Cookies and other tracking tools policy
1. Introduction
For Sempione SIM S.p.A (hereinafter the “Sempione SIM”), privacy is a major concern. The purpose of this Cookies and other tracking tools policy (hereinafter the “Cookies Policy”) is to inform Users about the processing of their data and the use of tracking tools by Sempione SIM. Cookies are small files that contain text information and are saved in the User’s browser when he/she visits Internet pages. When the User returns to the Internet page or opens several sub-pages, the browser recognises him/her through cookies. In addition to cookies, Sempione SIM uses tracking tools such as pixels, unique identifiers or tags (hereinafter referred to generically as “tracking tools”) to collect the information set out below (see point 4), to understand the aggregate choices of Users browsing Sempione SIM’s website and to manage and improve Sempione SIM’s services and the way Sempione SIM’s website is used. Tracking tools enable Sempione SIM’s to make useful assessments in order to provide its service. Sempione SIM uses tracking tools managed directly by Sempione SIM (commonly referred to as “first-party” tracking tools) and tracking tools that enable services provided by third parties (commonly referred to as “third-party” tracking tools). If not otherwise specified within this Cookies Policy, these third parties have access to the respective tracking tools. The duration and expiration of tracking tools may vary depending on what is set by Sempione SIM or each third-party provider. Some of them expire at the end of the Users’ browsing session. In addition to what is specified in the description of each of the categories of activities reported in point 4 of this Cookies Policy, Users may obtain more detailed and updated information on the duration, as well as any other relevant information – such as the presence of other tracking tools – in the Privacy Policy of the respective third-party providers published on their websites and which we invite Users to read. In addition to the terms of this Cookie Policy, any additional terms and conditions that may be set out in any consent statement or other contractual terms of Sempione SIM to which Users may be subject, such as the Privacy and Data Protection Policy published on Sempione SIM’s website (Sempione – Privacy e Protezione Dati (sempionesim.it)) as well as any applicable regulations to which Sempione SIM is subject, also apply.
2. Data collected by Sempione SIM
Sempione SIM will collect the following information through its site:
- Aggregated non-identifying User data that our servers automatically record when the User visits the Sempione SIM’s website (e.g. IP address, type of device used, type of browser used, pages of Sempione SIM’s website visited by the Users, date and duration of access and other technical information);
- Cookies, pixel, unique identifiers and other similar technologies to collect and process information from different channels and devices that you use to interact with Sempione SIM, to recognize you, remember your preferences, tailor the content we provide to you;
- Information from third parties or delegated third-party service providers (such as, but not limited to, aggregated non-identifying Users information collected through third-party provider’s app with which we have a relationship or through cookies, pixels, social plugins, tags and other similar technologies).
3. Purpose of processing
Sempione SIM may use tracking tools to improve its website and make it more suitable to Users’ needs. Please also note that in order to improve the User experience, third-party components may also be used, which, under certain circumstances, collect anonymised information on the utilisation by the User of the corresponding website and make it available to Sempione SIM in an anonymised form. In particular, the data collected by tracking tools are used for the following purposes: Website and User relationship administration In order to improve content and browsing, Sempione SIM uses tracking tools to keep track of Users’ preferences (such as language, time zone, timeouts after periods of inactivity). Product implementation and execution Sempione SIM may use tracking tools to improve the quality of its products and services.
Marketing activity Sempione SIM may use tracking tools to develop its advertising initiatives, assess their effectiveness on social media and improve them according to Users’ preferences. Tracking tools also allow the re-direction of people to specific social channels with relevant content.
4. Sempione SIM’s tracking tools
Sempione SIM umay use “technical” cookies or other similar tracking tools to carry out activities that are strictly necessary to ensure the operation or provision of the service as well as for the purposes defined in point 3 of this Cookies Policy. Please note that the utilisation data and tracking tools set out below are used and stored by Sempione SIM for one year.
| Provider | Type of Service/Product | Privacy Policy (third-party) | Place |
| Google Analytics Google reCAPTCHA Google Tag Manager | Google Privacy Policy | Irlanda – Privacy Policy | |
| Meta | Facebook Instagram Widgets | Facebook Privacy Policy Instagram Privacy Policy | Irlanda – Privacy Policy |
| LinkedIn Insights | LinkedIn Privacy Policy | California – Consumer Privacy Act | |
| Cloudflare | Traffic optimization and distribution | Cloudflare Privacy Policy | San Francisco, CA – Privacy Policy |
5. The users’ right to manage preferences and the users’ right to give or withdraw consent of using cookies
There are several ways to manage preferences for tracking tools and to give or withdraw consent where necessary. Users can manage their tracking tools preferences directly through their device settings, for example, they can prevent the use or storage of tracking tools. In addition, whenever the use of tracking tools is dependent on consent, Users may give or revoke such consent by setting their preferences within the Cookie Policy or by updating such preferences via the tracking settings widget, if any. It is also possible to remove previously saved tracking tools by means of special browser or device functions. Other tracking tools in the local browser memory can be removed by deleting the browsing history. As regards third-party tracking tools, Users may manage their preferences and revoke their consent by visiting the relevant opt-out (if available), using the tools described in the third party’s privacy policy or by contacting the third-party directly. Users may also manage certain mobile application tracking tools by deactivating them through the appropriate device settings, such as mobile advertising settings and tracking settings in general (Users may consult their device settings to find the relevant one). Users are free to decide whether or not to give consent. However, please note that tracking tools allow Sempione SIM to provide a better experience and improved functionalities to Users (in line with the purposes outlined in this Policy under point 3). Therefore, without Users’ consent, Sempione SIM may not be able to provide the relevant functionalities.
6. Data protection officer and contacts
Given the complexity of identifying tracking technologies, we provide details of the Data Protection Officer which can be contacted for any needs relating to the processing of personal data and the use of cookies and tracking tools:
Data Protection Officer: Dott.ssa Virginia G. Basiricò
Via M. Gonzaga, 2 20123 – Milano (MI) Italia e-mail: dpo@sempionesim.it
The use of third-party tracking tools on Sempione SIM cannot be fully controlled by the Data Protection Officer, any specific reference to third-party tracking tools is to be considered indicative. For further information, Users are invited to consult the privacy policy of the respective third-party services listed in this Cookies Policy.