Cookie Policy

This policy describes the use of cookies and similar technologies on the website www.nexaura.it (the “Site”), operated by Nexaura S.r.l. (“Nexaura” or “we”) as data controller. It has been drawn up in accordance with Article 122 of Italian Legislative Decree 196/2003 (the Personal Data Protection Code, as amended by Legislative Decree 101/2018, the “Italian Privacy Code”), which implements Article 5(3) of Directive 2002/58/EC, as amended by Directive 2009/136/EC. It also takes into account Regulation (EU) 2016/679 (GDPR) and the “Guidelines on cookies and other tracking tools” adopted by the Italian Data Protection Authority (Garante) on 10 June 2021.

This policy supplements the Privacy Policy, which describes in detail the processing of personal data carried out through the Site, the rights of data subjects and the identification details of the controller.

In brief

• The Site uses no profiling or marketing cookies and no third-party analytics tools.
• Only strictly necessary technical cookies set by the hosting provider may be present: for this reason no consent banner is displayed.
• Cookies can in any case be inspected and deleted through the browser settings (section 7).

This summary is provided for clarity and does not replace the full policy set out below.

1. What cookies and similar technologies are

Cookies are short text files that a website sends to the user’s device (computer, tablet, smartphone), where they are stored by the browser so that they can be sent back to the site on the next visit. They serve, for example, to keep a session active, to remember browsing preferences or to recognise the device over time.

Technologies with an equivalent function are subject to the same rules: local browser storage (local storage and session storage), tracking pixels and device identifiers, as well as fingerprinting techniques; the latter make it possible to recognise the user or the device without storing any information on the terminal.

Cookies are classified according to who installs them and how long they last:

• first-party cookies: installed directly by the operator of the website visited;
• third-party cookies: installed by a different domain, generally through content or scripts embedded in the page (maps, videos, social buttons, statistical tools);
• session cookies: deleted automatically when the browser is closed;
• persistent cookies: kept on the device until the expiry date set or until they are deleted manually by the user.

2. Categories of cookies and consent

The legislation and the Garante’s Guidelines distinguish two categories of cookies: technical cookies, for which a notice is sufficient, and profiling cookies, for which consent is required. Analytics cookies are an intermediate case: they are treated as technical cookies only under certain conditions. The rules applicable to each case, and the position of the Site, are set out below.

• Technical cookies: they enable browsing and the delivery of the service requested (session, security, load balancing, display preferences). They do not require consent: a notice is sufficient (Article 122(1) of the Italian Privacy Code). On the Site: only strictly necessary cookies, if any, as described in section 3.
• Analytics cookies: they measure traffic and page use in statistical form. They are treated as technical cookies, and therefore exempt from consent, only under the conditions set out in the Garante’s Guidelines: statistics that are exclusively aggregated and relate to that site alone; for third-party tools, masking of at least the fourth component of the IP address, no combination of the data with other processing operations and no transmission to further third parties. In all other cases consent is required. On the Site: none.
• Profiling and marketing cookies: they build user profiles and offer content or advertising messages in line with the preferences shown while browsing. They require prior consent that is freely given, specific, informed and unambiguous, expressed through a positive action (Article 4(11) and Article 7 GDPR) and revocable at any time as easily as it was given. On the Site: none.

3. Cookies and tools used by this Site

The Site is built as a set of static pages and adopts a deliberately minimal approach, consistent with the data minimisation principle (Article 5(1)(c) GDPR). In particular, the Site:

• does not use profiling cookies or marketing or retargeting tools;
• does not use third-party analytics tools (analytics cookies) or techniques for tracking the behaviour of individual visitors: any statistics on the use of the Site are derived in aggregate form from the server logs, as described in the Privacy Policy;
• does not load fonts, scripts or libraries from third-party servers: fonts are hosted directly on the Site and, during ordinary browsing, no request is sent automatically to external providers;
• does not embed third-party content such as maps, videos, sharing buttons or social widgets;
• does not store data in the user’s browser through local storage or similar technologies.

The only processing that may involve storing information on the device concerns the strictly necessary technical tools required for the operation of the infrastructure hosting the Site: any security, load-balancing or abuse-protection cookies set by the hosting provider. Such tools are not used to identify the user or to build a profile and do not require consent. [DA COMPLETARE: indicare il fornitore di hosting e verificare, sulla base della sua documentazione, se imposta cookie tecnici; in tal caso elencarli qui con nome, finalità e durata]

The contact form

The form on the Contact page installs no cookies and loads no third-party scripts. The data entered are transmitted only when the user presses the send button, in one of two ways depending on the configuration in use: to an external form management service, where activated, which delivers them to Nexaura acting as data processor; or to the user’s own email program, through a pre-filled message addressed to Nexaura, without passing through the systems of the Site. A hidden anti-spam field serves solely to discard automated submissions and collects no user data. The data collected, the purposes, the legal bases, the providers involved and the retention periods are described in the Privacy Policy.

4. Why no banner appears on the Site

A consent banner is required only where a website uses cookies or other tracking tools that go beyond technical ones. Since the Site uses no profiling, marketing or analytics cookies requiring consent, there is no banner and no mechanism for collecting preferences. This policy, which can be reached from every page through the footer, is sufficient to discharge the transparency obligations laid down by Articles 12 and 13 GDPR and by Article 122 of the Italian Privacy Code, in line with the Garante’s Guidelines.

5. Updates and future changes

We are committed to keeping this policy consistent with the actual configuration of the Site. Should we decide in future to activate analytics tools, marketing tools or third-party content entailing the installation of non-technical cookies, before activating them we will:

• update this policy, stating for each cookie the provider, the purpose, the duration and how it can be managed;
• introduce a banner compliant with the Garante’s Guidelines, allowing users to accept, refuse (including by closing the banner) or personalise their choices with equal ease, together with a link always accessible from the footer to review those choices or withdraw consent at any time.

In any event, no non-technical cookie will be installed before the user has given consent.

The date of the latest update is shown at the top of the page. Users are invited to consult this policy periodically.

6. Links to third-party websites

The Site contains links to external websites, in particular to the websites of the authorities referred to in the texts. These are simple hyperlinks: no content from those websites is loaded on the pages of the Site and no data are transmitted until the user decides to follow the link. Once a third-party site has been reached, the use of cookies and the processing of personal data are governed solely by the policies of the relevant operator, over which we have no control and which users are invited to read.

7. How to manage and delete cookies in the browser

Even in the absence of cookies requiring consent, users can at any time inspect, restrict or delete cookies through their browser settings. The functions generally available are the following: viewing the cookies stored, deleting all of them or only those of a given site, blocking third-party cookies, blocking all cookies, and setting automatic deletion when the browser is closed. In the most widely used browsers the route is broadly as follows:

• Google Chrome: Settings menu, “Privacy and security” section, “Third-party cookies” and “Site settings” items;
• Mozilla Firefox: Settings menu, “Privacy & Security” section, “Cookies and Site Data” panel;
• Microsoft Edge: Settings menu, “Cookies and site permissions” section;
• Apple Safari (macOS): Safari menu, Settings, “Privacy” tab; on iPhone and iPad: Settings, Apps, Safari (or Settings, Safari in earlier versions), “Privacy & Security” section;
• Opera: Settings menu, “Privacy and security” section, “Cookies and other site data” item.

The names of menu items may vary depending on the browser version; the official help pages of each vendor provide up-to-date instructions. Disabling technical cookies may impair the correct operation of some websites. Browsing this Site does not depend on cookies set by Nexaura; blocking all cookies could affect only the technical tools of the hosting provider referred to in section 3.

8. Data subject rights and contacts

For the exercise of the rights provided for by Articles 15 to 22 GDPR (access, rectification, erasure, restriction, objection, portability), for the procedures for lodging a complaint with the Italian Data Protection Authority (Garante) and for the identification and contact details of the data controller, please refer to the Privacy Policy and the Legal Notice. Any question about this policy may be sent to the email address shown in the footer of the Site.