With this document, in accordance with the provisions of Article 122 of Legislative Decree No. 196/2003 (Italian Personal Data Protection Act), amended and integrated for the adjustment to the EU regulation
Smemoranda Group, in its capacity as controller of personal data, provides users of the https://www.smemorandagroup.com website the following information concerning the cookies used. This policy has been drawn up on the basis of the information contained in the general provision issued by the Italian Data Protection Authority [Garante] on 8 May 2014.
The Data Controller
The party responsible for the processing of your personal data (Data Controller) is Smemoranda Group with registered address at Viale Ortles, 52/54 Milan, Italy, VAT no. 10541990965. For additional information, please contact the Data Controller using the following details: telephone (+39) 02 5737451 , e-mail email@example.com.
What are cookies?
Cookies are small text files that visited websites send to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, Opera, etc.), where they are stored to then be retransmitted the next time the same user visits the specific website or page.
When surfing a website, the user can also receive cookies from other websites of web servers (“third-party” cookies). This is due to the fact that the website visited may contain elements such as images, maps, sounds, social media buttons (Facebook “Like”, Google “+1”, etc.), or specific links to web pages on other domains residing on a server other than the one where the requested page is found. In other words, these are cookies that are set by a website other than the one currently being browsed.
Technical cookies are defined as cookies used for the sole purpose of “carrying out the transmission of communication over an electronic communications network, or as strictly necessary in order for the provider of a service of the Information Society, explicitly requested by the subscriber or by the user, to provide the service in question” (cf. Article 122, Paragraph 1 of the Code).
Profiling cookies, on the other hand, are cookies used for creating user profiles in order to send advertising messages in line with the preferences shown by the same user with regard to browsing the internet. Article 122 of the Code makes reference to profiling cookies stating that “the storage of information in the terminal device of a contracting party or user or access to information already stored are permitted only on the condition that the contracting party or the user have given their consent after being informed using the simplified methods” (Article 122, Paragraph 1 of the Code).
Types of cookies used by this website
The https://www.smemorandagroup.com website uses technical cookies, for which no consent is required by the interested party.
More specifically, the website uses:
• authentication cookies
• cookies for customising the user interface
The https://www.smemorandagroup.com website also uses third-party cookies. A list of third-party cookies used by the website, as well as the link through which users can receive additional information, including requests for deactivation, is provided below.
These are cookies used directly by the operator of the website to gather aggregate information on the number of users and how they visit the site.
In particular, the website uses the Google Analytics service, which relies on cookies to facilitate aggregate statistical analysis relating to the website visited.
Users wishing to prevent the use of their personal data by Google Analytics can install a browser add-on, available for download from the following page:
The social media buttons present on the website allow users to interact with the social media platforms.
To deactivate the service, please follow the procedure indicated on the page below:
This site uses AdRoll to provide interest-based advertisements to show our ads on other websites. The technology to do this is made possible by cookies and as such we may place a so called “remarketing cookie” during your visit. Tthe whole process is entirely anonymised.
More informations here:
Google advertising and remarketing
The site uses various Google advertising and remarketing services (Google Advertising, Google AdSense, DoubleClick); these services use advertising cookies.
For more detailed information on how these work and, more generally, on the related privacy policies, please see the following pages:
Adverts related to interests can, however, be managed and deactivated by selecting the relevant settings on this page:
WebEngage is a service used to gather feedback and/or comments from users of the site. This service is optional and, if used, requires the installation of cookies.
More detailed information can be found here:
HotJar is a heat mapping service, provided by Hotjar Ltd., which – also through cookies – allows you to track and analyze site navigation.
Data processing method
Personal data may be processed with or without the use of electronic or automated tools. Specific security measures are adopted to prevent data loss, unlawful or incorrect use and unauthorised access. The data may also be processed by staff and/or associates of the Data Controller, appointed as Persons in charge of processing. There is no disclosure or communication of data.
It is also possible to visit the website without using cookies, although in this case the user may not be able to take full advantage of the features or services offered. Most browsers accept cookies automatically. The automatic registration of cookies can be prevented by selecting “do not accept cookies” from the options provided.
For additional information on how to do this please refer to the specific instructions of your browser. The user can obtain specific instructions by visiting the links below.
• Microsoft Internet Explorer
• Google Chrome
• Mozilla Firefox
• Apple Safari
For information regarding the cookies stored on your device and in order to deactivate them individually, please visit the following page:
It is possible, at any time, to delete any cookies already stored on your hard disk.