Cookie Policy

Pursuant to article 13 of the EU Reg. N. 679/2016 on the protection of personal data (“General Data Protection Regulation” or “GDPR”) and based on the provision of 10 June 2021 of the Italian Data Protection Authority on cookies SEC Newgate S.p.A. provides some information regarding the use and management of cookies installed on the website www.secnewgate.com (“Site”) and related subdomains.

DEFINITION AND TYPES OF COOKIES

Cookies are small text strings that allow a website to recognize certain information (i.e. about the device used to access the website, the browser, the user’s IP number, etc.). These text files are sent by a website to the browser used by the user for browsing, and are then stored on the user’s device (i.e. computer, tablet, smartphone, etc.) and retransmitted to the same website during the user’s next visit.

There are different types of cookies:

• session cookies, identify the user during his session on the website and allow his interaction with the same. They are deleted from the system once the session is finished, i.e. once the browser is closed, being therefore of a temporary nature
• persistent cookies, are cookies stored on your hard drive or on your device until you delete them or when they reach their expiration date. The storage time will depend on the life of the cookie in question and the settings of your browser
• first-party cookies: these are the cookies installed and managed directly by the website you are visiting. Therefore, they belong to the domain that is displayed in the URL of the visited website and are mainly used, for example, to ensure its technical operation
• third-party cookies: these are the cookies installed on the terminal by a subject other than the website visited by the user (so-called third parties) and, therefore, are created by domains other than the one displayed in the URL of the website visited. These cookies are not necessary for navigation.

Moreover, cookies can be classed on the basis of the purposes of processing performed by each cookie. In this perspective, it is possible to distinguish between:

• technical cookies: they are cookies used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide this service. These are, in other words, cookies that are essential for the operation of the website or necessary to perform activities requested by the user. Among the technical cookies, which do not require express consent for their use, this type of cookies can be divided into:
• navigation or session cookies (for authentication)
• functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, the language) to improve the service rendered to the user
• analytics cookies, namely cookies aimed at collecting information, in aggregate form, on the users of the website. If they are used anonymously, without cross-referencing them with data already in possession and to collect information in aggregate form on the number of users and how they visit the website, they are assimilated to technical cookies. In the latter case, the consent of the user is not required
• profiling cookies: these are cookies aimed at creating profiles relating to the user and used to send advertising messages in line with the preferences expressed by the same in the context of surfing the net. For the use of these cookies, a prior consent of the user is required.

The Site uses the technical, statistical (like technical) and profiling cookies, as better described below:

Below are links to the privacy policies for third-party cookies:

COOKIE MANAGEMENT

The user can also block or delete (all or part of) the cookies through the specific functions of the browser. However, if all or some of the aforementioned technical cookies are disabled, it is possible that the Site may not be accessible or that certain services or functions of the Site may not be available or may not function properly and/or the user may be forced to modify or manually enter certain information or preferences each time you visit the Site.

The settings related to cookies can be managed directly within the main browsers in the dedicated sections, as indicated in the links below:

Internet Explorer™: support.microsoft.com
Safari™: support.apple.com
Chrome™: support.google.com
Firefox™: support.mozilla.org
Opera™: legal.opera.com

For more information about cookies, you can visit the following site: aboutcookies.org

DATA CONTROLLER

The Data Controller is SEC Newgate S.p.A., with registered office in Via Ferrante Aporti 6/8, Milan (MI) and head offices in Via Ferrante Aporti, 6/8 20125 Milan and 14 Greville Street London EC1N 8SB. The company can be contacted by sending an e-mail to: info@secnewgate.com .

SCOPE OF DATA COMMUNICATION

The data collected using cookies may be processed by employees and collaborators of the company as persons authorized to do so. Such data may also be processed by third party that carry out technical and organizational tasks on our behalf relating to the management of the Site. These companies are designed as data processors pursuant to art. 28 GDPR.

The data acquired using cookies can be transferred abroad adopting the necessary measures and precautions provided by the applicable regulations to ensure an adequate level of security and data protection but will in no case be disclosed to indeterminate subjects.

DESELECTING AND ACTIVATING COOKIES

You can set or change your cookie preferences for the Site at any time by loading our consent manager below “Cookie Consent”.

DATA RETENTION PERIODS

Cookies: please refer to the retention periods indicated in the table above.

Site navigation: the data is stored for the time necessary to allow for you to navigate within the Site and, in any case, for no longer than 12 months, except in cases where events occur that require the intervention of the competent Authorities, also in collaboration with third parties/recipients who are responsible for the IT security of the Data Controller’s data, to carry out any investigations into the causes that led to the event, as well as to protect the Data Controller’s interests.

RIGHTS OF THE INTERESTED PARTY

In relation to your personal data, you may – as an interested party – exercise, at any time, the following rights:

• Right of access (art. 15 of the GDPR) – You have the right to obtain confirmation about the existence or not of a processing concerning your personal data as well as the right to receive any information relating to the same processing
• Right to rectification (Art. 16 of the GDPR) – You have the right to obtain the rectification of your personal data, if they are incomplete or inaccurate
• Right to erasure (Art. 17 of the GDPR) – in certain circumstances, you have the right to obtain the erasure of your personal data in our archives
• Right to restriction of processing (Article 18 of the GDPR) – upon the occurrence of certain conditions, you have the right to obtain the limitation of the processing of your personal data
• Right to data portability (Art. 20 of the GDPR) – You have the right to obtain the transfer of your personal data to a different data controller as well as the right to obtain in a structured format, commonly used and readable by automatic device, the data concerning you
• Right to object (article 21 of the GDPR) – You have the right to formulate a request to object to the processing of your personal data in which to give evidence of the reasons justifying the opposition; the Data Controller reserves the right to evaluate this request, which may not be accepted if there are compelling legitimate reasons to proceed with the processing that prevail over your interests, rights and freedoms
• Right to lodge a complaint with a supervisory authority (Art. 77 of the GDPR) – in the event that you believe that the processing that concerns you violates the legislation on the protection of personal data, you can lodge a complaint with the supervisory authority of the member state in which you usually live, work or the place where the alleged violation occurred
• Right to an effective judicial remedy (art. 79 of the GDPR).