Cookie policy for users navigating on N&TS GROUP’s website pursuant to art. 13 of EU regulation no. 2016/679

This disclosure describes the management methods of the N&TS GROUP website, accessible at https://netsgroup.com/en/ (the “Site”) with regards t o cookie usage and the related processing of personal data of users browsing it.

N&TS GROUP discloses that it uses cookies in accordance with Regulation (EU) 2016/679 (European Regulation on the protection of personal data; “GDPR”), Legislative Decree 196/2003 and subsequent amendments (Code on the protection of personal data), Directive 2002/58/EC, the Provision of the Guarantor for the protection of personal data (“Guarantor Privacy”) “Identification of simplified procedures for the information and the acquisition of consent for the cookie usage” dated 8 May 2014, as well as in accordance with the subsequent “Clarifications on the implementation of the cookie legislation” dated 5 June 2015 and the “Cookie guidelines and other tracking tools” of 10 June 2021.

1. Identity and contact data of Data Controller and Data Protection Officer (DPO)

Data Controller: N&TS GROUP Networks & Transactional Systems Group S.p.A., con sede operativa in Milanofiori Strada 4 Palazzo A5 – 20057 Assago (MI) Italia.
Contact info: Tel. +39 02 822765.1 – E-mail legal@netsgroup.com

DPO: Frareg S.r.l. – Viale Jenner 38 – 20158 Milano (MI) Italia.
Contact info: Tel. +39 02 69010030 – E-mail dpo@frareg.com

2. Cookies

Cookies are simple text files sent by this Site and stored by your Internet browser on your computer or other device (such as tablet or smartphone) you use. The collected data can be sent:

to the servers of the owner and/or manager of the Site (i.e. first party cookies);
to third parties with respect to N&TS GROUP (i.e. third party cookies). Unless otherwise specified, please note that third-party cookies fall under the direct and exclusive responsibility of that very same operator; therefore, information on privacy and their use can be found directly on the websites of their respective managers.

Taking into account the indications of the Guarantor Privacy and the opinions issued in the European context by the Working Group pursuant to art. 29 (EDPB), cookies can be traced back to the following categories:

Necessary cookies, i.e. technical ones
Necessary cookies, or technical cookies, are essential for the transmission of a communication on a data network; therefore, they are essential for the basic functioning of the Site and for the provision of the service you requested. The Site will not function as intended without them. Cookies are classified as:
- session or navigation cookies: these are cookies which are not stored continuously on your own terminal, they are eliminated when the browser is closed and are strictly limited to the transmission of session identifiers necessary to allow for safe and efficient browsing of the Site;
- functionality cookies: they make it possible for you to remember the settings of the Site you choose, such as language or privacy preferences, in order to improve the services and the browsing experience.
These cookies do not store personal identification data.
With regard to these types of cookies, it is not necessary to obtain your prior and informed consent.
Profiling cookies
Profiling cookies are useful to bring back to specific, identified or identifiable subjects, specific actions or recurrent behavioural patterns in the use of the offered features (patterns) in order to group the different profiles within homogeneous clusters of different sizes, so that it is possible for the holder, among other things, to modulate the provision of the service in an increasingly personalised manner beyond what is strictly necessary for the provision of the service, and to send targeted advertising messages which is in line with the preferences expressed by the user in the context of web browsing. Profiling cookies present on the site are classified into the following categories:
- Functional cookies
  Functional cookies help perform certain features such as sharing the Site’s content on social media platforms, collecting feedback and other third-party features.
- Analytical cookies
  Analytical cookies can be used to evaluate the effectiveness of a service, to design a website or to measure its traffic.
  Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information about metrics regarding the number of visitors, bounce rate, traffic source, etc.
- Performance cookie
  Performance cookies are used to understand and analyse key website performance indexes which help provide visitors with a better user experience.
- Advertising cookies
  Advertising cookies are used to provide visitors with personalized advertisements based on the previously visited pages and to analyse the effectiveness of the advertising campaign.

2.1 Cookies used by the N&TS GROUP Website

This Site uses Necessary cookies (or technical cookies) to facilitate your navigation and allow for the correct use of the site itself. These types of cookies are not subject to your explicit consent, as they are necessary for a correct navigation within the Site.

All other profiling cookies, including those belonging to third parties, are introduced to optimize your experience and to allow N&TS GROUP to gain detailed information on its Site’s usage. These cookies will only be enabled with your consent. If you disable them, the Site may not function properly.

The N&TS GROUP Website does not utilise its own cookies for marketing and/or tracking purposes.
To view the complete and always up-to-date list of third-party cookies and to obtain more information about them, please consult the Website’s cookie banner (links in the “Customise” area of the cookie banner).

It is recommended you carefully review the information and policies relating to the use of cookies drawn up by third parties, in order to become aware of any changes made to them by the respective third parties and independent of N&TS GROUP as well.

3. Managing Consent Settings

During your first visit to the Site, you will be shown a popup with a brief explanation of the cookies used (cookie banner), through which you must confirm your choice to accept all cookies used by the Site, refuse all cookies used by the Site, or accept only technical cookies used by the Site. You must then save your preference to allow for N&TS GROP to utilise the cookie category, as described in this policy. You can disable cookies through your browser.

4. Enable/disable and delete cookies

You can use your browser to delete cookies automatically or manually. You can also change the settings of your Internet browser to receive a message each time a new cookie is placed. For more information on these options, you can consult the instructions found inside the Help/Support section of your browser related to cookie management.

Below are the web addresses (links verified up to the date of this document) of some of the most popular browsers’ cookie management settings:

Google Chrome – https://support.google.com/chrome/answer/95647;
Mozilla Firefox – https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
Apple Safari – https://support.apple.com/en-us/HT201265
Microsoft Internet Explorer & Edge – https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

However, you should remember that the Site may not function properly if third-party cookies are disabled.

5. Rights of the subject

According to the provisions of the GDPR, the subject has the following rights in relation to the Controller:

to obtain confirmation that personal data concerning them are being processed or not and, if so, obtain access to such personal data (Right of access Art. 15 GDPR);
to obtain the rectification of inaccurate personal data concerning them without undue delay (Right of rectification Art. 16 GDPR);
to obtain the cancellation of personal data concerning them without undue delay and the Data Controller is obliged to delete personal data without undue delay, if certain conditions are met (Right to be forgotten Art. 17 GDPR);
to obtain restriction of processing in certain cases (right to restriction of processing Art. 18 GDPR);
to receive in a structured, commonly used and machine-readable format the provided personal data concerning them and has the right to transmit such data to another Data Controller, without hindrance by the Data Controller to whom they have provided such data, in certain cases (Right to data portability Art. 20 GDPR);
to object at any time, for reasons related to their particular situation, to the processing of personal data concerning them (Right of opposition Art. 21 GDPR);
to receive, without undue delay, communication of the personal data breach suffered by the Data Controller (Art. 34 GDPR);
to revoke their express consent at any time (Conditions for consent Art. 7 GDPR).

Where applicable, the data subject may exercise the above rights, including via simple e-mail to the Data Controller. The Data Controller reserves the right to verify the identity of the data subject before taking action on the basis of their request.

The interested party moreover has the right to submit a complaint to the Guarantor Authority, through the contact methods defined by it.

6. Changes to the Policy

The Data Controller reserves the right to change this disclosure periodically. In the event of substantial changes, the Data Controller will also communicate such changes via e-mail.

Latest update dated: August 14^th, 2023