The purpose of this Cookie Policy is to describe how this Website is managed, with reference to the use of cookies and other tracking tools (hereinafter all referred to as “cookies”) and the processing of personal data of users/visitors.

This Policy is provided to the users of the website https://www.polostrategiconazionale.it/en pursuant to Regulation 2016/679/EU (General Data Protection Regulation – hereinafter GDPR) and the General Regulation of the Italian Data Protection Authority (Garante per la protezione dei dati personali) of 8 May 2014 on cookies, as supplemented by the Guidelines of the Italian Data Protection Authority of 10 June 2021 on cookies and other tracking tools.

This website is owned and managed by Polo Strategico Nazionale S.p.a.

This Cookie Policy only applies to the above mentioned website (hereinafter referred to as the “Website”) and any sub-domains, and it does not apply to other websites that the user may consult navigating through specific links.

Users/visitors are kindly invited to read this Cookie Policy carefully before submitting any kind of personal information and/or filling in any electronic form on the Website as well as, in general terms, using the Website itself.

The Data Controller is Polo Strategico Nazionale S.p.a. (hereinafter, “the Data Controller” or “PSN”) with registered office in Via Giacomo Puccini 6, Rome, Italy. The Data Controller can be reached at the following email address: info@polostrategiconazionale.it

The Data Protection Officer (DPO) can be reached at the following email address: dpo@pec.polostrategiconazionale.it

3.1 Browsing data

Personal information automatically sent while navigating the Website and using network communication protocols may include: IP addresses of the users connecting to the Website; unique identifiers (Uniform Resource Identifier) of requested resources; e-mail address, etc.

These categories of personal data are processed by the Data Controller in an aggregate form only for the pursuit of its own legitimate interests, pursuant to Article 6(1)(f) of the GDPR, related to the technical management of the Website and the anonymous collection of statistical information on the use of the Website, as well as for the ascertainment, exercise and judicial defense of its own rights. The data in question may also be used to comply with legal obligations, pursuant to Art. 6(1)(c) of the GDPR, related to the management of the Website and to comply with requests made by the competent judicial authorities and by the judicial police, to ascertain responsibility in the event of cybercrimes committed to the detriment of the Website.

3.2 Data communicated by the user

When optional, direct and voluntary messages are sent to the contact addresses of the Data Controller indicated on the Website, this entails the acquisition of the sender’s contact data necessary to reply to the requests forwarded, as well as all the personal data included in the communications. These data will be processed pursuant to art. 6(1)(b) of the GDPR in order to allow the Data Controller to provide the user with the service.

PSN invites users not to submit personal data other than those strictly necessary when submitting these requests.

Cookies are small text files that websites visited by users send to their devices (usually to their browser or smartphone), where they are stored and then retransmitted to the same websites on each subsequent visit via the same device. 

In addition, each website may allow the transmission of so-called ‘third-party’ cookies, i.e. cookies generated by websites other than the one the user is visiting (through objects present on the website such as banners, images, maps, sounds, specific links to web pages of other domains).

Depending on their duration, they can be classified as session cookies (i.e. cookies that are temporary and automatically deleted from the user’s device at the end of the browsing session by closing the browser) and persistent cookies (i.e. cookies that are stored on the user’s device until they expire or are deleted by the user). 

Cookies have different purposes. Firstly, they are used to carry out the transmission of a communication or to provide the service requested by the user; more specifically, they enable and optimise the operation of the website, perform computer authentication and prevent abuse, monitor sessions, improve the user’s browsing experience, for example by keeping the connection to the restricted areas active while browsing through the pages of the website without the need to re-enter the User-Id and password and by storing specific information regarding the users themselves (including preferences, type of browser and computer used). They may also be used (anonymously, in the case of third-party cookies) to carry out aggregate analysis on the functioning of the website, the number of users and how they visit the site. 

4.1 Technical cookies

These cookies are necessary for the proper functioning of the Website as they allow the user to navigate and save the login credentials in order to speed up user access to the Website in subsequent logins (for registered users) and the activation of navigation preferences. 

Technical cookies do not allow for user identification or profiling and are used by the Data Controller to the extent strictly necessary for the safe and efficient navigation of the site.

The user’s consent is not required for the aforementioned technical cookies, since without them some of the operations described above could not be carried out or would be more complex and/or less secure.

4.1 Profiling cookies 

Profiling cookies make it possible to collect information relating to the user experience, the purchases made and the use of Internet content by users/visitors of this Website in order to identify consumption habits and thus personalise content and ads, send users/visitors advertising in line with their preferences, measure the effectiveness of advertising messages and adopt the subsequent commercial strategies. 

Profiling cookies may also include so-called service customisation cookies, which allow the Website to provide features and/or customisations that are not strictly necessary for its operation but which would improve the user/visitor’s use of the service, such as customising Website content according to the user’s interests.

To allow the user to freely give its consent, when accessing the Website an information banner pops up where the user can authorise or refuse the installation of cookies other than technical cookies. Before these types of cookies are sent to the user’s device, in accordance with the regulations in force, a banner is immediately displayed in the foreground when accessing the home page or any another page of the website. This banner shows a short version of the cookie policy and the request for consent. The user may either give its consent (by clicking on the “accept” button) or refuse (by clicking for example on the “X” or “Continue without accepting” button at the top right of the banner).

The Website may use session cookies and persistent cookies. The types of first-party cookies generated and transmitted by this Website are the following: 

• Technical cookies, used for: a) authentication and management of a browsing session (e.g. to identify and validate the user for access to Restricted Areas); b) security purposes (e.g. to keep track of the number of failed logins by identifying possible abuses in the authentication process and preventing fraud); c) customisation of the user interface (e.g. to record the preferences expressed by the user such as language, currency, page display format, connection area); d) improved usability of the website and its audio-visual content; e) the proper functioning of the connection (e.g. by routing the user’s requests between several servers in an appropriate manner). 
• Profiling cookies make it possible to collect information relating to the user experience and the use of Internet content by users/visitors of this Website in order to identify consumption habits and thus personalise content and ads, send users/visitors advertising in line with their preferences, measure the effectiveness of the advertising messages and adopt the subsequent commercial strategies.
  To allow the user to freely give its consent, when accessing the Website an information banner pops up where the user can authorise or refuse the installation of cookies other than technical cookies. Before these types of cookies are sent to the user’s device, in accordance with the regulations in force, a banner is immediately displayed in the foreground when accessing the home page or any another page of the website. This banner shows a short version of the cookie policy and the request for consent. The user may either give its consent (by clicking on the “accept” button) or refuse (by clicking for example on the “X” or “Continue without accepting” button at the top right of the banner).
  For profiling cookies consent must be obtained pursuant to Art. 6(1)(a) of the GDPR unless third-party analytics cookies have been anonymized. These cookies are installed and managed according to the GDPR guidelines by the company Justbit S.r.l., REA code 1295483.
  Unless consent is revoked, the user/visitor may receive promotional messages/content based on its interests until the profiling cookies expire. The profiling cookies of Polo Strategico Nazionale will be stored on the device for 12 months from the visit of the user/visitor on this Website; afterwards they will be automatically deleted from the device.

• Analytics cookies are directly managed and used by Polo Strategico Nazionale to collect aggregate/statistical information on the number of users and how they navigate through this Website.  The Website also uses first-party analytics cookies to collect statistical and aggregate information on how users navigate through the Website (e.g. number of pages visited and accessed, time spent on the site) in an anonymous way (by masking parts of the user’s IP address). These cookies are used directly by the Website manager pursuant to Article 6(1)(f) of the GDPR. They are assimilated to technical cookies and do not require the user’s consent and, once stored on the user’s browser, will be deleted immediately after the relevant statistical processing.

Polo Strategico Nazionale makes use of analytics services provided by third parties to collect information relating to the browser, device, Internet connection, geographical area from which the user is connected, IP address (masked in whole or in part), pages visited on this Website as well as to produce aggregate statistics on the number of users and on how they navigate through this Website (possibly broken down by geographical area, connection time band and other characteristics), for the purposes of optimising the Website.

Specifically, the Matomo service provided by the company Justbit S.r.l. is used, which is configured in such a way that analytics cookies are equivalent to technical cookies, in compliance with the Guidelines of the Italian Data Protection Authority of 10 June 2021 (e.g. by masking all or part of the IP address used by the user). 

This Website also allows the transmission to the user’s device of third-party cookies, from third parties with which Polo Strategico Nazionale cooperates, as a technical intermediary. The Website sends these cookies but does not have any control on and access to the information provided/acquired.

For these cookies, please read the relevant cookie policy and manage the third-party consents by accessing the preference management panel. 

For these cookies, you can read the cookie policy by accessing the third-party links. With reference to the third-party cookies, the Data Controller does not have control over the related information and does not have access to such data, as they are managed independently by the third-party companies as described in their respective policies. In order to properly manage the aforementioned third-party cookies, please read the relevant policies by visiting the websites of the entities listed below.

Third-party cookies may include the following categories of cookies:

• profiling cookies of advertisers and e-commerce operators, which manage cookies to keep track of the activities or purchases that the user/visitor has made on this Website (also when coming from other websites), typically in order to: (i) create profiles of users/visitors in order to customise content and ads and send advertising messages on the potential interests of users/visitors on this Website and/or its affiliates’ sites; (ii) allow the correct allocation of commissions for the commercial transaction; (iii) measure the effectiveness of the advertising messages (content and ads) and adopt the subsequent commercial strategies (e.g. for product development). These advertisers may also use geo-referencing data based on the user/visitor’s IP address in order to target ads and content based on the different territories;
• social media cookies, which allow the sharing of content between logged in members of the same social network via plug-ins;
• performance cookies, which allow third parties to monitor the use of the Website by users, to carry out their own aggregate/statistical analysis and which may retain the possibility of identifying users.

The semantic encoding criteria and the retention periods set for each cookie can be consulted in the dedicated management panel for cookie and consent settings.

The user/visitor can manage its cookie preferences by using the specific features present in common browsers (Internet Explorer, Mozilla Firefox, Google Chrome, Apple Safari), which allow you to delete/remove cookies (all or some) or to change the settings of the browser itself in order to block the sending of cookies or to limit it to specific sites (as opposed to others). If you want to know more about how to configure the browser settings (usually accessible from the “Tools” bar), please visit the Support web pages of the providers of the aforementioned browsers (which can also be found using a common search engine). 

Disabling cookies does not in itself prevent the use of the services of the website; however, if all cookies, including technical cookies, are deleted/blocked, some operations could not be performed or would be more complex and/or less secure, such as, for example, for the performance of activities within the Website’s Restricted Areas (in fact, cookies allow the user to be identified and logged in during the session).

In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. You can check your preferences on the following pages, depending on your browser.

• Microsoft Edge: https://support.microsoft.com/it-it/windows/eliminare-e-gestire-i-cookie-168dab11-0753-043d-7c16-ede5947fc64d 
• Apple Safari: http://www.apple.com/it/support/mac-apps/safari/
• Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=it&hlrm=en&answer=95647
• Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
• Opera: https://help.opera.com/en/latest/web-preferences/
• Internet Explorer: https://support.microsoft.com/it-it/windows/eliminare-e-gestire-i-cookie-168dab11-0753-043d-7c16-ede5947fc64d

For browsers other than those listed above, please consult the relevant guide on how to manage cookies.

The deletion or elimination of cookies does not affect the lawfulness of personal data processing activities previously carried out via the deleted cookies.

The data processing operations connected to the web services offered by the Website are carried out at the Data Controller’s head office by technical personnel authorised to process the data using automated tools only, adopting suitable measures to ensure that personal data are processed appropriately and in compliance with the purposes for which they are managed.

The Data Controller does not transfer processed personal data to non-EU countries.

Except as specified for browsing data and cookies, the user is free to provide its personal data for the purposes set out in this information policy, but failure to do so may make it impossible to obtain the service requested.

Users/visitors have the right to access their data at any time and also to exercise their rights under Articles 15-22 of the GDPR, where applicable (request the origin of the data, rectification of inaccurate or incomplete data, restriction of processing, deletion or oblivion, data portability, as well as to opt out of their use for legitimate reasons). 

To this end, the user may send a specific request addressed to PSN by writing to the following
address info@polostrategiconazionale.it. 

If the user believes that the processing has been carried out in a manner that is not compliant with the GDPR, it may also contact the Supervisory Authority, lodging a complaint pursuant to Article 77 of the GDPR.

Further information can be found on the website of the Italian Data Protection Authority
at: www.garanteprivacy.it  

Last update: February 2023 

This information notice may be subject to changes. We therefore recommend that you check this webpage regularly and take into account the most up-to-date version of the information contained therein.