Cookie policy

Foreword

This Cookie Policy has been drawn up and customized specifically for the website www.autopromotec.com owned by Promotec s.r.l., based in Via Emilia 41/b Anzola dell'Emilia, 40011 (BO), Italy, VAT No. 00536491202, telephone +39 051 642 4000, email info@autopromotec.it. The Data Controller has appointed the Data Protection Officer, Ms. Chiara Ciccia Romito, who can be contacted at the following email address: dpo@autopromotec.it.
This Policy has been drafted on the basis of the provision of the Italian Data Protection Authority no.229 of 8 May 2014 "Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies" and the New provision no. 231 of 10 June 2021 "Guidelines on the use of cookies and other tracking tools". It supplements and updates other information notes already present on the website and/or issued before now by the company, in combination with which it provides all the elements required by Article 13 of EU Regulation 2016/679.

Important caution

We inform all third parties that the use of this information note, or even only parts of it, on other websites in reference to which it would certainly be irrelevant and/or incorrect and/or inconsistent, may lead to the imposition of heavy penalties by the Italian Data Protection Authority.

What are cookies

In practical and non-technical terms, a cookie can be considered a tracking system that consists of a small file, stored by the website in the user device while browsing, used with the aim of saving the preferences shown during browsing and improving the performance of the website, thus optimizing the browsing experience.
In technical terms, cookies are defined as strings of text (generally consisting of a combination of letters and numbers) that websites (so-called first parties) visited by the user or different website servers (so-called third parties) place and store, directly and/or indirectly, within a terminal device (PC, tablet, smartphone, etc.) that is available to the user. Servers for internet browsing or for device operation may store cookies and then transmit them to the same websites that have generated them, with a view to a subsequent visit by the same user. Specifically, these tracking tools allow the Website to recognize a given device or browser.

Types of cookies and their purposes

Cookies can be classified into:

• Technical cookies, used for the sole purpose of transmitting a communication on an electronic communication 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 as set out in Article 122, paragraph 1 of the Privacy Code. These types of cookies do not require the acquisition of consent from the user, but must be indicated in the cookie policy.
• Profiling cookies, used to trace specific actions or behavioural patterns back to specific, identified or identifiable individuals in order to allow the owner to modulate the provision of the service in a more customized way and send advertising messages in line with the preferences shown by the user during browsing.
• Analytics cookies, installed on the user terminal by the operators of the website visited or third-party websites. Third-party cookies, mainly for analytical purposes, are mostly derived from Google Analytics functions. For more information about Google Analytics, click on the link below: http://www.google.it/intl/it/analytics. In any case, cookies do not allow the data subject to be identified and are intended to refer to the individual device or the individual application in order to avoid tracking the user browsing data. Analytics cookies may be processed in the same way as technical cookies, and therefore without the user consent, under the following conditions:

• The use is limited to the production of aggregate statistics that can be used in relation to the website visited by the user;
• With regard to so-called third-party analytics cookies, the fourth part of the IP address being tracked must be masked;
• With regard to the so-called third-party analytics cookies, the third party must be prevented from using the analytics cookies in combination with other processing or disclosing them to other third parties.

Applicable legislation

For the use of cookies and other technical tracking tools, the Data Controller is subject only to the obligation to provide specific information to the Data Subject.  With regard to cookies and other tracking tools for purposes other than technical, the use is permitted only after obtaining the informed consent of the user, which must be expressed by an unambiguous indication, in accordance with Recital 32.

Consent acquisition mechanism

The Data Controller guarantees the mechanism for acquiring consent through the presentation of a banner when the user first accesses the website.
The banner contains:

• an X in the top right corner, which is equivalent to the user not giving consent.
• a brief information note stating that the website uses technical cookies and, only after obtaining the user consent, also profiling cookies.
• a link to the privacy policy and cookie policy.
• a command through which the user expresses his/her consent.
• a link to an area dedicated to the selection and customisation of cookies, where users can freely give their consent to functionalities, providers and specific cookies they wants to accept.

In the event that the user does not consent to the use of cookies and other tracking tools, and in the event that the user has chosen to consent only to the use of certain cookies, the choice is recorded and no longer solicited, except in the following cases:

• when one or more processing conditions change significantly
• when it is impossible for the website operator to know whether a cookie has already been stored on the device
• when at least 6 months have elapsed since the previous display of the banner.

Cookies used - Retention periods - Purposes - Transfer of data to third parties

Browser settings

We also inform you that the user can configure, freely and at any time, his/her privacy parameters in relation to the installation and use of cookies, directly through his/her browsing program (browser) by following the relevant instructions.
In particular, the user can set the so-called "private browsing", thanks to which his/her browsing program stops saving the history of visited websites, any passwords entered, cookies and other information on the pages visited.
Please note that if the user decides to disable all cookies (including technical cookies), the quality and speed of the services offered by this website may drastically worsen and the user may lose access to some sections of the website.

Data Subjects' rights

We inform you that, as Data Subject, you are entitled to exercise the following rights:
Right to access pursuant to Article 15 of EU Reg. 20167679, the Data Subject shall have the right to obtain confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and, inter alia, information on the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed.
Right to rectification pursuant to Article 16 of the Regulation:

•  rectification of inaccurate personal data concerning him or her without undue delay
• right to have incomplete personal data completed.

Right to erasure ("right to be forgotten") pursuant to Article 17 of the Regulation, erasure of personal data concerning you without undue delay
Right to restriction of processing pursuant to Article 18 of the Regulation, restriction of processing where one of the following applies:

• the accuracy of the personal data is contested by the Data Subject, for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful and the Data Subject opposes the erasure of the personal data and requests the restriction of their use instead;
• the Controller no longer needs the personal data for the purposes of the processing, but they are required by the Data Subject for the establishment, exercise or defence of legal claims;
• the Data Subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

Right to data portability pursuant to Article 20 of the Regulation, you can receive in a structured, commonly used and machine-readable format the personal data we hold about you;
Right to transmit such data to another data controller without hindrance from the controller to which the personal data have been provided in the cases referred to in Article 20 of the Regulation.
Right to object to processing carried out pursuant to Article 6(1)(e) or (f) and pursuant to Article 21 of the Regulation to object, at any time, on grounds relating to your particular situation, to processing of personal data concerning you, including profiling.
The aforementioned requests may be submitted to the Data Controller
The Data Controller is PROMOTEC srl, with registered office at 40011 – Anzola Emilia (BO) Italy, via Emilia 41/B, VAT No. 00536491202, telephone +39 051 642 4000, email info@autopromotec.it and certified electronic mail info@pec.autopromotec.it. 
Requests may be sent via:

• a registered letter with acknowledgement of receipt to PROMOTEC srl, with registered office in via Emilia 41/B, 40011 - Anzola Emilia (BO), Italy
• an email to privacy@autopromotec.it;
• a certified electronic mail to info@pec.autopromotec.it;
• an email to the DPO email address dpo@autopromotec.it

Furthermore, should the processing be deemed to have been carried out in breach of personal data protection legislation, a complaint may be lodged with the Italian Data Protection Authority, at Piazza Venezia, 11 - 00187 Rome - Italy.