Cookies

PRIVACY policy

ON THE SUBJECT OF THE PROTECTION OF PERSONAL DATA PURSUANT TO ART. 13 OF LEGISLATIVE DECREE No. 196/2003

Pursuant to and by effect of the provisions of art. 13 of Legislative Decree no. 196 of 30 June 2003, the Data Controller, the company The European House - Ambrosetti S.p.A. with registered office in (20149) Milan (MI), via Francesco Albani, 21, informs the users of the website www.ambrosettilive.eu about their personal data processing and use, the scope of communication and dissemination and the nature of data providing.

PROCESSED DATA

Navigation data:

During normal operation, the computer systems and software procedures utilised in the operation of this website gather some personal information whose transmission is implicit in the use of Internet communication protocols.

This information is not gathered for the purposes of association with identified Data Subjects, but by its very nature it could be processed and associated with other data held by third parties, leading to the identification of the users.

This data category includes IP addresses and domain names of the computers employed by users connecting to the website, addresses in URI (Uniform Resource Identifiers) notation, the resources requested, the time of the request, the method used to submit the request to the server, the size of the response file received, the numerical code indicating the status of the response given by the server (OK, error, etc.) and other parameters concerning the user's operating system and computer environment.

The data collected may be used to ascertain responsibility in the event of computer crimes against the website.

Data provided directly by users

The data optionally, explicitly and voluntarily sent as requested in the various sections of this website are used to process the user's requests (including but not limited to: requests for information or clarifications, by phoning the numbers given on the website or writing to the e-mail addresses given).

Any specific privacy policy information is given or displayed on the web pages presenting services available on request, in order to draw the Data Subject's attention to the processing of his/her personal data.

NATURE OF DATA PROVIDING

With the exception of navigation data required to process computer and remote protocols, data users are free to provide their personal data if they wish. However, if the data is not provided it will not be possible to process the requests forwarded or which users intend to forward.

PROCESSING METHODS

Data are processed in paper and computerised form. The data are kept on the company servers in electronic files and users can rest assured that the minimum security measures prescribed by law are duly observed.

Cookies and other technologies

WHAT ARE COOKIES?

A "cookie" is a small text file created by certain websites on the user’s computer when the user accesses a site, for the purpose of storing and transmitting information. The cookies are sent by a web server (which is the computer on which the website visited is running) to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) and stored on the latter’s computer; they are then re-sent to the website during the user’s subsequent visits to the website.

WHY AND WHAT TYPE OF COOKIES ARE USED?

Cookies serve to carry out IT authentications, to monitor sessions and store specific information on the users that access the website, and they usually exist in large quantities in users’ browsers.

Some operations could not be performed without the use of cookies which, in certain cases, are, therefore, technically necessary. In other cases, the site uses cookies to facilitate and streamline navigation by the user or to allow the said user to use specifically requested services.

The cookies can remain in the system for long periods of time and can also contain a unique identification code. This enables the websites that use them to track the navigation of the user inside the website itself, for statistical or advertising purposes, in order to create a personalised profile of the user based on the pages visited and show or send him/her targeted advertising messages (so-called Behavioural Advertising).

WHAT COOKIES ARE USED BY THE WEBSITE WWW.AMBROSETTILIVE.COM AND WHY?

The European House - Ambrosetti S.p.A. uses various types of cookies in order to:

  • enable the user to move smoothly from one page of the website to the next.

  • store the user’s name and any preferences entered.

  • free the user from having to enter the same information (such as user name and password) several times during his/her visit to the website.

  • measure the use of the services by the users in order to optimise the navigation experience and the services provided.

  • better understand users’ behaviour, discovering which parts of the website have been visited, facilitating and measuring the effectiveness of promotions (e.g. for up-and-coming events) and web searches.

These aims are pursued by The European House - Ambrosetti S.p.A. through the use of their own cookies and third party cookies, both temporary and persistent, as described below.

Temporary cookies or so-called Flash cookies

The use of so-called session cookies (cookies that are not stored in the user’s computer in a persistent manner and which disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) in order to allow the safe and efficient exploration of the website.

Persistent cookies

These are text files left by the websites visited which are stored on the user’s computer and remain there even after the user has exited the website. Persistent cookies perform a number of different functions: they make it possible to store certain information (such as passwords) or to personalise the pages that the user has browsed (e.g. wish list).

The persistent cookies used by The European House - Ambrosetti S.p.A. fall into two different categories:

• anonymous cookies – these are used for the purpose of allowing personalisation of the user’s web surfing and in order to improve the navigation of the website. This type of technology makes it possible to gather and register, anonymously, information on the web pages consulted. Data collected in this way cannot identify the visitor and are not combined with any other information (such as the personal data supplied by the user during registration). These data are used exclusively to track and analyse the use of websites by users, and to compile statistics based on the information gathered anonymously and through the use of data in aggregate form, for which the user’s consent is not required.

• identifying cookies – these allow the identification of the person by cross-checking with the database containing the data supplied voluntarily by the users, e.g. to register on the website or for specific services. They can be used for various different purposes, e.g. to speed up user access to reserved areas, freeing him/her from the obligation to enter user ID and password manually.

The cookies used by the website http://www.ambrosettilive.com/ are listed below

NOME COOKIES

DESCRIZIONE

Durata

Scopo

ambrosetti

The cookie stored on the user's PC is a reference to the file that is saved on the server. In the file saved on the server is the username of me keep the session active more useful information for the proper use of the site

Session only

Maintaining profile

login_type

By what method the user is authenticated

30 days

Recognition method login

cc_cookie_accept

It tracks whether the user has authorized the saving of cookies

45 days

Not propose to every access the acceptance of cookies

To all effects and purposes, the cookies used by the company fall into the following categories:

• Strictly necessary cookies. These are cookies that are necessary for the operation of the website, since their purpose is to transmit a message on an electronic communications network, or to provide a service explicitly requested by the user.

• Analysis/performance cookies. These cookies make it possible to personalise the user’s web surfing and facilitate the navigation of the website. This type of technology makes it possible to gather and register, anonymously, information on the web pages consulted. The data thus collected in anonymous and aggregate form do not allow user identification or profiling.

• Functionality cookies. These cookies are used to remind the user of given operations, to automate login procedures or to personalise site access and navigation.

What third party cookies are used?

The use of (temporary and persistent) third party cookies by the Data Controller’s website is exclusively anonymous and for the sole purpose of being able to use the web analysis services provided by third parties. These cookies are used to gather and record information, anonymously, on the pages of the website consulted, but they cannot identify visitors, and are not combined with other information in any way. The data are used exclusively to track and analyse the use of websites by users, and to compile statistics based on the information gathered anonymously and through the use of data in aggregate form. In particular, we inform users that the web analysis service releasing cookies used by the Data Controller is "Google Analytics", described below.

Google Analytics is a web analysis service supplied by Google, Inc. ("Google") which uses "cookies", deposited on the user's computer to allow the visited website to analyse how users use them. The information generated by the cookie on the use of the websites visited by the user (including the IP address) is sent to Google, and deposited on the Google servers in the United States. Google will use this information to track and analyse the use of the website by the users, compile reports on the website activities for the website operators and provide other services concerning the website activities and the use of the Internet. Google may also transmit this information to third parties where required by law or if these third parties process the above-described information on behalf of Google. Google will not associate the users' IP addresses to any other data possessed by Google. Users may refuse to use the cookies at any time by selecting the appropriate setting in their browser.

Using this website, users agree to the processing of their data by Google in the above-mentioned methods and purposes. To consult the Google privacy policy information for the Google Analytics service, please refer to the website http://www.google.com/intl/en/analytics/privacyoverview.html.

IS CONSENT TO THE USE OF COOKIES REQUIRED?

The user’s consent is not requested in cases in which the use of the cookies or other devices stored in the terminals of the users or contracting parties serves exclusively for technical purposes or when it responds to specific requests of the user or of the contracting party for an Internet service.

By way of example – as clarified also by the Working Party set up under "Article 29" in opinion WP194 and by the Italian Antitrust Authority for the protection of personal data in the FAQ on cookies – the cookies for which it is not necessary to obtain the user’s prior, informed consent are:

• cookies implanted in the terminal of the user/contracting party directly by the Data Controller of the individual website if not used for other purposes: this is the case of session cookies which are used for authentication, for multimedia contents such as Flash Player if they do not exceed the duration of the session, personalisation cookies (e.g. the choice of browsing language), etc.;

• cookies used for statistically analysing the accesses/visits to the site (so-called "analytics") if they are used exclusively for statistical purposes and gather information in an aggregate form.

Apart from these cases, as provided for by art. 122 of Legislative Decree no. 196/2003, the filing of the information in the computer terminal of a contracting party or a user, or the access to information already filed, is only permitted if the said user has expressed his/her consent in this regard. So, if necessary, the user will be asked to provide his/her authorisation through systems used for this purpose by the company.

In particular, we inform users that, like the majority of websites, we collect certain data automatically and file it in log files. These data include the version of the operating system and browser type used, referring and exit pages, date and time and clickstream data. We use these data to understand and analyse trends, to manage the site and to become acquainted with the behaviour of users in websites.

We specify that in some cases the contract-holder Company finances subscription costs through access to Interprofessional Funds. In these cases it is necessary to record all of the user’s interaction activities with the sites and, if a distance training programme is contemplated, also all the data relating to the viewing of videos (e.g. start/end of viewing, intermediary activities such as pauses, the moving of the cursor along the video timeline etc.). The user cannot ask for this information not to be recorded. The only way to do this is to cancel his/her subscription to the Service.

SOCIAL BUTTONS

The website has special "buttons" (called “social buttons/widgets”) with social network icons (e.g. Twitter). These buttons allow users browsing the website to interact with the social networks indicated with a simple “click”. In this case the social network acquires the data concerning the user's visit, while the Data Controller will not share any navigation information or user's data acquired through its own websites with the social networks that are accessible via the Social buttons/widgets.

COMMUNICATION AND DISSEMINATION

The data collected will not be disseminated, sold or exchanged with other third parties without the express consent of the Data Subject, unless such disclosure is required to perform the requested service. The data may also be transmitted to the competent authorities where required by law.

RIGHTS OF THE DATA SUBJECT

The Data Subject may exercise his/her rights as expressed in articles 7, 8, 9 and 10 of Legislative Decree no. 196 of 30 June 2003, by contacting the Data Controller. In particular, in accordance with art. 7, the Data Subject has the right to obtain confirmation of the existence or otherwise of personal data concerning him/her - even if not yet recorded - and the communication of the same in an intelligible form. The Data Subject has the right to obtain information regarding: a) the origin of the personal data; b) the purposes and methods used for processing them; c) the logic applied if the data is processed using electronic systems; d) the identity of the Data Controller, the data processors and the designated representative pursuant to art. 5, paragraph 2; e) the parties or categories of parties to which the personal data may be communicated or who may gain knowledge of them in their capacity as designated representative within national territory, data processors or authorised users. The Data Subject has the right to obtain: a) the updating, correction or – when interested – the integration of the data; b) the deletion, transformation into anonymous form or blocking of any data processed unlawfully, including any data which need no longer be kept for the purposes for which they were collected or subsequently processed; c) a statement that the operations mentioned under the letters a) and b) were notified, also with regard to their content, to those to whom the data were transmitted or disseminated, except for cases in which such a fulfilment is impossible or entails use of means that are clearly disproportionate to the right protected. The Data Subject has the right to oppose, either totally or in part: a) for legitimate reasons, the processing of personal information involving him/her, even though such information pertains to the reason it was gathered; b) the processing of personal information involving him/her for the purposes of sending advertising or direct marketing material, or for carrying out market research or business communication.

DATA CONTROLLER

The Data Controller is The European House - Ambrosetti S.p.A., with registered office in (20149) Milan (MI), via Francesco Albani, 21, acting through the CEO, Valerio De Molli. For any communication pursuant to art. 7 et seq. of Legislative Decree no. 196/2003 and subsequent amendments and additions, it is possible to write to the Data Controller at the following address: privacy@ambrosetti.eu.