Cookie Policy

The following information is provided to the user in implementation of the provision of the Italian Authority for the protection of personal data of May 8^th, 2014 “Identification of simplified methods for the information and acquisition of consent for the use of cookies“.

Data Controller
Themis S.p.A.
Head Office: Via delle Poste n. 10
20123, Milano (MI)
Operational Office: Via Brescia n.13
20025, Legnano (MI)
privacy@themis-industries.com

WHAT ARE COOKIES?
Cookies are small text strings that a website can send, during navigation, to your device (be it a PC, a notebook, a smartphone, a tablet; they are usually stored directly on the browser used for navigation). The same website that transmitted them can then read and record cookies that are on the same device to obtain various types of information. Which ones? For each type of cookie there is a clearly defined role.

HOW MANY TYPES OF COOKIES ARE THERE?
There are two basic macro-categories, with different characteristics: technical cookies and profiling cookies.

Technical cookies are generally necessary for the correct functioning of the website and to allow navigation; without them you may not be able to view pages correctly or use certain services. For example, a technical cookie is essential to keep you logged in throughout your visit to a website, or to store your language settings, display settings, etc. Technical cookies can be further distinguished int

• navigation cookies, which guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access reserved areas);
• analytics cookies, assimilated to technical cookies only when used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site.
• functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, language, products selected for purchase) in order to improve the service provided to the user.

Profiling cookies are more sophisticated! These cookies are designed to profile the user and are used to send advertising messages in line with the preferences expressed by the user during navigation.

Cookies can still be classified as:

• session cookies, which are deleted immediately when you close your browser;
• persistent cookies, which – unlike session cookies – remain within the browser for a certain period of time. They are used, for example, to recognize the device that connects to the site and facilitate authentication operations for the user.
• first-part cookies, i.e. cookies generated and managed directly by the operator of the website on which the user is browsing.
• third-party cookies (third-part cookies), which are generated and managed by parties other than the operator of the website on which the user is browsing (usually by virtue of a contract between the owner of the website and the third party).

WHAT KIND OF COOKIES IS USED BY Themis S.p.A.

FIRST PARTY COOKIES
TECHNICAL COOKIES
Among these technical cookies, described above, we point out the essential or browsing cookies, which enable functions, without which it would not be possible to fully use the Site.
These cookies are first-party cookies.
Essential cookies cannot be disabled using the functions of the Site and the legal basis for any processing of personal data carried out through their use is the execution of contractual obligations related to the use of the Site.
Technical cookies also include the functionality cookies, mentioned above and also the so-called “analytics”, which pursue exclusively statistical purposes and collect information in aggregate form without the possibility of tracing back the identification of the individual user. In this case, the legal basis for any processing of personal data carried out is the legitimate interest of the Owner to optimize and improve the functioning of the Site and the browsing experience of Users.
The prior consent of the users is not required for the installation of such cookies. These cookies can be deactivated and/or deleted through the browser settings (see below).
If the use of cookies is blocked, the service offered to the User through the Site will be limited, thereby influencing the experience of using the Site.

Below, for each technical cookie used, we list: name, purpose of use and conservation time.

Essential cookies

Cookie denomination	Cookie tipology	Owner	Scope and stored data	Time persistence
ASP.NET_SessionId	Session technician	Themis S.p.a.	It facilitates navigation and stores the current session string	Expires at the end of the session or when you close the browser

Analytics Cookie

Cookie denomination	Cookie tipology	Owner	Scope and stored data	Time persistence
_ga	Analytics	Google	Used to identify the users
_gat	Analytics	Google	Used to accellerate the frequency of requests

THIRD PARTY COOKIES

The site uses Google Analytics with anonymized results and its cookies to anonymously monitor visitor behavior and measure site performance.

More information about Google Analytics cookies can be found by following the links:

• https://support.google.com/analytics/answer/6004245?hl=it
• https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

Visitors who do not want cookies related to Google Analytics can prevent them from being stored on their computers through the “Additional browser component for deactivating Google Analytics” made available by Google at https://tools.google.com/dlpage/gaoptout. To activate the component, which inhibits the system of sending information about the user’s visit, simply install it by following the instructions on the screen, close and reopen the browser.

Finally, below are the links to the most popular browsers, where there is information about how to disable the storage or delete cookies already stored on the browser:

• Internet Explorer
• Google Chrome
• Mozilla Firefox
• Apple Safari

Notice concerning children under 14 years old

Children under 14 cannot provide personal data Themis S.p.A. will not be in any way responsible for any collection of personal data, as well as false statements, provided by the minor, and in any case, if you notice its use, Themis S.p.A. will facilitate the right of access and cancellation forwarded by the legal guardian or by those who exercise parental authority.

Exercise of the rights of the person concerned

The data subject, in relation to the personal data subject of this privacy policy, shall be entitled to exercise the rights provided for by the EU Regulation below:

• Right of access by the data subject [art. 15 of the GDPR]: the data subject has the right to obtain from the Data Controller confirmation that his personal data is being processed and, in this case, access to the information expressly provided for in the aforementioned article, including the purpose of the processing, the categories of data and recipients, the retention period, the existence of the right of cancellation, correction or limitation, the right to propose a complaint, all the available information on the origin of the data, the exemplary and non-exhaustive any existence of an automated decision-making process pursuant to art. 22 of the Regulations, as well as a copy of their personal data.
• Right to rectification [art. 16 of the GDPR]: the data subject has the right to obtain from the data controller the correction and / or integration of the incorrect personal data concerning him, without unjustified delay;
• Right to erasure (‘right to be forgotten’) [art. 17 of the GDPR]: the data subject has the right to cancel his / her personal data without unjustified delay, if one of the reasons expressly provided by the aforementioned article exists, including as an example and not exhaustive the need for treatment with respect to the purpose, revocation of the consent on which the treatment is based, opposition to the treatment in case it is based on non-prevailing legitimate interest, unlawful data processing, deletion due to legal obligations, data of minors treated in the absence of the conditions of applicability expected by art. 8 of the Regulations;
• Right to restriction of processing [art. 18 of the GDPR]: in the cases provided by art. 18, including the unlawful processing, the contestation of the accuracy of the data, the opposition of the interested party and the loss of the need for treatment by the data controller, the information provided by the data subject must be processed only for storage unless the consent of him and the other cases expressly provided by the aforementioned article;
• Right to data portability [art. 20 of the EU Regulation]: the data subject, in cases where the processing is based on consent and contract and is performed by automated means, he may request to receive personal data in a structured format, commonly used and readable by automatic device , and he has the right to transmit them to another Data Controller;
• Right to object [art. 21 of the GDPR]: the data subject has the right to object to the processing of his / her personal data, in the event that the processing is based on a non-prevailing legitimate interest or is carried out for direct marketing purposes;
• Right not to be subject to a decision based solely on automated processing [art. 22 of the GDPR]: the data subject has the right to be not subjected to a decision, including profiling, based solely on automated processing (for example carried out exclusively through electronic tools or computer programs).

The description given above does not replace the text of the articles cited here which are referred to and that you can read exhaustively and fully below(artt. 15-22) .

Changes and updates
This privacy policy reports the date of its last update in the header.
Themis S.p.A. can make changes, update or additions to this privacy policy also as a consequence of any new additive legal obligations, regulations, Italian and European law.

Legal references about rights of data subject

Article 15
Right of access by the data subject
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
(f) the right to lodge a complaint with a supervisory authority;
(g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2.Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3.The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4.The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16
Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17
Right to erasure (‘right to be forgotten’)
1.The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1). 2.Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
3.Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defence of legal claims.

Article 18
Right to restriction of processing
1.The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
(d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
2.Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3.A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 19
Notification obligation regarding rectification or erasure of personal data or restriction of processing
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

Article 20
Right to data portability
1.The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: (a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and (b) the processing is carried out by automated means.
2.In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
3.The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4.The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21
Right to object
1.The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2.Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3.Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4.At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. 5.In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6.Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Article 22
Automated individual decision-making, including profiling
1.The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
2.Paragraph 1 shall not apply if the decision: (a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; (b) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or (c) is based on the data subject’s explicit consent.
3.In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
4.Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.