Cookie Policy

Dear Visitor (hereinafter, "You" or the "User"),

This website wind.reconnects.com (hereafter the "Website") is owned by Reconnects Services Italy S.r.l., with registered office Corso Monforte, 2 – 20122 Milan (MI), Italy (hereinafter, "We" or the “Company”).

As our Website uses some of the so called "cookies" for different purposes, this cookie policy explains what the cookies are and how they are used on the Website. This cookie policy, also pursuant to Section 14 of the Regulation EU 2016/679 (the "Regulation"), explains how we collect such data, for what purposes and what your rights are.

Some cookies (so called first-party cookies) are stored directly by us. Through such cookies, the Company collects and processes some of your personal data. Other cookies (so called third-party cookies) are stored by third parties.

Please do read carefully this cookie policy and the general Privacy Policy of the Website in order to make an informed choice.

A. What are cookies and what are they used for.

Cookies are small text files that the websites visited by the user send directly to his/her terminal (usually to the browser). Such cookies are stored into the user's terminal in order to be retransmitted to the same websites when the user accesses them again (so called first-party cookies). During the browsing on a website, the user may receive on his/her terminal also cookies of different websites or webservers (so called third-party cookies); this happens because the visited websites contain items such as images, maps, sounds, specific links to pages of other websites that are hosted on a server other than the one on which the requested page is hosted. In other words, these are cookies that are set by a website different from the one that the User is currently visiting.

The cookies may be limited to a single browsing session (so called session cookies) and, in such case, they automatically disable when the User closes the browser. Some other cookies may have a preset expiry date and, in such case, they will remain stored and active in the User’s hard-disk until such expiry date, continuing to collect information in the course of the subsequent browsing sessions (so called permanent cookies).

Cookies are used for different purposes. Some of them are used to allow the user to visit a website and use its features (so called technical cookies). Some other cookies are used in order to collect statistical information, in aggregated or non-aggregated form, about the number of users who access a Website and how a website is used (so called monitoring or analytics cookies). Lastly, other cookies are used to track the User’s profile as a consumer and display advertising on a website which are consistent with Your interests (so called, profiling cookies).

The Website makes use exclusively of technical cookies and analytics cookies and does not make use of profiling cookies.

For further details about these categories of cookies please keep reading this cookie policy. Find out how they work and what they are used for and freely choose whether to provide or not Your consent to their use.

B. Technical cookies

Technical cookies are used on the Website for the sole purpose of allowing You to visit the Website and use its features. These cookies are always first-party cookies, as they are stored directly by us through the Website.

Some technical cookies are necessary to provide You with an optimized user experience or to allow your authentication on the Website, e.g. to purchase something on the Website or access your personal area (so called navigation cookies). Normally navigation cookies are session cookies and, therefore, once the internet browser is closed, they are automatically disabled.

Other technical cookies are useful to allow the User to save some of his/her preferences (e.g. the language or the country of origin) without having to reset such preferences each time You visits the Website (so called functionality cookies). For this reason, functionality cookies are often persistent cookies, because they remain stored in Your computer even after the interest browser has been closed, until the relevant expiry date or until you delete them from your browser.

As provided for by the applicable privacy laws, Your prior consent to the set-up of these cookies is not necessary. Obviously, you can freely decide to block the set-up of the technical cookies, by changing your internet browser settings (please refer to paragraph D, n. 1 to know how to do it). However, please consider that, by blocking the set-up of the technical cookies or deleting such cookies, the possibility to access the Website, use it in whole or in part, enable/disable specific features or receive specific services may be in whole or in part jeopardized.

C. Monitoring cookies or “analytics”

Analytics cookies are used on the Website to collect statistical information on the number of users accessing the Website and how they visit it, being it in an aggregate form or not.

The analytics cookies of this Website are third-party cookies, as they are not managed directly by the Company but by the relevant third parties.

Third-party analytics cookies are installed on the Website only subject to your consent, as these cookies are not anonymized and, therefore, other third parties might have access to disaggregated analytic data at an IP address level (in other words, through these cookies, third parties may theoretically trace back your identity through the IP address). Third-party analytics cookies used on this Website include:

Cookie Name Cookie Category Instructions for the opt-out
Google Analytics (Google LLC) third-party analytics cookie https://tools.google.com/dlpage/gaoptout

https://policies.google.com/privacy

For this reason, when you access the Website, a banner is displayed in order to inform you that (i) the Website uses third-party analytics cookies and that (ii) by closing the banner, scrolling the homepage or by clicking any element on the Webpage other than the banner, you give your consent to the use of such cookies. Should You give your consent for the set-up of the cookies in the said way, we will keep record of your consent through a technical cookie. By doing this, we will prevent You from visualizing the banner again during your future visits to the Website. Please do consider that, should you cancel this technical cookie from your browser through the process described under the following paragraph D, n.1), the record of your consent will be lost and, therefore, during your next visit to the Website, the banner on the cookies will be displayed again.

Obviously, you can freely decide to block the storing of analytics cookies at any time, and, in such case, the possibility to visit the Website or benefit of its contents will not be jeopardized in any manner whatsoever. If You would like to know how to do it, please read carefully the privacy policies of the relevant third parties by clicking on the links in the board above.

D. How to control and disable cookies and how to opt-out from their use

There are different ways to manage, disable or delete cookies:

(1) Change the settings of Your browser

Follow the instructions given by the developer of your Internet browser to find out how to control, disable or erase some or all of the cookies /technical and analytics):

Make your choices carefully. Rejecting all cookies, including the technical ones, without providing for an exception on the Website, will affect your browsing activity including the use of certain functionalities. Moreover, by blocking all cookies on the browser, also the technical cookies may be removed and, therefore, the preferences that you have set on the Website may be removed or you may not be able to use all the features of the Website.

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

To disable third-party cookies, please read the privacy policies of the relevant third parties who set- up analytics cookies (see paragraph C above) to know what tools are available to handle, disable and delete the cookies and, more in general, to opt-out from their use. Please remember that, by disabling third-party cookies, (i) you opt-out from their use not only on the Website but also from all other websites on which such cookies are used and (ii) the possibility to access the Website and use its features will not be jeopardized in any manner whatsoever. When You disable third party’ cookies, the cookie banner on the homepage will still be displayed; in this case, however, if you close the banner or scroll the homepage or click on any element on the of the homepage other than the banner, you will not receive any third party’ cookie that have been duly removed.

E. Further information

As highlighted in the introduction to this cookie policy, We collect and process certain of your personal data through the cookies that are managed via the Website (first-party cookies and third- party analytics cookies).

We act as controller of these data, in accordance with the provisions of the Regulation.

We process the data through the technical cookies for pursuing your and our legitimate interest in ensuring that the Website works correctly, and you can benefit of its functionalities in a secure manner (art. 6, paragraph 1, let. f) of the Regulation). We process the data through the analytics cookies for pursuing our legitimate interest in obtaining aggregate statistical data on how our users interact with the Website (art. 6, paragraph 1, let. f) of the Regulation).

We will process your data only by electronic means, in a totally automated manner and without human intervention. Therefore, our employees and collaborators will never access the content of your personal data obtained through cookies. Some of our employees and collaborates, who we have appointed as persons in charge of the processing, may perform maintenance operations on the IT systems that host your data, without ever being able to access their actual content.

Personal data may be stored on servers managed by our suppliers of IT services or may be accessed by such suppliers, which act as data processors on our behalf.

Some of our service providers are located in countries that do not belong to the European Economic Area ("EEA") or in turn entrust the processing of your personal data to sub-processors which are located in countries that do not belong to the EEA. These third countries do not offer adequate protection under the Regulation and, in relation to these third countries, there are no adequacy decisions of the European Commission. In order to protect your personal data, we or our suppliers have adopted the precautions required by the Regulations, transferring your personal data out of the EEA, relying on the appropriate guarantees provided for by the Regulation. Here is an overview of the out-of-EEA transfers of your personal data:

Provider /Data Processor Service Third country(ies) where the data are transferred to Legal basis
Google LLC Servizi di analytics https://www.google.com/about/datacenters/inside/locations/index.html

https://privacy.google.com/businesses/subprocessors
EU-U.S. Privacy Shield Agreement, recognized by an adequacy decision of the European Commission, according to the provisions of Article 45 of the Regulation - https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_it

F. Your rights

You have the right to exercise at any time, free of charge and without formalities the following rights as per articles from 15 to 22 of the Regulation: the right to request access to personal data (or the right to obtain from us the confirmation that data concerning you are being processed and, if so, to obtain the access to personal data, obtaining a copy themof and of the information referred to in Article 15 of the Regulation) and rectification (i.e. the right to obtain the correction of inaccurate data concerning you or the integration of incomplete data) or the erasure of the same (meaning the right to obtain the deletion of data concerning you, should any of the events indicated in Article 17 of the Regulation occur) or the restriction of the processing related to you (meaning the right to obtain, in the cases indicated in art. 18 of the Regulation, the marking of stored personal data with the aim of limiting their processing in the future), in addition to the right to data portability (i.e. the right, in the cases indicated in Article 20 of the Regulation, to receive from us, in a structured, commonly used and machine readable format the data concerning you, and to transmit it to another data controller without impediments).

You also have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point e) (performance of a task carried out in the public interest or in the exercise of official authority vested in the controller) or f) (legitimate interest) of Article 6(1) of the Regulation, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you such marketing, which includes profiling to the extent that it is related to such direct marketing.

To exercise your rights, please contact us by mail (to “Reconnects Services Italy S.r.l., with registered office Corso Monforte, 2 – 20122 Milan (MI) – To the kind attention of the Privacy Manager”).

Should you deem that the processing of your personal data infringes the Regulation, you have the right to lodge a complaint with the Italian supervisory authority (Garante per la protezione dei dati personali - www.garanteprivacy.it) or the competent supervisory authority of the EU Member State where you live or work or where the alleged breach has occurred (Article 77 of the Regulation) or to take a legal action before a court (Article 79 of the Regulation).

For further information on the cookies and on your rights, please consult the information material available on the website of the Italian Data Protection Authority: http://www.garanteprivacy.it/cookie.

Last update: 2nd July 2019