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Cookies

This policy on cookies ("Cookies Privacy Policy") is a further specification of the Privacy Policy and has the scope of describing the various types of cookies and the technologies used on the website http://www.investinlombardy.com of which the Holder is PROMOS Azienda Speciale of the Chamber of Commerce of Milan, with registered office in via Meravigli 9/b -20123 Milan, to describe the terms and conditions of use.

This document contains the following information:

1. What are cookies

1.1. Technical cookies

2. Third-party Cookies

3. Privacy and Safety on cookies

4. Other threats based on cookies

5. How to disable cookies

6. Cookies on the website http://www.investinlombardy.com

1. What are cookies

Cookies are small text files that the websites visited by the user send to the device (usually to the browser), they are stored in the corresponding folder of the browser while the user is busy visiting a website, and are passed on to these websites at subsequent visits. They are used in order to improve browsing, (the http protocol is stateless and cannot "remember" the authenticated user visiting the pages), safe user preferences already entered (username, password, etc.), track the user’s tastes and preferences allowing to manage the presence or absence of targeted marketing initiatives or provide services related to the activity of the Holder as newsletters, dem(direct email marketing), etc.

If their use is limited, this will surely affect the user's status during the consultation. Blocking or removing them from the browser cache, could result in an incomplete use of the services offered by the web application. For the purposes of interest, it is possible to divide the cookies in two categories: technical cookies and profiling ones.

The profiling cookies - as required by the 229/2014 provision by the Authority for the protection of personal data – aim at creating profiles relative to the user and are used to send advertising messages in line with the user’s preferences expressed while surfing the net.

1.1. Technical cookies

Technical cookies are used for the sole purpose of “performing the transmission of a communication over an electronic communications network, or as strictly necessary to the service provider of an information company explicitly requested by the subscriber or user to provide this service" (cfr. art. 122, paragraph 1, of the Code on the processing of personal data). Persistent cookies and session cookies are included among the cookies in this category.Session cookies are temporary cookies; they operate on the machine for a time limited to the duration of the user's session. When the browser is closed, the session cookies expire. These are generally used to identify users when they log onto a site, to remind the users of their preferences when moving among the pages of the site, to provide specific information collected previously.

The most common example of this feature is represented by the cart of an e-commerce site. For example, when visiting a page of a catalogue and selecting some items, the session cookie remembers the selection so that the items continue to be selected in a virtual shopping cart when ready for the checkout operation. Without the session cookie, if the user clicks on checkout, the new page could not recognise the activities gone by in the previous pages and the cart would still be empty.Persistent cookies, on the other hand, help websites remember the data and user settings for future consultations. This allows a faster and more convenient access in terms of time since it is not necessary to login again. Persistent cookies remain active even after the browser is closed.

In addition to authentication, other website features are made possible and include: the language selection, the theme selection, menu preferences, bookmarks or favourites, and many more. During the visit, the user selects their preferences and they will be remembered by using persistent Cookies during the next visit.

2. Third party cookies

The so-called third party cookies are cookies set by a different website than the one the user is browsing. They are used, for example, by the site that the visitor chose first and that contains ads from another server or third-party website. Operationally, the browser collects information provided by different sources so that all elements are displayed on the same page, creating more Cookies in the corresponding browser folder.

All these cookies can be removed directly from the browser settings, or through special and also free programs or their creation can be blocked. In the latter case, some services of the website could not work as planned and it could not be possible to access or even, not having the associated Cookie, lose the user preferences, so the information is displayed in the wrong local form or could not be available.

3. Privacy and safety on cookies

It is good to point out that the cookies are not viruses, they are just text files that are not interpreted by the browser or run on memory. As a result, they cannot duplicate, spread to other networks to be duplicated again. As they cannot perform these functions, they are not considered as viruses based on the standard definition. Nevertheless, cookies may be used for potentially malicious purposes, all the same.Since that thanks to them preference information are stored, as well as the history of a user's actions, the specific browsing among many websites, cookies can, indeed, be used to act as a dispyware form. Many anti-spyware products are aware of this issue and, routinely, report reporting cookies as possible threats.

4. Other threats based on cookies

Because cookies are transferred between browser and website, a malicious user or an unauthorised person could intercept the data and information related to them. Although relatively rare, this could happen if the browser connects to the website using a WI-FI non-protected network for instance. Other attacks based on cookies involve the server setting. If a website does not require that the browser uses only encrypted connections (i.e. https), attackers can exploit this vulnerability to trick visitors by sending their personal information to insecure channels. Attackers can then hijack personal data for non-authorised processing purposes.

5. How to disable cookies

Most browsers accept cookies automatically, but it is anyhow possible to choose not to accept them. It is advisable not to disable them, as this could prevent moving from one page to another and using all the site’s specific functions. If you do not want your computer to receive and store cookies, it is possible to change your browser's safety settings (Internet Explorer, Google Chrome, Safari etc.). In any case, it is précised that certain parts of the Site can be used fully only if the browser accepts cookies; on the contrary, for example, it may not be possible to complete operations like paying for an online service. Consequently, the choice of removing and not accepting cookies could affect your site visit and its enjoyment negatively.

In any case, if you want to change the settings of the cookies, hereunder are short instructions on how to carry out this operation for the four most popular browsers:

Privacy

REGISTRATION FORM FOR A NEW USER OF THE ON-LINE SERVICES PROVIDED ON THE INTERNET SITE AND FOR THE REGULAR NEWSLETTER MADE BY THE PROMOS INVESTMENT ATTRACTION AREA WITHIN THE INVEST IN LOMBARDY PROJECT. Disclosure for the registration form for a new user of the online services provided on the website and registration for the regular newsletter by the PROMOS Investment Attraction Area - Special Agency of the Milan Chamber of Commerce (hereinafter referred to as "PROMOS ") as part of the Invest project in Lombardy. Pursuant to Article 13 of the Legislative Decree 196 of June 30, 2003, We inform you that personal data provided herein shall be processed in accordance with the mentioned legislation. Such data will be processed through electronic registration and will be used only as follows: a) to register to the site and on-line services provided by the Invest in Lombardy (www.investinlombardy.com), to be identified and authorise your access through personal username and password. This service will be provided by the site’s Member Area, reserved only for members of the Partner Program project: an action program in favour of Lombard service companies and professionals that assist foreign companies investing in Lombardy. b) to be included to the mailing list and to send regular newsletter containing institutional communications (relating to services and initiatives by the PROMOS Investment Attraction Area project in Lombardy also in collaboration with private partners participating in the project, the Chamber of Commerce of Milan or other entities connected to investment attraction, exports, and internationalisation), promotion of certain services in the area, information on all the initiatives and activities (institutional information to the subscribers, events, services, call for bids, information on courses/seminars, meetings, conferences, sending of publications and research papers, updating and training, etc.) promoted by the PROMOS Investment Attraction Area within the Invest project in Lombardy, also in collaboration with private partners of the Invest network in Lombardy. Further information can be offered, subject to your consent, by the other Special Companies of the Chamber of Milan, through automatic systems to share, process and exchange information; in the latter case, the Milan Chamber of Commerce and the Special Agencies (Chamber of Arbitration of Milan, Formaper, Innovhub SSI, Promos) shall each operate as an independent holder of the processing and the service by CCIAA of Milan and other Special Companies shall be provided only after prior consent by the user involved in the processing. The personal data requested and marked with an asterisk (*) are mandatory because necessary to provide the services referred to in the above subparagraphs a) and b). If not provided it will be impossible to obtain the mentioned services. The email addresses (and any other collected data) are stored electronically in databases that are protected by safety systems suited to prevent the loss, misuse, unauthorised access or non-allowed treatments or that do not comply with the purposes of the collection. The processing of the collected data is handled by PROMOS through computerised and telematic tools with logics strictly related to the underlined purposes and, anyhow, in order to ensure the security and confidentiality of the data. To provide and manage the Newsletter, the PROMOS Investment Attraction Area uses the service offered by MailChip (The Rocket Science Group, LLC, 512 Means St., Suite 404-30318 - Atlanta, Georgia) and hereunder mentioned just as “MailChimp”. The collected data is stored on secure MailChimp servers. Pursuant to the MailChimp privacy policy, your data will never be used directly by MailChimp or sold by it to third parties. MailChimp guarantees the confidentiality of the processing with the linked privacy policy that is legally binding. With reference to the registration on the portal referred to at the above point a), it is noted that cookies are not used while surfing the corporate website to transmit personal information, nor are any kind of persistent cookies, or user tracking systems. The use of section cookies is strictly limited to the transmission of identification data necessary to allow the safe and efficient exploration of the site. For the corporate communication or promotional activity referred to at the above point b), carried out through automatic information processing systems aimed at improving the communication process with the users, as well as regularly informing businesses, professionals and privates on the activated initiatives, the personal data of the registered user will be processed by Promos, the Chamber of Commerce of Milan (CCIAA) and other Special Agencies (each acting as an independent data holder) as well as by those specifically appointed as data processors (SiComunica among which, by way of example) with automated and/or manual procedures and only for the purposes for which they are collected (the newsletter and institutional/promotional communications), for the time strictly necessary to provide the service; the data will be deleted immediately if the person concerned withdraws their registration with each holder. The data provided by you, both as a result of the conferment and as the result of voluntary contribution, for the above purposes they will be processed by internal Promos staff employed especially for this purpose (secretariat, administration and information system staff, etc.) and third parties, for which this is necessary and indispensable (or anyhow useful), to carry out the purposes of the processing already indicated; In this regard, it is précised that, to send the institutional/promotional communications through automated processing systems, these data will be communicated and shared with the Chamber of Commerce of Milan (CCIAA) and its Special Agencies, through the technical support of DigiCamere, appointed as head of this processing even for the management of the IT platform that involves the institutional communication service. In any case, the data will not be disclosed. It is possible to exercise your rights towards the data Holder at any time pursuant to Article 7 of the Law Decree 196/03. In particular, you have the right to obtain confirmation from the Holder on the existence of data that may concern you and on their processing treatment, to obtain updating, correction or integration of data, their deletion if collected illegally, and oppose the processing for legitimate reasons. The Privacy Coordinator (Ms. Paola Amodeo) is responsible for the relations, to whom you can refer by sending your request to the following e-mail: privacypromos@mi.camcom.it or to the fax number: + (39) 02-8515.5227 5394. Holder of the data processing is PROMOS Promozione Sviluppo, in the person of its legal representative. For further information on the PROMOS activities, you may view the privacy policy on our website where you can find complete information on the data processing made by us.