General Policy

(version 3.0 of 01 Feb 2017)


This policy is addressed to the VISITORS of the Websites affiliated to ShinyNetwork.

Dear Visitor (hereinafter, “You” or the “User“),

This page is owned by the Triboo Data Analytics S.r.l., having its registered office in Viale Sarca 336 20126 Milan (MI) (Italy), VAT No. and Fiscal Code No.09761680967, registered with the Company Register of Milan under No. MI 2111858 (hereinafter, “Triboo”, “We or Us” or the “Company“).

Our Company acts as Analytics services provider, such services aiming at optimising of the website use by users, further than Analytics services aiming at efficiency raising in supplying display and video advertising messages within the Publisher network affiliated to the so called ShinyNetwork.

Therefore, we act as third parties in respect to the website you currently come from (hereinafter the “Source Website”).

Since when you visit the Source Website we install the so called cookies on your terminal, we hereby aim at explaining to You what cookies are and how they are used by Us.

We hereby explains to You how We collect such data, for which purposes and what your rights are, also pursuant to Article 13 of the Legislative Decree No. 196 of 30 June 2003 (the “Privacy Code”).

A. What cookies are and what they are for

The cookies are small text files that the websites visited by a user send directly to its terminal (usually, to the browser), where they are memorised to be transmitted to the same websites at the following visit of the same by the same user (the so called proprium first part cookies). During the web surfing of a website, a user may receive on its terminal also cookies of other websites or of other web servers (the so called third parties cookies); this happens because there may be elements on the visited website, such as images, maps, sounds, links to specific web pages of other domains that are on servers other than the server on which the requested page is placed. In other words, such cookies are set up on a website other than the one that is currently visited.

The cookies may have a duration limited to a single session of navigation on the browser (the so called session cookies), and, in such event, they deactivate automatically once the browser is closed by the user; or may have a predetermined duration and, in such event, they will remain memorised and active on your hard disk until the expiry date, thus continuing collecting information during different sessions of navigation on the browser (the so called permanent cookies).

The cookies are used for several purposes. Certain cookies are necessary in order to allow You to surf websites and benefit of their functionalities (the so called technical cookies). Other cookies are used in order to obtain statistical information, whether in aggregate or not, about the number of users accessing the websites and how the websites are used (the so called analytics cookies). To the end, other cookies are used in order to track your consumer profile and make You viewing advertisings that may be of interest for You, since complying with your preferences and your consumer habits (the so called profiling cookies).

In order to know more in details such different categories of cookies please continue reading such policy. Please discover how they works and for what use they are for, and choose freely if you want to consent to their use or prevent the same.

B. Technical cookies

When you visit the Source Website, the Company installs the following technical cookies.

Our Company actually uses the following technical cookies:

COOKIE DENOMINATION

COOKIE CATEGORY

PURPOSE OF THE COOKIE

CAP_xxx – technical cookie
– surfing and functional
Managing frequency of capping campaigns
AFF_[UGMW]_xxx – technical cookie
– surfing and functional
Managing uniques for frequency of user’s capping
AFF_S_xxx – technical cookie
– surfing
– session
Identifying user’s session for managing the release of the contents
shbnrcl – technical cookie
– surfing
– session
Identifying user’s session for managing the release of the contents

As provided by the privacy legislation actually in force, Your prior consent is not required for the installation of such cookies. You are clearly free to block the installation of the technical cookies, modifying your browser’s settings (please read the following paragraph E, No. 1 in order to know how to do it).

C. “Analytics” cookies

The Company uses the analytics platform ShinyStat™ (hereinafter the “Platform”) in order to install analytics cookies; the Company does not store any personal data by means of the Platform, but anonymise all the browsing sessions and the analytics cookies make your identification impossible, since data are aggregated and anonymised in real time (within some milliseconds) in the several reports made available. The non-aggregate data and other personal information (for example, the complete IP address) are not stored in any manner whatsoever by the Company’s system.

It is hereby specified that the Company uses instrument for anonymising IP addresses. In order to know the detailed data anonymization and analytics cookies procedure, please read this: http://www.shinystat.com/en/anonimizzazione_free.html

The Company does not match the information included in such cookies with other information available to the same.

Should you wish to do so, you can opt-out clicking on the following link: http://www.shinystat.com/en/opt-out_free.html

For those who exercise the opt-out option, the Company will not collect any statistical data. If you are using several browsers or devices to access to the Source Website (computer, smartphone, tablet, etc.), it is necessary to carry out the opt out for each browser on each device for which you wish to disable the analytics cookies released by the Company.

Using the interactive button to block the cookies of the Company, in any case you will receive a technical cookie for memorising the express preference. Also such technical cookie could be deleted by deleting all the cookies from the browser and, therefore, you should also express your choice to block such cookies again by using the opt-out interactive button, available at the link included in this policy.

Our Company uses the following analytics cookies through the Platform, such anonymised cookies being conveyed directly by Us and therefore are installed by the Source Website without your prior consent:

Cookie

Cookie category

Policy and consent

ShinyStat™ – analytics cookie
– permanent
– anonymised
ShinyStat™ Policy:
http://www.shinystat.com/en/informativa_privacy_generale_free.html
Opt-Out: http://www.shinystat.com/en/opt-out_free.html

D. Profiling cookies

The profiling cookies are used to create a user’s profile, based on the preferences and likings showed by You during the navigation on Internet and to make You display advertisings consistent with your profile. In such way, the advertisings that You will display on the Source Website and on the other websites on which our cookies are installed could be more of interest for You.

Your prior consent is requested in order to install such cookies, as provided pursuant the current privacy law. For such a reason, when you access the Source Website a specific banner is displayed, informing you that (i) profiling cookies are used on the Source Website and that (ii) closing the banner, surfing on the home page or clicking whatever element on the home page outside the banner, You are giving your consent to the use of cookies.

In the event that you express your consent to the use of cookies in this way, the editor of the Source Website could track your consent by means of a specific technical cookie. In this way, the editor of the Source Website will avoid you displaying the cookies banner during your following visits of the Source Website. Please take into account that, in the event that you remove from your browser such technical cookie with the modalities set forth under the following paragraph E, No. 1), the track of your consent would be lost and, therefore, the cookies banner will be displayed again during your following visit to the Source Website.

You are clearly free to block the installation of profiling cookies in any moment whatsoever and this will not compromise in any manner whatsoever the possibility to visit the Source Website and benefit of its contents.

Certain cookies are lasting ones and have a maximum duration of 6 months. The first part profiling cookies used on the Source Website are the specified in the following table, together with the indication of the modalities to use in order to oppose to their installation:

Cookie

Cookie category

Opt-out instructions

SSA – profiling cookies
– permanent
– anonymised
Policy: http://www.shinystat.com/en/informativa_privacy_generale_free.html
Opt-Out: http://www.shinystat.com/en/opt-out_free.html

Using the interactive button to block the first part profiling cookies, You will receive in any case a technical cookie in order to memorise your preference. Please consider that, removing all the cookies from the browser, also this technical cookie could be removed and, therefore, you would have to express again your choice to block such cookies using the interactive button included in this policy.

Other profiling cookies are, otherwise, installed by third parties, who act as autonomous data controllers (third parties cookies). Please find here below a list of the third parties who currently uses profiling cookies in our WebSite, together with the links to the relevant policies pages created by their developers:

Cookie

Privacy Policy

LiveRail http://www.liverail.com/cookies-policy
Google http://www.google.co.uk/intl/it/policies/privacy
Kaltura http://corp.kaltura.com/privacy-policy
SpotXchange http://www.spotxchange.com/privacy-policy
Improve http://www.improvedigital.com/en/platform-privacy-policy
Tgadv http://www.tgadv.it/informativacookie
Zoomin http://www.zoomin.com/global/PrivacyPolicy
Mosaicoon https://plavidnetwork.com/about/#pl-policy
StickyADS http://www.stickyads.tv/privacy_policy/
Viralize https://viralize.com/cookie-policy/
Xaxis https://www.xaxis.com/static/view/privacy-policy-en
Adform http://site.adform.com/privacy-policy/en/
Sizmek http://www.sizmek.com/en/privacy-policy/
4W Marketplace http://www.4wmarketplace.com/privacy/

Certain third party cookies are installed by subjects with which we do not have a direct contractual relationship. For such reason, we hereby provide you with the links to the internet websites of the subjects acting as intermediary between us and such third parties, on which you may find (i) the list of the third parties installing profiling cookies on the Website and (ii) the links to the privacy policy of such third parties, in which you can find all the necessary information on their profiling cookies and on the modalities by which oppose to their installation (opt-out):

Cookie

Privacy Policy

LiveRail http://www.liverail.com/cookies-policy
Google http://www.google.co.uk/intl/it/policies/privacy
Kaltura http://corp.kaltura.com/privacy-policy
SpotXchange http://www.spotxchange.com/privacy-policy
Improve http://www.improvedigital.com/en/platform-privacy-policy
Tgadv http://www.tgadv.it/informativacookie
Zoomin http://www.zoomin.com/global/PrivacyPolicy
Mosaicoon https://plavidnetwork.com/about/#pl-policy
StickyADS http://www.stickyads.tv/privacy_policy/
Viralize https://viralize.com/cookie-policy/
Xaxis https://www.xaxis.com/static/view/privacy-policy-en
Adform http://site.adform.com/privacy-policy/en/
Sizmek http://www.sizmek.com/en/privacy-policy/
4W Marketplace http://www.4wmarketplace.com/privacy/

Using the interactive button to block these profiling cookies, You will receive in any case a technical cookie in order to memorise your preference. Please consider that, removing all the cookies from the browser, also this technical cookie could be removed and, therefore, you would have to express again your choice to block such cookies using the interactive button included in this policy.

E. How to manage the cookies and oppose to their use


There are several options to manage, disable and remove the cookies.

(1) Modify your browser settings

Please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies (technical, analytics and profiling):

Explorerhttps://support.microsoft.com/en-us/kb/196955/it
Chromehttps://support.google.com/chrome/answer/95647?hl=it
Firefoxhttps://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
Safarihttps://support.apple.com/kb/PH17191?locale=it_IT
Operahttp://help.opera.com/Windows/10.00/it/cookies.html

Please be careful in making your choice. Indeed, by blocking the receipt of all the cookies indiscriminately, including the technical ones, without providing a specific exception for the Source Website, you might be no more able to surf on the Source Website or to benefit, in whole or in part, of its functionalities. Furthermore, removing all the cookies from the browser, also the technical cookies could be removed and, therefore, you could remove the preferences set up by using the Source Website or no more find products or services included in your basket.

(2) Use our interactive instruments or those provided by third parties

In order to disable the analytics cookies, or the profiling cookies installed by the Company, you may simply use the instruments indicated in paragraphs C and D of this policy.

In order to disable third parties cookies, please inspect the privacy policies of the third parties installing profiling cookies (please see paragraph D above) in order to know the other instruments made available to You in order to manage, disable and cancel the cookies and, more in general, to oppose to their use. Please remember that, by disabling third parties cookies, (i) you oppose to their use not only on the Source Website, but on all the websites on which they are installed and (ii) the possibility to navigate on the Source Website and to use its functionalities will not be compromised in any manner whatsoever. When you disable the third parties cookies, you will display the banner related to cookies on the Source Website home page; in this case, however, closing the banner, surfing on the home page or clicking whatever element on the home page outside the banner, You will not receive any third party cookie being duly disabled.

(3) Use the Internet website www.youronlinechoices.eu/it/

Your Online Choices is an internet website managed by the no profit association European Interactive Digital Advertising Alliance (EDAA), the Italian version is available at the following address www.youronlinechoices.eu/it/, providing information on the behavioural marketing based on the profiling cookies (http://www.youronlinechoices.com/it/a-proposito) and allowing Internet user to easily oppose (opt-out) to the installation of the main profiling cookies installed by the marketing participants and used on the Internet websites (http://www.youronlinechoices.com/it/le-tue-scelte). Before using such instrument, We hereby recommend You to read carefully the service general terms and conditions available on the website Your Online Choices (http://www.youronlinechoices.com/it/condizioni-generali-di-servizio), the FAQs (http://www.youronlinechoices.com/it/faqs) and the user’s guidelines (http://www.youronlinechoices.com/it/help).

Use Your Online Choices consciously. Indeed, although Your Online Choises collects many of the most important marketing companies using cookies, certain third parties installing cookies through the web could not have adhered to Your Online Choices. Therefore, the use of Your Online Choices does not guarantee that you will not receive third parties cookies surfing the web. Furthermore, please remember that, by deleting all the cookies by Your browser, also the technical cookies released by Your Online Choices in order to remember your choices could be cancelled, making third parties cookies active again.

F. Other information

The Company can amend this privacy policy on the basis of legislative and regulatory provisions, or with the aim of making it compliant with the instructions issued by the competent supervisory authorities. For this reason, it is hereby recommended to control the same periodically.

As highlighted under the preamble of this policy, the Company collect and process certain personal data by means of the cookies conveyed directly on the Source Website (first part cookies). The Company acts as data controller of such data, in compliance with the provisions of the Privacy Code. Please note that we will process your data with electronic instruments only, in a much automatised manner and without any human intermediation. Therefore, our employees and coworkers will never access the content of your personal data obtained by means of cookies. Certain employees of ours and coworkers, appointed by us as data controllers, could make maintenance operations on IT systems that host your data, without the possibility to access their actual contents. The personal data could be memorised on servers managed by third parties (for example, providers of IT systems) or may be managed by online marketing specialised subjects, acting as external data controllers on the basis of a specific written appointment by the Company. We hereby inform you that, complying with the requirements and the guarantees provided under the law, your data could be transferred to Countries outside the European Economic Union that could not guarantee a level of privacy and personal data protection equal to the level of protection guaranteed by the Italian and European privacy laws. Your personal data will not be transferred to third parties data processors, nor will be disseminated.

G. Your rights

Pursuant to Article 7 of the Legislative Decree 30 June 2003, No. 196, you have the right to obtain confirmation of the existence or not of personal data pertaining to you and to know its content and source, verify the correctness of the same or require the integration, the update or the rectification of the same (Article 7 of Legislative Decree No. 196/2003). You have also the right to require the cancellation, anonymisation or the block of data processed in breach of the law, as well as to oppose in any event, for legitimate reasons, to their processing. In the end, you have the right to obtain a list of the external data controllers appointed by the Company. In order to exercise your rights, or to obtain any other information or clarification in relation to this policy, please contact the Company by means of registered letter with return receipt (to the following address Viale Sarca, 336 – 20126 Milan (MI) Italy )  or by e-mail (to the following address privacy@shiny.net).