COOKIE POLICY
1. General information
This Cookie Policy is issued by OMGM Group S.r.l. (hereinafter, the “Data Controller”), as data controller pursuant to Articles 12 and 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 (hereinafter, the “GDPR”), Legislative Decree No. 196 of 30th June 2003, as amended by Legislative Decree No. 101 of 10th August 2018 (hereinafter, the “Privacy Code”), including Article 122 thereof, and in accordance with the guidelines on cookies and other tracking tools issued by the Italian Data Protection Authority on 10th June 2021, Provision No. 231, web doc. No. 9677876.
This Cookie Policy applies exclusively to the website https://omgmgroup.com (hereinafter, the “website”) and does not apply to any third-party websites that may be accessed through links on the website.
2. Data Controller
OMGM Group S.r.l.
VAT No.: 00518881206 – Tax Code: 00616350377
Telephone: +39 0542 641003
For any communication relating to this Cookie Policy, the data subject may contact the Data Controller using the contact details indicated above or at the e-mail address published on the website in the “contacts” section.
3. About cookies
Cookies are small text files that are stored on the user’s device, such as a computer, smartphone or tablet, when the user visits a website, and are subsequently sent back to the same website during future visits. Cookies allow the website to recognise the device and store certain information, such as browsing preferences, authentication status and consent choices.
In addition to cookies in the strict sense, this document also describes similar tracking tools, such as tracking pixels and third-party scripts, which may be used on the website.
4. Cookie categories used by the website
4.1 Technical cookies, first-party
Technical cookies are necessary for the proper functioning of the website and for the use of its content. They do not collect personal data for profiling purposes and do not require the data subject’s consent, without prejudice to the obligation to provide adequate information. Pursuant to the guidelines of the Italian Data Protection Authority of 10th June 2021, this category includes:
- session cookies, which enable browsing and expire when the browser is closed;
- preference cookies, which store the user’s choices, such as language or layout, for the current session or for subsequent visits;
- consent cookies, which record the consent status expressed by the data subject through the cookie banner, preventing the same banner from being displayed again each time they access the website. This type of technical cookie is specifically provided for and permitted by the aforementioned guidelines.
4.2 Third-party analytics cookies, treated as technical cookies
The website may use web traffic statistical analysis tools, such as Google Analytics, provided by Google LLC, configured in accordance with the guidelines of the Italian Data Protection Authority, namely with IP address anonymisation and limited sharing of analytics data. In this configuration, analytics cookies are treated as technical cookies and do not require prior consent.
The data subject is invited to consult Google’s privacy policy at the following address: https://policies.google.com/privacy.
4.3 Third-Party cookies: YouTube Embeds, Google LLC
The website may include videos from YouTube, a platform owned by Google LLC, a company based in the United States. Access to YouTube content is subject to the data subject’s prior consent through a dedicated preventive blocking mechanism, known as Content Blocking, which is already implemented on the Website. Once consent has been given, Google LLC may place third-party cookies on the user’s device.
These cookies may collect data relating to the user’s browsing behaviour, including IP address, unique device identifiers, pages viewed and interactions with videos, and are managed by Google in accordance with its own privacy policies. The processing involves the transfer of personal data to the United States. Such transfer takes place on the basis of the EU-US Data Privacy Framework, adopted by the European Commission through its adequacy decision of 10th July 2023, pursuant to Article 45 of the GDPR.
The Data Controller does not have direct access to the data collected by YouTube/Google through such cookies.
The data subject is invited to consult:
- Google privacy policy: https://policies.google.com/privacy
- Google Cookie Policy: https://policies.google.com/technologies/cookies
- Google ads settings: https://adssettings.google.com
5. Cookie overview
The following table provides an overview of the main cookies detected or potentially activated while browsing the website.
*The cookie names indicated by way of example may vary following technical updates to the website or to third-party platforms. The Data Controller undertakes to keep this table updated periodically.
6. Legal basis for processing
Pursuant to Articles 6 and 7 of the GDPR, and in accordance with Directive 2002/58/EC, the “ePrivacy Directive”, as implemented by Legislative Decree No. 196/2003:
- technical cookies and analytics cookies treated as technical cookies: the processing is based on the legitimate interest of the Data Controller pursuant to Article 6(1)(f) of the GDPR and does not require prior consent;
- third-party cookies, embedded YouTube content, non-anonymised analytics cookies and marketing cookies: the processing is subject to the data subject’s prior, freely given, specific, informed and unambiguous consent, pursuant to Article 6(1)(a) of the GDPR and the Guidelines of the Italian Data Protection Authority of 10 June 2021. The website has implemented a prior blocking mechanism for third-party content, known as Content Blocking, in compliance with this requirement.
7. Consent and withdrawal
When accessing the website, the data subject is informed through a dedicated banner and may choose to:
- accept all cookies, including both technical and non-technical cookies;
- reject non-technical cookies, allowing only the installation of strictly necessary cookies;
- make a granular choice by cookie category, by accessing the detailed preferences.
The consent given shall remain valid for a maximum period of 6 months, after which the banner will be displayed again. The data subject may modify or withdraw their choices at any time by accessing the cookie preference management panel, available through the dedicated link in the Website footer.
Please note that the withdrawal of consent shall not affect the lawfulness of any processing carried out before such withdrawal, pursuant to Article 7(3) of the GDPR.
8. Managing cookies through browser settings
Regardless of the preferences expressed through the cookie banner, the data subject may control the installation and storage of cookies directly through their browser settings. Instructions for the main browsers are provided below:
- Google Chrome: https://support.google.com/chrome/answer/95647
- Mozilla Firefox: https://support.mozilla.org/kb/cookies-information-websites-store-on-your-computer
- Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471
- Microsoft Edge: https://support.microsoft.com/windows/microsoft-edge-browsing-data-and-privacy
- Opera: https://help.opera.com/en/latest/web-preferences/#cookies
Please note that disabling technical cookies, either fully or partially, may affect the usability of the website and the availability of certain services.
9. Transfers of data to third countries
As indicated in Section 4.3, the activation of YouTube/Google cookies involves the transfer of personal data to the United States. Such transfer takes place on the basis of the European Commission adequacy decision relating to the EU-US Data Privacy Framework, adopted by Implementing Decision of 10 July 2023, pursuant to Article 45 of the GDPR. Google LLC is certified under the EU-US Data Privacy Framework.
The data subject may verify Google’s certification under the Data Privacy Framework at the following address: https://www.dataprivacyframework.gov.
10. Data retention
Personal data collected through cookies shall be retained for the period strictly necessary to achieve the purposes set out in this Cookie Policy, in compliance with the storage limitation principle referred to in Article 5(1)(e) of the GDPR. The retention period of each cookie is indicated in the table set out in Section 5.
11. Rights of the Data Subject
With respect to personal data processed through first-party cookies, the data subject may exercise the rights provided for under Articles 15 to 22 of the GDPR, namely:
- right of access, Article 15 of the GDPR: the right to obtain confirmation as to whether or not personal data concerning them are being processed and to access such data;
- right to rectification, Article 16 of the GDPR: the right to obtain the rectification of inaccurate personal data;
- right to erasure, “right to be forgotten”, Article 17 of the GDPR: the right to obtain the erasure of personal data in the cases provided for by law;
- right to restriction of processing, Article 18 of the GDPR;
- right to object, Article 21 of the GDPR: the right to object to processing based on legitimate interest;
- right to data portability, Article 20 of the GDPR, where applicable;
- right to withdraw consent at any time, Article 7(3) of the GDPR, without affecting the lawfulness of processing based on consent before its withdrawal.
Requests must be addressed to the Data Controller using the contact details indicated in Section 2. The Data Controller shall respond within 30 days of receipt of the request, save for any extension in cases of particular complexity, pursuant to Article 12(3) of the GDPR.
The data subject also has the right to lodge a complaint with the Italian Data Protection Authority, www.garanteprivacy.it, pursuant to Article 77 of the GDPR.
12. Updates to this Cookie Policy
The Data Controller reserves the right to amend this Cookie Policy at any time, in particular as a result of regulatory changes, technical updates to the Website or the introduction of new tracking tools. Any amendments will be published on the Website, together with the date of update. Users are therefore advised to consult this page periodically.
13. Reference Legislation
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, GDPR;
- Legislative Decree No. 196 of 30 June 2003, as amended by Legislative Decree No. 101 of 10 August 2018, Privacy Code;
- Directive 2002/58/EC of the European Parliament and of the Council, ePrivacy Directive;
- Guidelines of the Italian Data Protection Authority on cookies and other tracking tools, Provision No. 231 of 10 June 2021, web doc. No. 9677876;
- EDPB Guidelines 05/2020 on consent under Regulation (EU) 2016/679, version 1.1, adopted on 4 May 2020;
- European Commission Implementing Decision of 10 July 2023 on the EU-US Data Privacy Framework.