Notice on cookies used by the Site
1. Data Controller
The Data Controller is Swiss Chamber – Camera di Commercio Svizzera in Italia (Schweizerische Handelskammer in Italien), with registered office at Via Palestro 2, 20121, Milan, telephone +39 02 7632031 and email email@example.com
2. Browsing data
The computer systems and procedures used to run the Site automatically acquire, in the course of their normal operation, some personal data not relating to the user’s browsing history, including environmental variables. This category of data includes, but is not limited to:
- The IP addresses of the computers used by service users;
- The number of visits;
- The pages viewed;
- The date and time of the visit;
- The URL where the browser was before viewing our page;
- The browser used;
- The operating system used.
Except as specified below, merely visiting the Site and its sections does not entail the processing of the User’s personal data.
3. What are Cookies
Cookies are strings of text that the websites ( “publishers”, or “first parties”) visited by the user or other sites or web servers ( “third parties”) install and store – directly, in the case of publishers, and indirectly, i.e. through publishers, in the case of “third parties” – on a terminal device available to the same user.
Different kinds of cookies are stored for different amounts of time and can therefore be classified according to their duration, i.e. subjectively. In this way, it is possible to distinguish between:
- persistent cookies, i.e. cookies that remain stored, until they expire, on the user/visitor’s device. They are used to make it easier to browse the Site and to use it correctly, to facilitate access to services that require authentication, and for statistical purposes, to know which areas of the Site have been visited and, in some cases, to optimise management of pages and advertising spaces or to deliver content and advertising in line with the choices made by visitors.
- session cookies, i.e. cookies that are not stored persistently on your device and disappear when you close the browser. They are used to transmit the session identifiers necessary to enable a secure and efficient Site visit.
- first-party cookies, i.e. those generated and managed directly by the site manager. They may be either persistent or session cookies.
- third-party cookies, i.e. those generated and managed by third parties other than the Controller and external to the Site. They may be either persistent or session cookies.
In addition, cookies can also be classified according to their processing purposes. In this way, it is possible to distinguish between:
- technical cookies, i.e. cookies used for the sole purpose of ‘sending a communication over an electronic communications 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’ (see Article 122(1) of the Privacy Code). Technical cookies are necessary and help to make a website usable by enabling basic functions such as page navigation and access to protected areas of the site. The Site cannot function properly without these cookies.
- statistics cookies, i.e. cookies that collect information, in aggregate form, on the Site Users. They are similar to technical cookies provided that: (i) they are only used to produce aggregate statistics and in relation to a single website or mobile application only; (ii) at least the fourth component of the IP address is concealed for third-party cookies; (iii) third parties refrain from combining analytics cookies, which are therefore minimised, with other types of processing (customer files or statistics of visits to other sites, for example) or from sharing them with other third parties (although third parties may produce statistics with data relating to multiple domains, websites or apps attributable to the same publisher or business group). However, the Controller retains the right to carry out, on its own behalf, simple statistical processing of data relating to the Site and to multiple domains, websites and apps attributable to it, even using unencrypted data, as long as the purpose limitation requirement is met;
- profiling (or non-technical) cookies, i.e. cookies used to link specific actions or recurring habits in the use of the functions offered (patterns) to specific identified or identifiable subjects, in order to group the different profiles into clusters of different sizes, making it possible to tailor the provision of the service in an even more personalised way and to send targeted advertising, in line with the preferences shown by the user while browsing the web.
4. Cookies used by the Site and their purposes
The Site uses the following technical, statistical (similar to technical) and profiling cookies:
|Type of Cookie||Cookie Name||Provider||Purpose||Duration|
|Technical||wp-wpml_current_language||First party||Collects data on the language used in the user’s browser.||Session|
|Non-technical||_gat||Analytics Used by Google Analytics to limit the number of requests.||1 minute|
|Non-technical||_gid||Analytics Records a unique ID to generate statistical data on how the visitor uses the website.||24 hours|
|Non-technical||_ga||Analytics Used to distinguish unique users.||2 years|
The installation of non-technical cookies is subject to the User’s prior consent, which is given by clicking, in the banner either: (i) the “Accept All” button, or (ii) the “Accept Selected” button after having selected the “Statistics and Analysis” option in the list of individual cookie categories. If the User (i) closes the banner without making any selection, (ii) selects “Decline” or (iii) selects “Accept Selected” without having enabled “Statistics and Analysis”, non-technical cookies, including those of Google Analytics, will not be installed on the User’s computer and the User may continue to visit the Site with the default settings, which provide for the exclusive use of technical cookies.
By merely scrolling or browsing the Site, you do not give your consent to the use and installation of tracking tools, with the sole exception of technical cookies.
You may change your cookie preferences at any time. Each page of the Site contains the heading “Cookie preferences” in the footer. If you click on it, you open the banner to give consent for cookies and you may change your preferences at any time.
The Site may ask you to select your cookie preferences again:
- when one or more conditions of the processing significantly change and, therefore, the banner also meets a specific and necessary informational purpose precisely with regard to any such changes;
- when it is impossible for the publisher to know whether a cookie has already been previously stored on the device in order to be transmitted again, when you return to the website that generated it (for example, if you delete the cookies legitimately installed on your device without the publisher having any way of keeping track of your wish to maintain the default settings and thus to continue browsing without being tracked);
- when at least six months have elapsed since the last time the banner appeared.
As indicated in the table above, the Site uses analysis and performance cookies from Google Analytics, the installation of which is subject to the User’s prior consent, since these are non-technical cookies as defined in the “Guidelines for cookies and other tracking tools – 10 June 2021”. These cookies make it possible to collect information on how Users use the Site in order to carry out statistical analyses, on an aggregate basis, on the number of users and how they browse the Site.
With regard to the non-technical cookies of Google Analytics, the Controller implements the appropriate tools to reduce their ability to identify users, which includes masking significant portions of IP addresses, using the anonymisation tool offered by Google and better described at the following link https://support.google.com/analytics/answer/2763052?hl=it.
The information generated by Google Analytics cookies about your use of the Site will be transmitted by your browser to and stored on servers at Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The installation of Google Analytics cookies will therefore result in the transfer of your data, including personal data, to the United States, outside the territory of the European Union.
Under current EU law, the United States is a third country that does not provide an adequate level of protection under Article 45 of the GDPR and does not offer a similar level of data protection and protection of data subjects’ rights as within the EU. In particular, data, including personal data, collected by Google and relating to data subjects residing in the EU territory will be accessible by the Federal Public Security Agencies of the US Government.
When you give your consent to the installation of non-technical cookies by clicking on (i) the “Accept All” button of the cookie banner or (ii) the “Accept Selected” button after selecting and enabling the “Statistics and Analysis” option, you acknowledge this circumstance and expressly accept and authorise the personal data collected by the non-technical cookies of Google Analytics to be transferred to the United States pursuant to Article 49, para. 1(a) of the GDPR.
5. Legal basis of processing
5.1 Legal basis of the processing of data collected via technical and statistics (similar to technical) cookies
Technical cookies are necessary and help make the Site user-friendly by enabling basic functions such as page navigation and access to protected areas of the site. The Site cannot function properly without these cookies. The processing of personal data collected by means of technical cookies is based on the Controller’s legitimate interest and does not require your prior consent, since without such processing the Site could not be made available in full working order.
Your prior consent is not necessary for statistics cookies that collect information, in aggregate form, on the Site Users and cookies that are similar to technical cookies, in compliance with the “Guidelines for cookies and other tracking tools” adopted by the Italian Data Protection Authority on 10 June 2021, as no personal data are collected.
5.2 Legal basis of the processing of data collected via non-technical cookies
Pursuant to Article 122 of Legislative Decree No. 196/2003, the only legal basis for the processing of data collected via first-party or third-party non-technical cookies is your express, free and informed consent, to the exclusion of any other legal basis.
Consent is optional for all non-technical cookies. Failure to provide it will prevent the processing of the relevant personal data and will only make it impossible for the Controller to provide a personalised service.
You may give or withhold your consent to the use of non-technical cookies for the purpose of analysing Site performance or for profiling purposes in the specific banner displayed when you first access the Site.
The legal basis of the transfer of personal data to the United States, inherent in the use of Google Analytics cookies, is your express, free and informed consent pursuant to Article 49, para. 1(a) of the GDPR.
6. Deleting Cookies
Since cookies are normal text files, they can be accessed using word processing programmes. In any event, you may set your own device’s browser so that it accepts/declines all cookies or displays a warning each time a cookie is proposed, so you can decide whether or not to accept it.
If you set your browser to decline cookies, the quality of the Site pages you visit may be reduced and your browsing experience may be less enjoyable.
Below are links to the main browsers containing instructions on how to manage cookies:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=it;
- Mozilla Firefox: https://support.mozilla.org/it/kb/protezione-antitracciamento-avanzata-firefox-desktop;
- Internet Explorer: https://support.microsoft.com/it-it/windows/eliminare-e-gestire-i-cookie-168dab11-0753-043d-7c16-ede5947fc64d;
- Safari: https://support.apple.com/it-it/guide/safari/sfri11471/mac.
Google Analytics allows users to disable cookies by installing the opt-out tool provided by Google on their browser. This tool is available and can be downloaded at the following link https://tools.google.com/dlpage/gaoptout.
7. Third-party plug-ins
The Site features buttons for sharing content via social networks or other communication tools, such as Facebook, Linkedin and Youtube.
Pages containing such buttons do not generate first-party nor third-party cookies. However, by clicking on these buttons, you will be redirected to third-party sites and/or platforms – which are not available to or managed by the Controller – that may install cookies or other tracking tools on your device.