COOKIE POLICY

This cookie policy (the “Cookie Policy”) sets out information on the use of cookies and other tracking technologies on the digital platform available at www.nadireo.com (the “Platform”), operated by Serco Italia S.p.A., with registered office at Viale dell’Astronomia 13, Rome 00144, Italy, tax code 06293370588 (the “Controller” or the “Platform Provider”). In connection with the use of such technologies, the Controller may process personal data relating to users of the Platform (the “Data Subjects”).

This Cookie Policy has been prepared in accordance with applicable data protection legislation, including Regulation (EU) 2016/679 (the “GDPR”), Directive 2002/58/EC (the “ePrivacy Directive”) and Italian Legislative Decree No. 196/2003, as amended and supplemented from time to time (the “Italian Privacy Code”).

1.       Identity and contact details of the Controller

The Controller is Serco Italia S.p.A., which may be contacted by Data Subjects for any information relating to the use of cookies and other tracking technologies at the following contact details:

  • email: postmaster@nadireo.com
  • postal address: by sending a written communication to the address indicated above (Viale dell’Astronomia 13, Rome 00144, Italy).

The Controller has appointed a Data Protection Officer (“DPO”), who can be contacted for matters relating to the processing of personal data and for the exercise of the rights granted under the GDPR at the following email address: postmaster@nadireo.com.

2.       What are Cookies?

Cookies are small text strings that are placed and stored on a Data Subject’s device (such as a computer, a smartphone or tablet) when they visit the Platform. They are then retransmitted to the Platform when the Data Subject visits it again.

Cookies may be classified on the basis of the following criteria:

  • Duration
  • Session cookies: Session cookies store information that is required during a browsing session and are deleted when the session ends, i.e., when the Data Subject closes the browser;
  • Persistent cookies: Persistent cookies remain stored on the Data Subject’s device and are read by the Platform each time the Data Subject visits it again. They remain on the device until they are deleted by the Data Subject or until they expire.
    • Party setting the cookies
  • First-party cookies: First-party cookies are installed and managed directly by the Controller.
  • Third-party cookies: Third-party cookies are installed through the Platform by third-party providers and are processed for purposes determined by those third parties. Such cookies are controlled by the relevant third parties, as further described in their respective cookie policies.
    • Purposes
  • Technical cookies: Technical cookies enable the Platform to function properly, facilitate navigation and allow Data Subjects to use the Platform’s features. These cookies are necessary for the smooth and efficient operation of the Platform. Without them, certain services or functionalities may not work correctly. Accordingly, the use of technical cookies does not require the Data Subject’s prior consent.
  • Analytical cookies: Analytical cookies enable the collection of statistical information, whether in aggregate or non-aggregate form, concerning the number of Data Subjects accessing the Platform and how the Platform is used. For example, they may be used to assess the effectiveness of the service, design or improve the Platform, and measure traffic.

Analytical cookies may be installed only with the Data Subject’s prior consent, unless they are used solely to produce aggregate statistics relating to the Platform and the Data Subjects’ data is minimised in a manner that prevents the identification of individual Data Subjects. In such cases, analytical cookies are treated as equivalent to technical cookies and do not require consent.

Where consent is required, the Data Subject is free to withhold consent, without this affecting their ability to browse the Platform or use its services.

  • Cookies used on the Platform

The Platform uses different types of cookies to ensure an optimal experience during Data Subjects’ navigation. The cookies used by the Controller on the Platform are listed below.

  • Technical cookies

Technical cookies are necessary for the proper functioning of the Platform and cannot be disabled through the Platform’s cookie management tool. The Data Subject may, however, configure their browser to block such cookies. In that case, certain parts of the Platform may not function properly. Technical cookies may include:

  • Navigation cookies: These cookies enable normal browsing and use of the Platform, including, for example, authentication to access restricted areas. They are typically session cookies and are automatically deleted when the browser is closed.
  • Functionality cookies: These cookies enable browsing based on criteria selected by the Data Subject, such as language or country, in order to improve the service provided through the Platform. They are persistent cookies and remain on the Data Subject’s device after the browser is closed, until they expire or are deleted by the Data Subject. Deleting or blocking these cookies may prevent some or all websites visited by the Data Subject, or certain functionalities of those websites, from operating correctly or efficiently.
  • Analytical cookies

Analytical cookies make it possible to identify the number of visits to the Platform and traffic sources, in order to measure and improve the Platform’s performance. The information collected is used to compile statistics on the use of the Platform and to improve the user experience.

The installation of analytical cookies requires the Data Subject’s prior consent, unless the Controller uses them solely to produce aggregate statistics relating to the Platform and the Data Subjects’ data is minimised so as to prevent the identification of individual Data Subjects. In such circumstances, analytical cookies are treated as equivalent to technical cookies and are therefore listed in the technical cookies table above.

In all other cases, analytical cookies may be installed only with the Data Subject’s prior consent. For this reason, when the Data Subject accesses the Platform, a banner is displayed informing them that the Platform uses analytical cookies. Through the banner, the Data Subject may either consent to or refuse the installation of such cookies.

The Data Subject may change their preferences at any time using the tool made available on the Platform and accessible through the link in the footer, which allows the Data Subject to manage consent for each category of cookies used on the Platform.

Where the Data Subject gives consent, the Controller records that consent through a specific technical cookie, so that the banner does not need to be displayed again on subsequent visits. The Data Subject may withdraw or change their consent at any time, without this affecting their ability to visit the Platform or access its content.

  • How to delete or disable cookies

The Data Subject may configure their browser so that the installation of cookies is subject to consent or so that cookies are blocked entirely. The procedure for changing cookie settings varies depending on the browser used and is usually described in the browser’s “Help” section.

BrowserInstructions
Mozilla FirefoxDelete cookies in Firefox
Microsoft EdgeDelete cookies in Microsoft Edge
Google ChromeDelete cookies in Chrome

In addition, when the Data Subject accesses the Platform, a banner is displayed informing them that the Platform uses cookies, including third-party cookies, where applicable, that require prior consent.

Through the banner, the Data Subject may choose which cookies to allow, other than technical cookies. The Controller records the Data Subject’s preferences through a specific technical cookie, in order to avoid displaying the banner each time the Data Subject visits the Platform.

The Data Subject may change their preferences at any time through the [“Cookie Settings”] link available at the bottom of each page of the Platform https://sandbox.nadireo.com/cookie-notice/.

  • Amendments to this Cookie Policy

The Controller may amend this Cookie Policy from time to time, including to reflect changes in applicable national or European Union legislation, technological developments, or updates to the cookies used on the Platform.

The most recent version of this Cookie Policy will always be made available on the Platform. Data Subjects are therefore encouraged to review it periodically.

In the event of material changes to the processing activities described in this Cookie Policy, the Controller will inform Data Subjects through the cookie banner when they access the Platform.

The Controller will also display the banner again when:

1. the Controller is unable to determine whether a cookie has previously been stored on the Data Subject’s device for the purpose of recognising the Data Subject on a subsequent visit, for example where the Data Subject has deleted cookies lawfully installed on their device; or

2. at least six months have elapsed since the banner was last displayed to the Data Subject.

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