Informativa Provacy

Information on the processing of personal data of website users

Articles 13 and 14 of Regulation 2016/679/EU (hereinafter also "GDPR")

Why this notice

COMID SRL (hereinafter also "Company" or "Owner") is committed to the respect and protection of your privacy and wants you to feel safe both while simply browsing the site and in case you decide to register by providing us with your personal data in order to take advantage of the services made available to its Users and/or Customers. On this page Company intends to provide some information on the processing of personal data relating to users who visit or consult the website accessible by electronic means from the address https://www.comid.it/it/ . The information is provided only for the Company's website and not also for other websites that may be consulted by the user through links (for which please refer to their respective privacy policies/policies). Reproduction or use of pages, materials and information contained within the Site, by any means and in any medium, is not permitted without the prior written consent of Azienda. Copying and/or printing for personal and non-commercial use only is permitted (for inquiries and clarifications contact Company at the contact details below). Other uses of the content, services and information on this site are not permitted.

With respect to the content offered and information provided, Company will endeavor to keep the contents of the Site reasonably up-to-date and revised, without offering any warranty as to the adequacy, accuracy or completeness of the information provided by expressly disclaiming any liability for any errors of omission in the information provided on the Site.

Origin - Browsing Data

Company informs you that the personal data provided by you and acquired at the time of your request for information and/or contact, registration to the site and use of the services through smartphones or any other tool used to access the Internet, as well as the data necessary for the provision of such services, including navigation data and data used for the possible purchase of products and services offered by Company but also only the so-called "navigation" data of the site by Users, will be processed in compliance with applicable regulations. The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of the Internet. This is information that is not collected in order to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, make it possible to identify navigating users. This category of data includes the "IP addresses" or domain names of the computers used by users who connect to the site, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used in submitting the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check the proper functioning of the Company's website. It should be noted that the aforementioned data could be used to ascertain responsibility in the event of computer crimes to the detriment of the Azienda website or other sites connected or linked to it: except for this eventuality, at present the data on web contacts do not persist for more than a few days.

Origin - Data provided by the user

Company collects, stores and processes your personal data for the purpose of providing the products and services offered on the Site, or for legal obligations. With respect to some specific Services, Products, Promotions, etc. Company may also process your data for commercial purposes. In such cases, a specific, separate, optional and always revocable consent will be required in the manner and at the contact details below.

The optional, explicit and voluntary sending of electronic mail to the addresses indicated in the appropriate section of the Website, as well as the filling in of questionnaires (e.g. forms), communication via chat, push notification via APP, social networks, call centers, etc., implies the subsequent acquisition of some of your personal data, including those collected through the use of the Apps and related services, necessary to respond to your requests. We also point out that when using your mobile connection to access digital content and services offered directly by the Company or by our Partners, it may be necessary to transfer your personal data to such third parties. Please note that you may access the Site or connect to areas where you may be enabled to post information using blogs or message boards, communicate with others, for example by coming from the Company page on Facebook®, LinkedIn®, Youtube®, and other social networking sites, review products and offers, and post comments or content. Before interacting with these areas, we encourage you to carefully read the General Terms of Use keeping in mind that, under certain circumstances, the information you post can be viewed by anyone with access to the Internet and any information you include in your postings can be read, collected, and used by third parties.

Purpose of processing and legal basis

Data are processed for the purposes:

1) Strictly related to and necessary for registration at https://www.comid.it/ to the services and/or Apps developed or made available by Company, to the use of related information services, to the management of requests for contact or information, to make purchases of products and services offered through the site Company;

2) for ancillary activities related to the management of User/Customer requests and the sending of feedback that may include the transmission of promotional material; for the completion of the purchase order of the products and services offered, including aspects related to payment by credit card, the management of shipments, of the possible exercise of the right of repentance provided for distance purchases, updating on the availability of products and services temporarily unavailable;

3) related to the fulfillment of obligations under EU and national regulations, protection of public order, detection and suppression of crimes;

4) direct marketing, i.e. sending advertising material, direct sales, carrying out market research or commercial communication of products and/or services offered by Company; this activity may also concern products and services of Group Companies Company and be carried out by sending advertising/information/promotional material and/or invitations to participate in initiatives, events and offers aimed at rewarding users/customers, carried out by "traditional" means (by way of example, paper mail and/or operator calls), or by means of "automated" contact systems (by way of example, SMS and/or MMS, telephone calls without operator intervention, e-mail, fax, interactive applications), pursuant to art. 130 c. 1 and 2 of Legislative Decree 196/03 and subsequent amendments and additions;

The provision of data for the purposes referred to in points 1), 2) and 3), related to a pre-contractual and / or contractual phase or functional to a user request or provided for by a specific regulatory provision, is mandatory and, failing that, it will not be possible to receive the information and access any services requested; with regard to point 4) of this Information Notice, consent to the processing of data by the user/customer is instead free and optional and always revocable without consequences on the usability of products and services except for the impossibility for Company to keep users/customers updated on new initiatives or special promotions or benefits that may be available.

Company may send commercial communications relating to products and/or services similar to those already provided, in accordance with Directive 2002/58/EU, using the e-mail, or paper coordinates, indicated by you on such occasions to which you may object in the manner and at the addresses below.

Modalities, processing logic, storage times and security measures

The processing is also carried out with the aid of electronic or otherwise automated means and is carried out by Company and/or third parties thatCompany may use to store, manage and transmit the data. The data processing will be carried out with logics of organization and processing of your personal data, also related to the logs originated from the access and use of the services made available via web, of the products and services used related to the purposes indicated above and, in any case, in such a way as to guarantee the security and confidentiality of the data. The personal data processed will be kept for the period of time prescribed by the legislation applicable at the time.

Also with regard to data security, in the sections of the website set up for particular services, where personal data is requested from the navigating user, the data is encrypted using a security technology called Secure Sockets Layer, abbreviated as SSL. SSL technology encrypts information before it is exchanged over the Internet between the user's computer and the central systems of Company, making it unintelligible to unauthorized parties and thus guaranteeing the confidentiality of the transmitted information; in addition, transactions made using electronic payment instruments are carried out using the Payment Service Provider (PSP) platform directly and Company retains only the minimum set of information necessary to handle any disputes.Precisely with reference to the aspects of personal data protection, the user/customer is invited, pursuant to Article 33 of the GDPR, to report to Azienda any circumstances or events from which a potential "personal data breach (data breach)" may arise in order to allow an immediate assessment and the adoption of possible actions to counter such an event by sending a communication to privacy@Azienda.it or contacting Customer Service. The measures taken by Azienda do not exempt the Customer from paying the necessary attention to the use, where required, of passwords/PINs of appropriate complexity, which he/she shall update periodically, especially in case he/she theme they have been hacked/known by third parties, as well as carefully guard them and make them inaccessible to third parties, in order to avoid improper and unauthorized use.

Cookies

A cookie is a short string of text that is sent to your browser and, eventually, saved on your computer (alternatively on your smartphone/tablet or any other tool you use to access the Internet); such sending generally occurs every time you visit a website. Company uses cookies for a variety of purposes in order to provide you with a fast and secure digital experience, for example, by allowing you to maintain an active connection to the secure area as you navigate through the pages of the site.

Cookies stored on your terminal cannot be used to retrieve any data from your hard drive, transmit computer viruses, or identify and use your e-mail address. Each cookie is unique to the browser and device you use to access the Web Site or use the App from Company. Generally, the purpose of cookies is to improve the operation of the Website and the user experience in using it, although cookies may be used to send advertisements (as specified below).

For more information on what cookies are and how they work, you can read the attached WHAT COOKIES ARE IN COMPUTERS.

Scope of communication and data transfer.

For the pursuit of the above purposes, Company may communicate and have processed, in Italy and abroad, the personal data of users/customers to third parties with whom we have relationships, where these third parties provide services at our request. We will only provide these third parties with the information necessary to perform the requested services taking all measures to protect your personal data. Data may be transferred outside the European Economic Area if this is necessary for the management of your contractual relationship. In this case, protection and security obligations equivalent to those guaranteed by the Data Controller will be imposed on the recipients of the data. In the case of using services offered directly by Partners we will provide only the data strictly necessary for their performance. In any case, only the data necessary for the pursuit of the intended purposes will be disclosed and the guarantees applicable to data transfers to third countries will be applied where required.

We may also disclose personal data to our commercial service providers, for marketing reasons, who are appointed as external data processors for this purpose. In addition, personal data may be disclosed to the competent public entities and authorities for requirements of compliance with regulatory obligations or for the ascertainment of responsibility in case of computer crimes to the detriment of the website as well as disclosed to, or allocated at, third parties (as managers or, where they are providers of electronic communication services, as autonomous controllers), which provide computer and telematic services (e.g.: hosting services, website management and development) and which Company uses to perform tasks and activities of a technical and organizational nature also instrumental to the functioning of the website. The subjects belonging to the above categories operate as separate Data Controllers or as Managers appointed for this purpose by Azienda.

Personal data may, in addition, be known by employees/consultants of Company who are specially instructed and appointed as Data Processors.

The categories of recipients to whom the data may be disclosed is available by contacting Company at the contact details below.

Rights of data subjects

You may at any time exercise the rights granted to you by law, including that:

a) to access your personal data, obtaining evidence of the purposes pursued by the Data Controller, the categories of data involved, the recipients to whom the data may be communicated, the applicable retention period, the existence of automated decision-making processes;

b) to obtain without delay the rectification of inaccurate personal data concerning you;

c) to obtain, in the cases provided for, the deletion of your data;

d) to obtain the limitation of the processing or to object to the same, when possible;

e) to request the portability of the data that you have provided to Azienda, i.e. to receive them in a structured, commonly used and machine-readable format, including for the purpose of transmitting such data to another data controller, within the limits and under the constraints of Article 20 of the GDPR;

In addition, it may lodge a complaint with the Data Protection Authority pursuant to Article 77 of the GDPR.

For the processing referred to in point 4) of the purposes, the Customer may always revoke consent and exercise the right to object to direct marketing (in "traditional" and "automated" form). The opposition, in the absence of any indication to the contrary, will refer to both traditional and automated communications.

Data Controller

The Data Controller, pursuant to Article 4 of the Code and the GDPR, is. COMID SRL, via Nazionale,715 - 80059 Torre del Greco(NA) P.IVA: 01524521216 - CF: 06318850630

The above rights may be exercised upon request of the Interested Party in the manner made known by the Customer Service or on the Company's WEB site or by using the following references: ANTONIO RICCIARDI (aricciardi@comid.it).

Use of the Web Site, including those intended for tablets and/or smartphones, by the Client and/or User implies full knowledge and acceptance of the content and any directions included in this version of the policy published by Company at the time the site is accessed. Company informs that this policy may be modified without prior notice and therefore recommends periodic reading.

The Data Controller

COMID SRL

This privacy policy was updated on 01/08/2018

WHAT ARE COOKIES IN COMPUTERS

Cookies are generally small text files, ID tag data that are stored in the computer's browser directory or program data subfolders. Cookies are created when you use your browser to visit a Web site that uses cookies to keep track of your movements within the site, to pick up where you left off, remember your registered login, theme selection, preferences, and other customization features. stores a file corresponding (with the same ID tag) to the one set in your browser, and in this file you can track and store information about your movements within the site and any information you may have voluntarily provided while visiting the Web site, such as your e-mail address.

Cookies are often essential for Web sites that have huge databases, need logins, have customizable themes, other advanced features.

Cookies usually do not contain much information except the url of the Web site that created the cookie, the duration of the cookie's abilities and effects, and a random number. Because of the small amount of information contained in a cookie, it usually cannot be used to reveal your identity or personal information. However, marketing is becoming increasingly sophisticated and in some cases cookies can be used aggressively to profile your browsing habits.

There are two types of cookies: session cookies and persistent cookies. Session cookies are created temporarily in the subfolder of your browser while you visit a Web site. Once you leave the site, the session cookie is deleted. On the other hand, persistent cookie files remain in the browser subfolder and are activated again after visiting the Web site that created that particular cookie. A persistent cookie remains in the browser subfolder for the duration period set within the cookie file.

More about cookies

A cookie is a small file of letters and numbers downloaded to your computer when you access certain Web sites. Like virtual keys, cookies unlock your computer's memory and allow a Web site to recognize users when they return to a site by opening doors to different content or services. Like a key, a cookie itself contains no information, but when read by a browser it can help a Web site improve the service it provides.

Cookie files are automatically placed in the cookie file-the browser's memory-and each one typically contains:

  • The name of the server from which the cookie was sent
  • The duration of the cookie
  • A value - usually a randomly generated unique number

The server of the Web site that sent the cookie uses this number to recognize you when you return to a site or navigate from one page to another. Only the server that sent a cookie can read and then use that cookie.

A cookie is a string of text-only information that a Web site transfers to the browser's cookie file on your computers hard drive so that the Web site can remember who you are.

A cookie will typically contain the name of the domain from which the cookie came, the "lifetime" of the cookie, and a value, usually a unique randomly generated number. Two common types of cookies are used on most Web sites: session cookies, which are temporary cookies that remain in your browser's cookie file until you leave the site, and persistent cookies, which remain in your browser's cookie file for much longer ( although how long will depend on the duration of the specific cookie).

Cookies can help a Web site organize content to match your favorite interests more quickly. Most Web sites use cookies. Cookies cannot be used by themselves to identify you

There are two types of cookies:

Session cookies : these are temporary cookies, which are deleted when you close your browser. When you restart your browser and return to the site that created the cookie, the Web site will not recognize you. You will have to log in again (if login is required) or select your preferences/themes again if the site uses these features. A new session cookie will be generated, which will store your browsing information and will be active until you leave the site and close your browser. More about session cookies.

Persistent cookies : these files remain in one of the browser's subfolders until manually deleted or the browser deletes them according to the duration period contained in the permanent cookie file (more on permanent cookies).

What are persistent cookies used for?

Persistent cookies help Web sites remember your information and settings when you visit them in the future. This results in faster and more convenient access since, for example, you do not need to log in again.

In addition to authentication, other Web site features made possible by persistent cookies include: language selection, theme selection, menu preferences, internal site bookmarks or favorites, among many others. During your first visit, the Web site is presented in default mode. During your visit, you select your preferences and these preferences are remembered, through the use of the persistent cookie, the next time you visit the site.

For example, a Web site may offer its content in different languages. During your first visit, you may choose to deliver content in French, and the site may record that preference in a persistent cookie set on your browser. When you visit that site, it will use the cookie to ensure that the content is delivered in French.

For a demonstration of how a persistent cookie might be used . You can decide whether to allow your browser to accept these types of cookies by changing your settings. For more information, go to manage cookies .

WHAT CAN'T COOKIES DO?

Cookies are simple text files. They are not compiled so that they cannot perform functions or make copies of themselves. They cannot browse or scan your computer or snoop on you or look for private information on your hard drive.

Cookies have a very limited function: to help your browser provide all the features designed into many of today's Web sites. These features include easy login, preference settings, themes, shopping carts, and many other features.Cookies cannot capture or retrieve your personal information.

Because cookies are only harmless files or keys, they cannot look into your computer and find information about you, your family, or read material stored on your hard drive. Cookies simply unlock your computer's memory and allow a Web site to recognize users when they return to a site by opening doors to different content or services. It is technically impossible for cookies to read personal information.

WHAT IS A PROFILING COOKIE?

Cookie profiling, also called Web profiling, is the use of permanent or persistent cookies to track a user's general online activity. This tracking occurs not only when you are on a particular site, but occurs all the time you are browsing. This type of profiling activity is often carried out by marketers who purchase advertising rights on thousands of popular Web sites in order to collect and collate cookie information and create a single "profile" of a user. Internet advertising, as it is called, targets potential customers based on the way they browse the Internet.This is the real reason why most Web sites flash banner ads on their pages. The issue may not be a big deal to some, but others take their privacy seriously and are uncomfortable with being "followed around" and profiled.

Cookies work as an encryption mechanism to identify your computer from the millions of users who access the Internet. The information in a cookie is used to track a user's activity when they visit pages online.

This tracking is done anonymously, but the user must give permission before a site can store a cookie on the machine. Most Web browsers these days allow users to disable cookies permanently or delete them on exit.

Why cookie profiling?

Cookie profiling is the only way for marketers to target potential customers and get a possible product purchase from them. By knowing a user's browsing habits, including sites visited, age, marital status, and political and religious affiliations, they can show him or her advertisements that are attractive, ads that he or she will take care to protect. This is one way marketers increase their profits by expanding their customer base.

WHAT INFORMATION IS IN A COOKIE?

The contents of a cookie are determined by the specific website that created that cookie. The contents vary from site to site. As a general rule, cookies contain random alphanumeric characters.

Cookies are intended to help you access a site more quickly and efficiently. For example, cookies can store information to help you enter a site without having to log in. In effect, cookies tell the Web site that your browser has already been to the site. It does not need to know your exact identity. To learn more about this feature, please see the section on cookie management

When cookies are created, they normally do not contain any personal information. They do not scan your computer or perform any kind of investigation to find out your personal information. Any personal information they might contain is the result of your personal input on a website form. Most of the time, when a cookie stores personal information, that information is encoded in such a way that it is unreadable to any third party accessing the cookie folder. The only computer that can read and decode the information is the server that created the cookie in the first place.

In addition to encrypting the information stored in cookies, some Web sites add additional layers of security to browser cookie management processes: store only anonymous but unique content on local cookies; or store personal information on the Web site's server and make it accessible only by matching it with the anonymous cookie stored on your computer.

See how personal information can be linked to a cookie to produce a personalized Web site experience.

This depends on how a Web site has set up its cookie function, but generally the content of a cookie is a randomly generated set of characters. For most purposes, a Web site that sends a cookie does not need to know who you are-just remember that it has already seen your browser (for more information, go to the manage cookies section ).

Some Web sites write personal information about you in a cookie, but this is only possible if the information was provided in the first place. If personal information is stored in a cookie, it is usually encrypted--encrypted--so that third parties who have access to your browser's cookie folder cannot read it.

Some web servers use a combination of methods: on your browser they can create a cookie with unique but anonymous content;or on the server side they can create a file that records that unique but anonymous content alongside any personal information you have provided.

View a demonstration of how personal information linked to a cookie can provide you with personalized content on a web page.

Although cookies are simple text files that help your browsing experience, they are not without controversy. Cookies can be used to track your browsing history on your browser Web site. If you feel that this affects your privacy, you can change your browser settings to restrict the use of cookies on your computer to reduce its ability to retain browsing history records.

Essentially this is your Internet browser's memory where you can find all your cookies stored in a format that facilitates easy retrieval by a browser.

STANDARD USES FOR BROWSER COOKIES

Site servers set cookies to allow user authentication if the user logs in to a secure area of the Web site. The login information is stored in a cookie so that the user can log in and out of the Web site without having to re-enter the same authentication information over and over again. More information

Session cookies are also used by the server to store information about user page activity so that users can easily pick up where they left off on server pages. By default, Web pages have no "memory." Cookies tell the server which pages to show the user so that the user does not have to remember or start browsing the site again. Cookies act as a kind of "bookmark" within the site. Similarly, cookies can store order information needed to make shopping carts work rather than forcing the user to remember all the items the user has placed in the cart.

Persistent or tracking cookies are also used to store user preferences. Many Web sites allow the user to customize the way information is presented through site layouts or themes. These changes make the site easier to navigate and/or allows the user to leave a part of the user's "personality" on the site. For information on session and persistent cookies and tracking, see here

COOKIE SECURITY AND PRIVACY ISSUES

Cookies are NOT viruses. Cookies use a plain text format. They are not pieces of code compiled in such a way that they cannot execute or self-execute. Consequently, they cannot make copies of themselves and spread to other networks to execute and replicate again. Since they cannot perform these functions, they do not fall under the definition of standard viruses.

Cookies can be used for malicious purposes though. Because they store information about a user's browsing preferences and history, either on a specific site or by browsing between different sites, cookies can be used as a form of spyware. Many anti-spyware products are well aware of this problem and regularly flag cookies as candidates for deletion after a standard virus and/or spyware scan. See here for some privacy issues and concerns .

The way responsible and ethical web developers deal with privacy concerns caused by cookie tracking is to include clear descriptions of how cookies are deployed on their site. If you are a web developer and need advice on cookie implementation and a privacy policy, you can contact us via the request form at the bottom of the page. These privacy policies should explain what kind of information is collected and how the information is used. Organizations that use and display an appropriate and useful cookie privacy policy and policy include: LinkedIn Networkadvertising.org and Dealspotr .Most browsers have built-in privacy settings that provide different levels of cookie acceptance, expiration time, and disposal after a user has visited a particular site. Backing up your computer can give you peace of mind that your files are safe.

OTHER COOKIE-BASED THREATS

It is important to be aware of what threat cookies can represent.

Because cookies are transmitted back and forth between a browser and a Web site, if a malicious user or unauthorized person intervenes between the data transmission, sensitive cookie information can be intercepted. Although relatively rare, this can happen if the browser connects to the server using an unencrypted network such as an unsecured WiFi channel. Internet security can only be achieved if you regularly use an antivirus protection program . See our section on antivirus protection .

WHAT DOES THE NEW LAW SAY?

The new requirement is essentially that cookies can only be placed on machines where the user or subscriber has given consent.

KEY TIPS FOR SAFE AND RESPONSIBLE COOKIE-BASED WEB BROWSING

Because of their flexibility and the fact that many of the largest and most visited sites use cookies by default, cookies are almost unavoidable. Disabling cookies will block a user from many of the most used sites on the Internet such as Youtube, Gmail, Yahoo mail and others. Even search settings require cookies for language settings. Here are some tips you can use to ensure smooth cookie-based browsing:

Customize your browser's cookie settings to reflect your comfort level with cookie security or use our guide to clear cookies .

If you are very comfortable with cookies and you are the only person using your computer, you can set long expiration intervals for storing personal login information and browsing history.

If you share access on your computer, you may want to set the browser to erase private browsing data every time you close the browser. Although not as secure as rejecting cookies outright, this option allows you to access cookie-based Web sites by deleting any private information after your browsing session.

INSTALL AND KEEP UP-TO-DATE ANTISPYWARE APPLICATIONS

Many spyware detection features, cleaning applications, and spyware removers include attack site detection. They block your browser from accessing Web sites designed to exploit browser vulnerabilities or download malicious software.

Make sure your browser is up-to-date

If you have not already done so, set your browser to update automatically. This eliminates security vulnerabilities caused by outdated browsers. Many cookie-based exploits rely on exploiting security flaws in older browsers .

Cookies are everywhere and cannot really be avoided if you want to enjoy the biggest and best Web sites out there. With a clear understanding of how they operate and how they help your browsing experience, you can take the necessary security measures to ensure that you browse the Web with confidence.

As we have mentioned, cookies are inherently harmless. Cookies are simple, unfilled text files that help coordinate the remote Web site servers and the browser to display the full range of functionality offered by most contemporary Web sites. These features include seamless automatic login and authentication, shopping cart functionality, third-party ad serving, ad management, preference setting, language setting, and many others. As cookie technology evolves along with Web site publishing and advertising technology, privacy concerns are sure to increase.

PRIVACY CONCERNS: STORING PERSONAL INFORMATION AND TRACKING USER BEHAVIOR

Although the cookies by themselves per se cannot search or look up your data or search your computer, they do store personal information in at least two ways: form information and ad tracking. This personal information is not generated by the cookies themselves but by your own input into Web site order forms, registration pages, payment pages, and other online forms. Often used for ecommerce, this information is often encrypted and protected from hacking by the remote server through limited interaction via security features such as SSL (Secure Sockets Layer) certified pages and schemes of security similar network.

Cookie-based ad tracking has evolved over the years. From simple operations such as counting ad impressions, limiting popups, and preserving ad sequence, third-party ad serving cookies have evolved to tracking user/website preferences. The latter group of activities-monitoring of ads-has sparked much controversy among online consumer privacy groups and other stakeholders. Many of the largest online Web sites use large-scale third-party ad serving networks that cover many sites. One of the largest is Google's AdSense / Adwords ad serving network. Literally, millions of pages publish AdSense ads . For every click made by a valid user on an ad placed by Google on their site, site owners get money ranging from cents to dollars.

MAXIMIZING ADVERTISING EFFECTIVENESS THROUGH COOKIE-BASED USER PROFILING

Google's ad serving platform embodies many of the technological innovations used by other ad serving companies: it uses a user profiling system that tracks and shapes a particular user's browsing and ad habits. Google has long provided contextual ads triggered by words on a page. Google's ad serving system has added another layer to this technology: modeling/tracking user preferences. Simply put, when a user visits certain websites or reads certain content, Google ads will try to serve ads to that user that matches their content browsing preferences. Preferences are not set consciously or explicitly by the user but are shaped by the user's browsing history, page views, and ad click history. As a result, when a user reads "dog training" and switches to another Google ad page that may not be related to dog training, dog training ads may follow the user to the new page. There is no obvious notification or notice sent to the user that the user's online actions are being tracked for ad serving purposes.

As noted by some online privacy groups, this ubiquitous tracking and ad specificity increase the effectiveness of ads. However, they urge that such increased ad effectiveness must be weighed against the impact on user privacy and the fact that there is no overt consent for such tracking. Given the rapid evolution of cookie-based ad serving and behavior tracking technology, consumer privacy activists urge reconsideration of the default standards for cookies. The rise and fall of flash cookies have intensified the privacy debate.

FLASH COOKIES: A CAUSE FOR CONCERN

In addition to tracking user behavior and browsing history-based ad serving, online consumer groups are also concerned about the increasing level of cookie anonymity. While browser-based cookies are easy to detect and delete, many consumers are not very familiar with "flash-based" cookies. Also called "Local Shared Objects" (LSOs), flash-based cookies are not stored on your computer like browser-based cookies. As a result, they are harder to find and delete. Banks and online finance sites use flash-based cookies for this very reason. Since they are more difficult to detect and delete and less known than browser-based cookies, banking/finance sites store flash cookies on users' computers to authenticate account owners and prevent fraud since fraudsters only have user access and passwords but no access to the user's computer. The flash cookie acts as a second level of authentication that complements the user's login and password. Again, no explicit notice is sent to the user that a flash cookie has been installed on the user's computer.

Due to growing concerns expressed by consumer and privacy groups, flash-based cookies are being phased out at the technical level. Newer versions of Adobe Flash inform users that a cookie is being installed and explicitly asks users if they consent to having the information stored on their computer's server. Users can choose to install or cancel the installation process. Regardless, the increase, widespread use, and fallout from Flash-based cookies raises a fundamental question at this stage in the technological evolution of cookies: are current privacy protection processes sufficient?

P3P: INADEQUACY IN THE FACE OF INTERNET EVOLUTION?

P3P stands for "Platform for Privacy Preferences Project." It is a project of the Internet standards-setting body, the World Wide Web Consortium (W3C), which aims to help consumers manage their privacy while browsing Web sites that have different privacy policies (e.g., what information is collected, what duration is set, among others). Users set their privacy preferences in their P3P-enabled browsers. Before a user loads a site, the browser's P3P agent checks the privacy policy of the Web site being loaded. If the site falls within the privacy settings preset by the user, the site is automatically loaded.

ACTIVATION AND DEACTIVATION COOKIES

For much of the history of the Internet and cookie-enabled Web sites, most Web sites have been placing cookies and managing user information based on opt-out criteria. By default, Web sites are free to load their cookies on your computer. If you don't like it, you can always search for cookie files and delete them or set your browser to ask you when a cookie is planted. In addition, there are websites such as networkadvertising.org that lists most of the large third-party ad serving services on the Internet and allows users to select which networks they wish to disable.

Proponents of the optout model boast of the smooth user experience. They simply switch from one Web site to another. There is no "gate" that you have to go through to read free content or use free tools. This makes the Internet easy to navigate and convenient to use.

Critics of the optout model point to the increasingly intrusive capabilities of third-party ad tracking cookies that follow users from one network site to another. These cookies create dynamic user profiles that advertisers use to maximize their revenues at the expense of users who have not been notified or given consent. Users are "surfing blind" because they do not know what information is being collected, the purposes of that collection, nor are they provided with a copy of the information collected. In addition, online behavior monitoring could lead to discrimination based on groups (e.g., people using a particular IP address block or people from certain Web sites). They also increase the risk of private groups collecting information that is then turned over to government authorities. Because constitutional protections cover only government actions, the collection of private data raises particularly serious concerns.

IP ADDRESS

The IP address is a unique number assigned to the computer connection from the home or office or the employer's Internet service provider (ISP). This unique number acts as the ID of the connection when it accesses the Internet. It works the same way as your address: if someone wants to send you an e-mail or order a pizza, your address is needed by the mailman or courier to find your home. The same process applies to your computer-your IP address is used to route information from the Internet to your computer.

Depending on the type of ISP service contract you have, the IP address is assigned to your computer's connection on a temporary basis and usually changes each time you restart your router.

An IP address is one way to measure a user's unique identity. It is a number assigned to your browser by your Internet Service Provider (ISP) or employer when you connect to the Internet. It is usually assigned on a temporary (or dynamic) basis, that is, it is assigned to your browser only for the duration of your online session. It is the 'address' of your computer while you are online. Without an IP address, servers would not be able to deliver content to you because they would not be able to locate your computer.

7Pixel S.r.l., in the person of the protempore legal representative, is appointed as the data controller of the User's data (email address) for handling requests for comments under the Trusted Program of the website www.trovaprezzi.it