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. Cd cookies "third parties" are instead 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 for?

Cookies are used for different purposes: computer authentication, session monitoring, storing information on specific configurations concerning users accessing the server, storing preferences, etc.

3. Waht are "technical" cookies?

These are cookies 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 performed or would be more complex and / or less secure, such as, for example, home banking (account statement display, bank transfers, bill payments, etc.), for the which cookies, which allow you to make and keep the user's identification within the session, are essential.

4. Are the analytics cookies "technical" cookies?

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

5. What are "profiling" cookies?

These are cookies used to track user browsing on the net 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 shown by the same user while browsing online.

6.Is the user's consent required to install cookies on his terminal?

It depends on the purposes for which the cookies are used and, therefore, if they are technical or profiling cookies.
For the installation of technical cookies, users' consent is not required, while it is necessary to provide information (Article 13 of the Code privacy). Profiling cookies, on the other hand, can only be installed on the user's terminal if they have given their consent after being informed in a simplified manner.

7. How should 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 containing a first brief information, the request for consent to the site must immediately appear. Use of cookies and a link to access a more extensive information. On this page, the user will be able to find more and more detailed information on cookies, choosing which specific cookies to authorize.

8. How should the banner be made?

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, that is through the selection of an element contained in the page below.

9. What indications should the banner contain?

The banner must specify that the site uses profiling cookies, possibly also diterze parts, which allow to send advertising messages in line with the user's preferences. It must contain the link to the extended information and the indication that, through that link, it is possible to refuse the consent to the installation of any cookie. It must be specified that if the user chooses to continue skipping the banner, he consents to the use of cookies.

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

To keep track of the acquired consent, the site owner can use a specific technical cookie, a system that is not particularly invasive and that does not in turn require further consent. at 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 an easy manner, his own options, for example through access to the extended information, which must be therefore linkable from every page of the site.

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

No. The owners of the sites always have the possibility of having recourse to methods other than that identified by the Guarantor in the aforementioned provision, provided that the methods chosen present all the requisites of validity of the consent required by law.

12. Does the obligation to use the banner also apply to site owners who only use 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 relative indications 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 information and to third-party consent forms with which the owner has stipulated agreements for the installation of cookies through his site. Finally, he must recall the possibility for the user to express his 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 website owner who installs profiling cookies. For third-party cookies installed through the site, the disclosure and consent obligations are borne by third parties, but the site owner, as a technical intermediary between these and users, is required to insert updated information links in the extended information and to the consent forms of the third parties themselves.

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

Profiling cookies, which usually last over time, are subject to notification, while cookies that have different purposes and fall into the technical cookie category must not be notified to the Guarantor.

16. When will 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 come into compliance. This period will end on 2 June 2015.