
Cookie policy of the site “thdshowroom.thdlab.com“
THD S.p.A., (C.F. and VAT: 02111430357 (hereinafter “THD”), represented by its pro tempore legal representative, with registered office in Correggio (RE), via per Carpi 15/B, as Data Controller pursuant to Articles 4 no. 7) and 24 of the EU Regulation no. 2016/679 (GDPR), outlines, below, the cookie policy (“Policy”) applicable to the present website thdshowroom.thdlab.com (“Site”).
1. Legal framework reference.
1.1. The Policy is inspired by the following regulatory provisions (first and/or second level) at the community and/or national levels: (i) Directive no. 2002/58/EC of 12.7.2012 (known as the ePrivacy Directive), as amended by Directive no. 2009/136/EC; (ii) Article 122 of the amended Legislative Decree no. 196/2003 (Privacy Code), which has transposed, into the national legal system, the ePrivacy Directive; (iii) GDPR: Articles 4 no. 11), 7, 12, 13, 25 and 95 (furthermore, particularly considering Recitals no. 30, 32, and 173); (iv) Guidelines no. 5/2020 adopted on 4.5.2020 by the EDPB, replacing the Guidelines of 10.4.2018 by WP Article 29; (v) Measure no. 231 of 10.6.2021 [web doc no. 9677876] by the Data Protection Supervisor (Privacy Authority); (vi) Recommendation no. 2/2001 by WP Article 29; (vii) Opinion no. 2/2010 by WP Article 29; (viii) Opinion no. 4/2012 by WP Article 29; (ix) Guidelines no. 8/2020 by the EDPB; (x) Guidelines no. 8/2020 by the EDPB; (xi) Measures no. 224 of 9.6.2022 [web doc no. 9782890], no. 243 of 7.7.2022 [web doc no. 9806053] and no. 254 of 21.7.2022 [web doc no. 9808698] by the Privacy Authority.
2. Cookies and other tracking tools: definition and classification.
2.1. The “cookies”1 are typically text strings that a website (“publisher” or of the “First party”) visited by the user or a different website (of the “third party”) places and stores, directly (in the case of the First party website) or indirectly (through the latter, in the case of a third party website), within a terminal device available to the same user: regarding this, the Privacy Authority specified that the information encoded in cookies can include both personal data pursuant to Article 4 no. 1) of the GDPR (e.g., IP address; username; email address; unique identifier) and non-personal data pursuant to Article 3 no. 1) of EU Regulation no. 1807/2018 (e.g., language; type of device used).
Alongside (or beyond) these, there may exist (and, therefore, be used) the “other tracking tools”, which can be divided into “active” (that possess almost the same characteristics as cookies) and “passive” (e.g., fingerprinting).
2.2. Beyond the described intrinsic characteristics, cookies (and other tracking tools) can record different peculiarities in terms of temporality (and thus be considered as “session”2 or “permanent”3, depending on their duration), from a subjective point of view (depending on whether the publisher acts autonomously or on behalf of a “third party”) and, finally (but particularly), based on the processing purpose pursued, so as to be divided into two different (macro) categories:
“technical”, used solely “to carry out the transmission of a communication over an electronic communications network, or as strictly necessary to the provider of an information society service explicitly requested by the subscriber or user to provide such service” (Article 122 paragraph 1) of the Privacy Code). On this regard, the Privacy Authority highlighted, in Measure no. 231 of 10.6.2021 (consistently with the previous Measure on the subject from 2014), that “cookie analytics”4 can well be included within the scope of “technical” cookies (or other tracking tools) (and, therefore, may be used without the prior acquisition of consent from the concerned data subject), subject to certain conditions aimed at precluding the possibility of directly identifying the concerned data subject (single out)5.
“profiling”/“marketing” (known as non-technical), used to trace determined, identified or identifiable subjects, specific actions or recurring behavior patterns in the use of offered functionalities (pattern) for the purpose of grouping different profiles within homogeneous clusters of varying size, so that the Data Controller can, among other things, also modulate the provision of the service in a more personalized manner beyond what is strictly necessary for the provision of service, as well as send targeted advertisements (i.e., in line with preferences expressed by the user during web browsing).
3. Cookies installed on the Site.
3.1. Within the Site, the following types of cookies have been installed:
1 year
Analytic