, owned by Microsoft Azure, which is identified as an external data processor. The Data Controller guarantees a high standard of protection and compliance with the regulations relating to the processing of personal data by the subjects designated as external data processors. Please refer to Microsoft Azure’s privacy policy to verify compliance with regulatory provisions on privacy and the protection of personal data.

Exclusively with reference to third-party cookies, some data may have to be shared with services located outside the European Union. In these cases, the transfer is authorized pursuant to Article 46 of the GDPR as the third parties provide adequate guarantees of protection for the rights of the data subjects.

You can refuse the use of third-party cookies and at any time you can revoke the consent you have already given.

 

DATA RECIPIENTS

The personal data collected are processed by the Data Controller’s staff who act on the basis of specific instructions provided regarding the methods and purposes of the processing itself.

The Data Controller, for the services offered by WiseTown, uses servers owned by Microsoft Azure located in the territory of the European Union. Data is generally not transferred to third parties, except in specific cases:

• legitimate request by the judicial authority and only in the cases provided for by law;
• if it is necessary for the provision of a specific service requested by the User;
• to perform security checks and optimization of the Application.

Therefore, in these cases, the data provided may be communicated to recipients belonging to the following categories:

– competent authorities for the fulfilment of legal obligations and/or provisions dictated by public bodies;

– external parties who manage/support/assist, even if only occasionally, the joint controllers in the administration of the information system and telecommunications networks.

The subjects belonging to the above categories perform the function of Data Processor (on the basis of specific appointment), or operate in total autonomy as Data Controllers or perform the function of Joint Data Controllers. The list of any data processors is constantly updated and available from each Data Controller.

The Data Controller undertakes to use external suppliers and processors who comply with the guarantees established by art. 46 et seq. of the GDPR.

The Data Controller periodically verifies the tools through which personal data are processed and the security measures provided for them, which it provides for to be constantly updated. It also verifies, also through the persons authorised to process the processing, that no personal data is collected, processed, stored or stored that is not necessary for processing; verifies that the data are stored with the guarantee of integrity and authenticity and that their use is limited exclusively to the intended purposes.

DURATION OF STORAGE

In compliance with the provisions of art. 5 paragraph 1 letter e) of the GDPR, the personal data collected will be stored for a period of time not exceeding the achievement of the purposes for which the personal data are processed (principle of storage limitation) or according to the deadlines provided for by law.

NATURE OF PROVISION AND REFUSAL

Except as specified for navigation data that is acquired automatically, users are free to provide their personal data or not to provide them.

Failure to provide such data, however, may make it impossible to use all or some of WiseTown’s services.

RIGHTS OF THE DATA SUBJECTS

Pursuant to art. 7 of the Privacy Code, at any time and free of charge, the interested party has the right to obtain confirmation of the existence or otherwise of the data concerning him/her and to know its content and origin, to verify its accuracy or request its integration or updating, or rectification. You also have the right to request the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose the processing of data concerning you for legitimate reasons.

Data subjects have the right to object to the processing of their personal data (articles 15 et seq. of the Regulation) by sending a specific request to the e-mail address: support@wise.town.

RIGHT TO LODGE A COMPLAINT

Data subjects who believe that the processing of their personal data is in violation of the provisions of the Regulation have the right to lodge a complaint with the Data Protection Authority, as provided for by art. 77 of the Regulation, or to take legal action (Article 79 of the Regulation).

Any update to this policy will be communicated to the User promptly and by appropriate means and the same will be communicated if the Data Controller follows up with the processing of personal data for purposes other than those referred to in the Privacy Policy with adequate notice for the purposes of the necessary consent.

SPECIAL ASSIGNMENTS

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