Cookie Policy

Dear User,

Modefinance S.r.l. (“Modefinance”, “us”, “our” or the “Company”), with registered office at Edificio A AREA Science Park, Padriciano, 99 (34149) Trieste, which can be contacted at info@modefinance.com, in its capacity as Data Controller, provides you the information regarding the use of cookies on our website cra.modefinance.com (the “Site”).

Modefinance has appointed a Data Protection Officer (“DPO”), pursuant to Article 37 of Regulation (EU) No. 2016/679 (“GDPR”), who is at your service for any information related to the processing of your personal data and the exercise of your rights as a data subject. The DPO can be contacted using the Controller's contact details or at the e-mail address dpo@studiolegalevicenzotto.it.

Legal basis and purpose of processing

The acquisition and processing of your personal data will be performed in compliance with the requirements of legality provided by law, to:

1. ensure the correct navigation on the Site, pursuant to art. 6, par. 1, let. b) and f) of the GDPR.
2. to comply with the legal obligations to which the Company is subject, pursuant to art. 6, par. 1, let. c) GDPR.
3. defense of rights in judicial and extrajudicial proceedings pursuant to art. 6, par.1, let. f) GDPR.
4. pursuit of the legitimate interest of the Company in the management of its internal control and risk management system, pursuant to Article 6, par. 1, let. f) GDPR.
5. pursuit of the legitimate interest of the Company in the management and continuous improvement of its operational processes, pursuant to art. 6, par. 1, let. f) GDPR.

The provision of personal data is optional, but not providing it may make impossible to navigate the Site or to respond to your requests.

Furthermore, based on your consent pursuant to art. 6, par. 1, let. a) GDPR, we may install profiling cookies to modulate the provision of online services in an increasingly customized way beyond what is strictly necessary for the provision of the service, as well as to send targeted advertising messages, i.e., in line with the preferences expressed by you during your navigation on the Web.

The provision of data for this purpose is optional, with the only consequence that without it we will not be able to offer you customized content and/or advertising messages.

Cookie

Cookies are small text strings that the Site sends to the user's terminal, where they are stored and transmitted to the Site on the next user's visit. Cookies may be first party (set directly by the Company) or third party (i.e., cookies from a different domain than the one used by the Site). Cookies are useful because they allow the Site to recognize the user's device and allow the user to navigate through pages, remembering the preferences expressed and improving the user's browsing experience. In certain cases, some types of cookies can also ensure that the advertisements displayed online are more suitable for the user or relevant to his/her interests.

Some operations could not be carried out without the use of cookies which, in certain cases, are also technically necessary for the functioning of the site itself.

There are different types of cookies, depending on their characteristics and functions, and they can remain on users' devices for different periods of time:

1. session cookies, automatically deleted when the browser is closed;
2. persistent cookies, that are stored on the device until a predetermined expiration date.

According to the regulations in force in Italy, the use of cookies does not always require the express consent of the user. Consent is not required for "technical cookies", i.e., cookies used for the sole purpose of carrying out the transmission of a communication on an electronic network, or when they are strictly necessary to provide a service as specifically requested by the user. In other words, these cookies are indispensable for the functioning of the Site or necessary to carry out activities requested by the user.

Among the technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see Provision of June 10th, 2021 "Guidelines cookies and other tracking tools" - the "Guidelines") also includes:

• browsing or session cookies (to authenticate yourself).
• functionality cookies, enabling the user to navigate according to a series of selected criteria (e.g., language) to improve the service provided to the user. They may be set by us or by third party providers whose services have been added to our pages.
• analytics cookies, only if used directly by the Site’s owner to collect information, in aggregate form, on the number of users and how they visit the site.

For profiling cookies, on the other hand, i.e., those aimed at creating profiles on the user and used to send advertising messages in line with the preferences expressed by the same as part of the navigation on the network, prior consent of the user is required. These cookies may be set through our Site by our advertising partners. They may be used by these companies to build a profile of your interests and show you relevant advertisements on other sites.

Cookies used by the Site

We have categorized the cookies we use according to their type of purpose.

Technical Cookies

The Site uses session and persistent cookies to allow safe navigation and efficient use of the Site's functions, as well as to improve the content.

These are cookies that, for example, allow the recognition of the selected language and the country from which you are connecting to the Site. Functionality cookies, on the other hand, are designed to improve your browsing experience.

These cookies are necessary for the operation of our Site and cannot be disabled without compromising the functionality of the Site itself.

Measurement

This Site uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service.

Anonymized analytics services

The services contained in this section allow the Owner, through the use of third-party Trackers, to collect and manage analytics in an anonymized form.

Google Analytics with anonymized IP (Google Ireland Limited)

Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Tracker.
Place of processing: Ireland – Privacy Policy.

Google Analytics 4 (Google Ireland Limited)

Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
Personal Data processed: Trackers.
Place of processing: Ireland – Privacy Policy – Opt Out.

Facebook Analytics for Apps (Facebook Ireland Ltd)

Personal Data processed: Tracker, Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)

Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy.

Targeting & Advertising

This Site uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailgun (Mailgun Technologies, Inc.)

Personal Data processed: Tracker and various types of Data.
Place of processing: Germany – Privacy Policy.

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.

JSDELIVR (jsdelivr.com)

Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy.

Facebook Audience Network (Facebook Ireland Ltd)

Personal Data processed: Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.

Facebook Lookalike Audience (Facebook Ireland Ltd)

Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.

AddThis(Oracle Corporation)

Personal Data processed: Tracker, Universally unique identifier (UUID) and Usage Data.
Place of processing: United States – Privacy Policy – Opt out.

Remarketing and behavioral targeting

This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.

Facebook Remarketing (Facebook Ireland Ltd)

Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.

Facebook Custom Audience (Facebook Ireland Ltd)

Personal Data processed: email address and Tracker.
Place of processing: Ireland – Privacy Policy – Opt Out.

In case the user wants to configure or modify their cookie settings on an individual level, they can access the section Edit Preferences - Browser settings

Modifying the settings of your browser, you can choose in general how to manage your cookies.

To understand how to set cookies, the User can consult the following links:

• Google Chrome
• Mozilla Firefox
• Apple Safari
• Microsoft Internet Explorer
• Microsoft Edge
• Brave
• Opera

In addition to the above, Users are informed of the possibility of making use of the information available on YourOnlineChoices (EU), Network Advertising Initiative (USA), Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. With these services, it is possible to manage the tracking preferences of most advertising tools. The Company, therefore, recommends that users use these resources in addition to the information provided in this document.

The Digital Advertising Alliance also provides an application called AppChoices which helps Users control behavioral advertising on mobile applications.

Scope of communication and dissemination of data and recipients and transfer of data

The data will be processed by persons in charge of processing pursuant to Articles 29 and 32 of the GDPR and 2-quaterdecies of Legislative Decree no. 196/2003.

In addition, for the abovementioned purposes, the data may be communicated to other companies in the TeamSystem Group and to third parties designated as data processors pursuant to art. 28 GDPR.

Furthermore, the other companies of the TeamSystem Group may access the data for administrative and/or accounting purposes, pursuant to recitals 47 and 48 and art. 6 GDPR.

If necessary, the data will be accessible to customers and other business partners of the Company, as well as to entities and/or autonomous data controllers to whom it is mandatory to communicate the data by virtue of legal requirements.

Transfer of data to international organizations and/or Third Countries

As regards the possible transfer of data to international organizations and/or Third Countries, the processing will take place in accordance with one of the ways permitted by the regulations in force (e.g.: adoption of standard contractual clauses approved by the European Commission, selection of subjects participating in international programs for the free circulation of data or operating in countries considered safe by the European Commission, etc.).

Data Retention

The data will be retained for the time necessary to achieve the purposes for which they were collected, respecting the principles of retention limitation and minimization referred to in art. 5, par. 1, let. c) and e) GDPR and in accordance with the duration of each cookie described in the tables above.

At the end of the storage period, the data will be anonymized or destroyed.

Rights under the GDPR

Regarding the data, you may - as a data subject - exercise the following rights at any time:

- Right to withdraw your consent (art. 7 of the GDPR) - you have the right to withdraw any consent given at any time, without prejudice to the lawfulness of the processing carried out prior to the withdrawal.

- Right of access (art. 15 of the GDPR) - you have the right to obtain confirmation of the existence of processing of your personal data and the right to receive any information relating to such processing.

- Right of rectification (art. 16 of the GDPR) - you have the right to obtain the rectification of your personal data, if the same are incomplete or inaccurate.

- Right to erasure (Art. 17 of the GDPR) - in certain circumstances, you have the right to obtain the erasure of your personal data present in our archives.

- Right to restriction of processing (art. 18 of the GDPR) - under certain circumstances, you have the right to obtain the restriction of the processing of your personal data.

- Right to portability (art. 20 of the GDPR) - you have the right to obtain the transfer of your personal data to a different data controller as well as the right to obtain in a structured, commonly used, and machine-readable format your data.

- Right to object (art. 21 of the GDPR) - you have the right to formulate a request to object to the processing of your personal data in which you give evidence of the reasons that justify the opposition; the Company reserves the right to evaluate this request, which may not be accepted if there are compelling legitimate reasons to proceed with the processing that prevail over your interests, rights and freedoms.

- Right to lodge a complaint with the Supervisory Authority (Article 77 of the GDPR) - if you believe that the processing of your personal data conflicts with the legislation on the protection of personal data, you may lodge a complaint with the Supervisory Authority of the Member State in which you usually live or work or of the place where the alleged violation occurred.

- The right to bring an action before the appropriate courts (Article 79 of the GDPR).

Changes and Updates

This Cookie policy is valid from the date of the last update indicated below. The Company may also make changes and/or additions to this Cookie policy, also because of possible regulatory changes and/or additions. Changes will be notified in advance and the User will be able to view the regularly updated Cookie policy on the Site's page https://cra.modefinance.com/it/cookie-policy. Last update 2 March 2022.