INFORMATION

Cookie Policy

Dear Visitor (hereinafter, “You” or the “User”),

This Internet website (https://www.suntimes.it/); hereinafter, the “Website”) is owned by Sun-TIMES S.r.l., with registered offices in Via Giosuè Borsi, 9, 20143 Milan MI, Tax Code/VAT No. 01231370113 (hereinafter, “We” or the “Company”).

Since our Website uses the so-called cookies for several purposes, we hereby aim at explaining to You what cookies are and how they are used on the Website.

Certain cookies (the so called proprium cookies or first party cookies) are conveyed and controlled by us directly.  The Company collects and processes your personal data by means of these cookies.  We hereby explain to You how We collect such data, for which purposes and what your rights are, also pursuant to Article 13 of the General Data Protection, Regulation (EU) 2016/679 (the “Regulation”) and Italian Legislative Decree No. 196/2003 (hereinafter, “Privacy Code” and, together with the Regulation, “Applicable Law”).

To the contrary, other cookies (the so called third-parties cookies) are conveyed and controlled by third parties. This policy includes links to the policies published by such third parties.  We hereby invite you to read such policies carefully.

If You are not familiar with cookies, please read carefully this policy and the general privacy policy of the Website, in order to make your choices consciously. 

The Company takes the utmost account of the right to privacy and protection of personal data of its Users. For any information related to this Cookie Policy, Users may contact the Company at any time, using the following methods:

  • sending a registered letter with return receipt to the registered offices of the Controller, as indicated above;
  • sending an electronic mail message to the address contabilita@sun-times.it

The Users may also contact the Data Protection Officer (DPO) appointed by the Controller at the following e-mail address: dpo@suntimes.it.

  1. What cookies are and what they are for

The cookies are small text files that the websites visited by a user send directly to its terminal (usually, to the browser), where they are memorised to be transmitted to the same websites at the following visit of the same by the same user (the so called proprium first-party cookies). During the web surfing of a website, a user may receive on its terminal also cookies of other websites or of other web servers (the so called third-parties cookies); this happens because there may be elements on the visited website, such as images, maps, sounds, links to specific web pages of other domains that are on servers other than the server on which the requested page is placed.  In other words, such cookies are set up on a website other than the one that is currently visited.

The cookies may have a duration limited to a single session of navigation on the browser (the so called session cookies), and, in such event, they deactivate automatically once the browser is closed by the user; or may have a predetermined duration and, in such event, they will remain memorised and active on your hard disk until the expiry date, thus continuing collecting information during different sessions of navigation on the browser (the so called permanent cookies).

The cookies are used for several purposes. Certain cookies are necessary in order to allow You to surf the Website and benefit of its functionalities (the so called technical cookies). Other cookies are used in order to obtain statistical information, whether in aggregate or not, about the number of users accessing the Website and how the Website is used (the so called monitoring cookies or analytics). To the end, other cookies are used in order to track your consumer profile and make You viewing advertisings that may be of interest for You, since complying with your preferences and your consumer habits (the so called profiling cookies).

In order to know more in details such different categories of cookies please continue reading such policy.  Please discover how they works and for what use they are for, and choose freely if you want to consent to their use or prevent the same.

B. The technical cookies

The technical cookies are used on the Website for the sole purpose to make You able to surf the Website and allow You to use its functionalities. They are first party cookies, since they are conveyed directly by us on the Website.

Certain technical cookies are essential to offer You an optimal surfing experience or in order to allow You to authenticate on the Website, for example in order to make a purchase on the Website or to enter into your reserved area (the so-called surfing cookies).  The surfing cookies are normally session cookies and, therefore, once the surfing browser is closed, are automatically deactivated.

The technical cookies are useful in order to allow You to memorise your preferences (for example, the language or the Country) without setting up the same at the following visits (the so-called functionalities cookies).  For such reason, the functionalities cookies are often lasting cookies, since they remain memorised on your computer also after the closure of the surfing browser, until the scheduled expiry date or until when you decide to eliminate the same.
The technical cookies currently used on the Website are listed in the table at the end of paragraph I.

As provided by the Applicable Law, your prior consent is not required for the installation of technical cookies, as referred to in paragraph B.1 above. You are free to block the installation of technical cookies by modifying the settings of your browser (read paragraph E, no. 1 to find out how to do this). However, please note that by blocking the installation of technical cookies, or subsequently deleting them, your ability to access the Website, to use all or part of it, to enable or disable certain functions or to receive certain services may be totally or partially compromised.

On the contrary, your prior consent is required for the installation of cookies and/or other tracking tools other than technical ones (such as, for example, profiling cookies). For this reason, when you access the Website, a special banner (also known as the Consent Management Platform; hereinafter, “CMP”) is displayed prominently, informing you that subject to your consent, non-technical cookies are used on the Website and that by pressing the appropriate button provided therein, you will be able to consent to the use of cookies.

Should you give your consent to the installation of cookies in this way, we will keep track of your consent by means of a technical cookie or other technical means linked to the use of CMP, which allow us to keep up-to-date records of your choices. In the latter case, the Company may process, for this purpose, metadata relating to the granular choices made by the User: the possible expression of consent, the details of the granular purposes for which the User has given consent, as well as the possible choice of the User to continue browsing by maintaining the default settings by pressing the relevant button provided by the CMP.

In this way, We will ensure that you do not see the CMP during your subsequent visits to the Website and we will keep track of your choices in line with the requirements of Applicable Law.

Please note that, if the Company uses a technical cookie or other means in order to demonstrate that it has obtained your consent and to keep a record of your choices up to date at all times, and you delete this technical cookie or other tool used for this purpose from your browser in the manner set out in paragraph E, no. 1 below, the record of your consent may be lost and, therefore, during your next visit to the Website the CMP may be displayed again. 

C. Monitoring cookies or “analytics”

The analytics are used on the Website in order to collect statistical information, whether on aggregate or not, on the number of users accessing the Website and on how the same visit the same.

The analytics cookies of this Website are third parties cookies, since they are not conveyed directly by us they are not installed directly by the Company but by third parties subjects.

Third-parties analytics cookies are installed on the Website with your prior consent, since the same are not anonymised, given that third parties can access to analytics disaggregated data at the IP address level (in other words, using these cookies, third parties could theoretically go back to your identity by means of the IP address):

The analytics currently used on the Website are listed in the table at the end of paragraph I.

Your prior consent is requested in order to install such cookies, as provided pursuant the Applicable Law. For such a reason, when you access the Website a CMP is displayed, informing you that, subject to consent, analytics cookies are used on the Website and that, by clicking on the appropriate button provided therein, You can provide your consent to the use of cookies. In the event that you express your consent to the use of cookies in this way, We will track your consent by means of a specific technical cookie.  In this way, we will avoid you displaying the CMP during your following visits of the Website. Please take into account that, in the event that you remove from your browser such technical cookie with the modalities set forth under the following paragraph E, No. 1), the track of your consent would be lost and, therefore, the CMP will be displayed again during your following visit to the Website.

You are clearly free to block the installation of analytics cookies in any moment whatsoever and this will not compromise in any manner whatsoever the possibility to visit the Website and benefit of its contents.  Please read carefully the third parties cookies policies, following the links specified in the above table, in order to know how to do it.

D. Profiling cookies

The profiling cookies are used to create a user’s profile, based on the preferences and likings showed by You during the navigation on Internet and to make You display advertisings consistent with your profile. In such way, the advertisings that You will display on our Website could be more of interest for You.

Your prior consent is requested in order to install such cookies, as provided pursuant the Applicable Law.  For such a reason, when you access the Website the CMP is displayed, informing you that, subject to consent, profiling cookies are used on the Website and that, by clicking on the appropriate button provided therein, You can provide your consent to the use of cookies. In the event that you express your consent to the use of cookies in this way, We will track your consent by means of a specific technical cookie.  In this way, we will avoid you displaying the CMP during your following visits of the Website.  Please take into account that, in the event that you remove from your browser such technical cookie with the modalities set forth under the following paragraph E, No. 1), the track of your consent would be lost and, therefore, the CMP will be displayed again during your following visit to the Website.

You are clearly free to block the installation of profiling cookies in any moment whatsoever and this will not compromise in any manner whatsoever the possibility to visit the Website and benefit of its contents.  In the event that you decide to deactivate the behavioural advertising, this does not mean that you will not receive advertisings on the Website. However, the banners that you will display on the Website could not reflect your interests or your preferences on the browser you are actually using.

Some of the profiling cookies are installed directly by the Company or are tools through which the Company collects data in its capacity as data controller or, in certain cases, joint data controller together with the provider of such cookies (as specifically indicated by the provider of the cookie in the privacy policy set out in the table in this paragraph D.1).

In addition, other profiling cookies are installed on the Website by third parties (third-party cookies).

The profiling cookies used on the Website are listed in the table at the end of paragraph I.

The Company also informs Users that Google’s AdServer may enable advertisers or other third parties to use cookies linked to advertising messages in order to collect information on the User's browsing activities.

Similarly, other partners of the Company indicated in the CMP may process the User’s personal data in order to provide advertising, including interest-based advertising. For the relevant information, please refer to the links found next to each vendor within CMP.

E. How to manage the cookies and oppose to their use

There are several options to manage, disable and remove the cookies. .

(1) Modify your browser settings
Please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies (technical, analytics and profiling):

Please be careful in making your choice.  Indeed, by blocking the receipt of all the cookies indiscriminately, including the technical ones, without providing a specific exception for the Website, you might be no more able to surf on the Website or to benefit, in whole or in part, of its functionalities.  Furthermore, removing all the cookies from the browser, also the technical cookies could be removed and, therefore, you could remove the preferences set up by using the Website or no more find products or services included in your basket.

(2) Use our interactive instruments or those provided by third parties
In order to disable the third parties cookies, please see the privacy policies of those third parties installing analytics cookies (see paragraph C above) or profiling cookies (see paragraph D above) in order to know the other instruments available to you for managing, disabling and removing cookies and, more in general, to oppose to their use.  Please be reminded that, by disabling third parties cookies, (i) you are opposing to their use not only on the Website, but on all the Internet websites on which such cookies are used and (ii) the possibility to surf on the Website and use its functionalities will not be jeopardised in any manner whatsoever. 

(3) Use the Internet website Internet www.youronlinechoices.eu/it/ 
Your Online Choices is an Internet website managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA), the Italian version of which can be found at the address www.youronlinechoices.eu. It provides information on behavioural advertising based on profiling cookies (https://www.youronlinechoices.com/uk/about-behavioural-advertising) and allows Internet users to easily opt-out of the installation of the main profiling cookies installed by advertisers and used on Internet websites (https://www.youronlinechoices.com/uk/your-ad-choices). Before using this tool, we recommend that you carefully read the general terms and conditions of service of the Your Online Choices website (https://www.youronlinechoices.com/uk/terms-conditions), as well as the frequently asked questions (FAQ) (https://www.youronlinechoices.com/uk/faqs) and the help page (https://www.youronlinechoices.com/uk/opt-out-help).

Please use Your Online Choices consciously. Indeed, notwithstanding that many of the most important marketing companies using cookies are members of the same, certain third parties installing cookies through the Website could not be members of Your Online Choices.  Therefore, the use of Your Online Choices does not guarantee that third parties cookies will be received surfing on the Website.  Please be remained that, removing all the cookies from the browser, also the technical cookies released by Your Online Choices in order to remind your choices could be removed, thus reactivating third parties cookies.

(4) Use the CMP
For the processing of personal data that, subject to the User’s consent, third party companies may carry out through cookies, the User may also use the CMP implemented on the Website, to provide or withdraw consent by following the relevant instructions.

F. Processing methods and data retention timing

As highlighted under the preamble of this cookie policy, the Company collect and process certain personal data by means of the cookies conveyed directly on the Website (first party cookies).  The Company acts as data controller of such data, in compliance with the provisions of the Regulation. Please note that we will process your data with electronic instruments only, in a much automatised manner and without any human intermediation.  Therefore, our employees and coworkers will never access the content of your personal data obtained by means of cookies, meaning that they will never be able to see and/or have any direct PII (Personally Identifiable Information), that is information from which it will be possible to identify you directly.

Certain employees of ours and coworkers, appointed by us as data persons in charge of the processing, could make maintenance operations on IT systems that host your data, without the possibility to access their actual contents. The personal data could be memorised on servers managed by third parties (for example, providers of IT systems) or may be managed by online marketing specialised subjects, acting as Data Processor on the basis of a specific written appointment by the Company. 

Your personal data will not be transferred to third parties Data Controller, nor will be disseminated.

Your personal data will be kept for the time strictly necessary to carry out the primary purposes described in this statement, or in any case as necessary for the protection of the rights of both the interests of both Users and the Company.

G. Transfer of personal data to a third country

We hereby inform you that, complying with the requirements and the guarantees provided under the law, your data could be transferred to Countries outside the European Economic Area (EEA) that could not guarantee a level of privacy and personal data protection equal to the level of protection guaranteed by the Applicable Law, but as Data Controller we take the utmost account of the right to security, therefore we will process such transfers with all due care and guarantees and, therefore, we will handle such transfers with all due care and guarantees in accordance with the Applicable Law and, in particular, in accordance with articles 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to adequate safeguards) of the Regulation.

Specifically, for the provision of the Google Analytics service (referred to in paragraph C above), the supplier of the Company, Google Ireland Limited, may transfer pseudonymous personal data of the Users outside the EEA, under the Standard Contractual Clauses or under an Adequacy Decision: in particular, towards the United States, data will be transferred on the basis of the Data Privacy Framework certification adopted by Google LLC (further information available at the following link). In consideration of the scope of the processing, the nature of the data processed and the risks of the processing, the Company has deemed suitable the additional security measures that the supplier guarantees to adopt for the protection of personal data processed on behalf of the Company itself. 

 We would like to point out that some of the third parties indicated in the tables in this privacy policy and/or in the CMP may - as independent data controllers - process personal data collected by means of the cookies installed on this Website from a location outside the European territory and, therefore, we recommend that you read their privacy policy carefully above for further details.


H. Your rights

In order to exercise your rights, or to obtain any other information or clarification in relation to this cookie policy, please contact the Company by means of:

  • sending a registered letter with return receipt to the registered offices of the Controller, as indicated above;
  • sending an electronic mail message to the address contabilita@sun-times.it

The Users may also contact the Data Protection Officer (DPO) appointed by the Controller at the following e-mail address: dpo@suntimes.it.

Pursuant to Applicable Law, the User has:

  1. the right to withdraw consent at any time, if the processing is based on their consent;
  2. the right of access to the personal data;
  3. (if it is applicable) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by automatic device), the right to restriction of the processing of personal data, the right to rectification and the right to erasure (“right to be forgotten”);
  4. the right to object:
    - in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
    - in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;

  5. if they believe that the processing that concerns them violates the Regulation, the right to lodge a           complaint with a Supervisory Authority (if a European citizen, in the Member State in which they          usually reside, in the one in which they work or in the one in which the alleged violation has 
      occurred). The Italian Supervisory Authority is the Garante per la protezione dei dati personali, 
      located in Piazza Venezia n. 11, 00187 - Rome (http://www.garanteprivacy.it/).

I. Cookie’s list