Cookie information​

COOKIE POLICY

B810 SpA , (Tax code and VAT number: 03378920361) (hereinafter “B810”), in the person of its legal representative pro tempore , with registered office in Reggio Emilia, via E. Lazzaretti , 2/1, as Data Controller pursuant to articles 4 no. 7) and 24 of EU Regulation no. 2016/679 (GDPR), illustrates , below , the cookie policy (“Policy”) referring only to this website www.a1-charge.com (Site) .

1. Legal framework .​​

1.1. The Policy is inspired by the following ( first and/or second level) Community and/or national regulatory provisions : (i) Directive no. 2002 /58/EC of 12.7.2012 (cd. ePrivacy Directive ), as amended by Directive no. 2009/136/EC; (ii) Art. 122 of the novella D.Lgs. n. 196/2003 (Privacy Code), which has received , within the national legal order , the ePrivacy Directive ; (iii) GDPR: artt . 4 n. 11), 7, 12, 13, 25 and 95 (as well as, in particular , at Considerando Nos . 30, 32 and 173); (iv) Guideline no . 5/2020 adopted on 4.5.2020 by the EDPB, replacing the Guidelines of 10.4.2018 signed by WP Art. 29; (v) Provision no. 231 of 10.6.2021 [doc. web n. 9677876] the signature of the Guarantor Authority for the protection of personal data (Privacy Guarantor); (vi) Recommendation no. 2/2001 of the WP Art. 29; (vii) Opinion n. 2/2010 of the WP Art. 29; (viii) Opinion n. 4/2012 of the WP Art. 29; (ix) Guideline no . 8/2020 of the EDPB; (viii) Provisions no. 224 of 9.6.2022 [doc. web n. 9782890],

n. 243 of 7.7.2022 [web doc. n. 9806053] and n. 254 of 21.7.2022 [web doc. n. 9808698] signed by the Privacy Guarantor .

2. Cookies and other tracking tools : definition and classification .

2.1. “ Cookies ” ¹ are , as a rule , strings of text that a website ( “publisher” or “ first party ”) visited by the user or a different website (“ third party ”) places and stores , directly (in thecase of a first party website ) orindirectly(via the latter, in the case of a third party website ) , within a terminal device available to the user : in this regard , the Privacy Guarantor has specified the fact that the information , encoded in cookies, may include both personal data pursuant to art. 4 no. 1) of the GDPR (e.g. IP address ; username ; email address ;unique identifier ) ​​and non- personal data pursuant to art. 3 no. 1) of EU Regulation no . 1807/2018 (e.g. language; type of device used).

Alongside (or in addition to) them , there may be ( and therefore be used ) ” other tracking tools “, which can be divided into ” active ” ( which have practically the same characteristics as cookies ) and ” passive ” (e.g. finger printing).

2.2. Beyond the intrinsic characteristics described , cookies (and other tracking tools ) can record different peculiarities from a temporal perspective (and, therefore , be considered ” session “ ² or “permanent” 3 , ^depending on their duration ), from a subjective point of view ( depending on whether the publisher acts independently or on behalf of a ” third party “) and , finally (but inparticular ) , based on the processing purpose pursued , so that they can be divided into two different (macro) categories :

• “ technical ”, used for the sole purpose of “ carrying out the transmission of a communication over an electronic communications network , or to the extent strictly necessary for the provider of an information society service explicitly requested by the contractor or user to provide such service ” ( art. 122 paragraph 1) of the Privacy Code ).

In this regard , the Privacy Guarantor has highlighted , within the Provision no. 231 of 10.6.2021 (in line with the previous Provision on the matter of 2014 ), that the ” analytics cookies ” ⁴ can well be included within the scope of cookies (or other tracking tools ) of a ” technical ” nature (and, therefore , can be used in the absence of prior acquisition of consent from the interested party ) , when certain conditions occur , aimed at precluding the possibility that , through their use , the direct identification of the interested party can be achieved (single out) ⁵ .

• “ profiling ”/” marketing ” (so-called non-technical), used to trace back to specific subjects, identified or identifiable , specific actions or recurring behavioral patterns in the use of the features offered ( patterns ) in order to group the different profiles within homogeneous clusters of varying sizes , so that the Data Controller can , among other things , also modulate the provision of the service in an increasingly personalized way beyond what is strictly necessary for the provision of the service , as well as send targeted advertising messages ( i.e., in line with the preferences expressed by the user while browsing the internet) .

3. Cookie installati sul Sito.

3.1. The following types of cookies have been installed (or may be installed, subject to obtaining specific consent from the user) on the Site:

4. Browser settings .

4.1. B810 highlights the possibility for the user to delete and block the operation of the cookies described in the previous art. 3 at any time using the appropriate setting functions present within the browser used: in this regard , B810 adds that , where the user decides to disable the technical cookies referred to in art. 2.2. point i ), the quality and speed of the services and features offered and made available on the Site could worsen .

You can find information on how to manage cookies with some of the most popular browsers by visiting the following web pages :

5. Rights of the data subject .

5.1. In relation to the user’s personal data, B810 informs that the data subject, pursuant to Article 4(1) of the GDPR, has the right to exercise the following rights, subject to the limitations set forth in Articles 2-undecies and 2-duodecies of the Privacy Code: right of access pursuant to Article 15 of the GDPR: the right to obtain confirmation as to whether or not personal data concerning the data subject is being processed, as well as the information referred to in Article 15 of the GDPR (e.g., purpose of the processing, retention period); right to rectification pursuant to Article 16 of the GDPR: the right to correct, update, or supplement personal data; right to erasure pursuant to Article 17 of the GDPR: the right to obtain the erasure, destruction, or anonymization of personal data, where the conditions listed in the same article are met; right to restriction of processing pursuant to Article 18 of the GDPR: a right with markedly precautionary connotation, aimed at obtaining restriction of processing where the conditions set forth in Article 18 apply; Right to data portability pursuant to Art. 20 of the GDPR: the right to obtain the personal data provided to B810 in a structured, commonly used, and machine-readable format (and, where required, to transmit that data directly to another data controller), where the specific conditions indicated in the same article apply (e.g., legal basis of consent and/or performance of a contract; personal data provided by the data subject); Right to object pursuant to Art. 21 of the GDPR: the right to obtain the permanent cessation of certain personal data processing; Right to lodge a complaint with the Supervisory Authority (i.e., the Italian Data Protection Authority) pursuant to Art. 77 of the GDPR: the right to lodge a complaint if you believe that the processing being analyzed violates national and EU data protection legislation.

5.2. In addition to the rights described in the previous art. 5.1., B810 specifies that , in relation to the personal data of the interested party, there exists , where possible and conferring , the right to exercise , on the one hand, the (sub)right provided for by art. 19 of the GDPR (“The data controller shall communicate to each recipient to whom the personal data have been disclosed any rectification or erasure of personal data or restriction of processing carried out pursuant to Article 16 , Article 17 , paragraph 1 , and Article 18 , unless this proves impossible or involves disproportionate effort . The data controller shall inform the data subject of those recipients if the data subject requests it ”), to be considered connected and linked to the exercise of one or more rights regulated in Articles 16, 17 and 18 of the GDPR ; on the other hand , B810 specifies that , in relation to the personal data of the interested party, there exists , where possible and conferring , the possibility to exercise the right provided for by art. 22 paragraph 1) of the GDPR (“The interested party has the right not to be subjected to a decision based solely on on automated processing , including profiling , which produces legal effects concerning him or her or similarly significantly affects him or her ” ) , without prejudice to the exceptions provided for in the following paragraph 2) .

5.3. In compliance with art. 12 paragraph 1) of the GDPR , B810 undertakes to provide the user with the communications referred to in articles 15 to 22 and 34 of the GDPR in a concise , transparent , intelligible , easily accessible form and using clear and simple language : such information will be provided in writing or by other means , including electronic means , or , at the user’s request , will be provided orally , provided that the user ‘s identity is proven by other means .

5.4. Pursuant to art. 12 paragraph 3) of the GDPR , B810 informs that it undertakes to provide the user with information relating to the action taken regarding a request pursuant to articles 15 to 22 of the GDPR without undue delay and , in any case , no later than one month from receipt of the request itself ; this deadline may be extended by 2 months if necessary , taking into account the complexity and number of requests (in this case , the Data Controller undertakes to inform the user of such extension and of the reasons for the delay , within one month of receipt of the request ) .

5.5. The user may exercise , at any time , the above -described rights (with the exception of the right pursuant to art. 77 of the GDPR) by using the contact details illustrated in art. 6.

6. Contact details .​

6.1. B810 can be contacted at the following address: info@b810group.it

6.2. The Data Protection Officer (DPO) pursuant to Article 37 of the GDPR , appointed by B810 , can be contacted at the following address: privacydpob810@baldiandpartners.it

7. Social plug-in.

7.1. In compliance with EDPB Guidelines no. 7/2020, B810 also specifies that it holds the status of joint Data Controller pursuant to Articles 4 no. 7) and 26 of the GDPR with some social media providers, by virtue of the installation, within the Site , of the relevant social plug-ins, which can be easily viewed and used on the Site .

Reggio Emilia (RE), 11/22/2023 ( last updated).

B810 S.p.A.

(in the person of his legal representative for the time being)

1 See Recital 30) of the GDPR (“Natural persons may be associated with online identifiers produced by the devices, applications, tools and protocols used, such as IP addresses, temporary markers (cookies) or other types of identifiers, such as radio frequency identification tags. Such identifiers may leave traces which, in particular when combined with unique identifiers and other information received from servers, can be used to create profiles of natural persons and identify them”), and art. 122 paragraphs 1) and 2) of the Privacy Code (“1. The storage of information in the terminal equipment of a contractor or user or access to information already stored is permitted only on condition that the contractor or user has given his consent after being informed using simplified methods. This does not prohibit any technical storage or access to information already stored if aimed solely at carrying out the transmission of a communication on an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the contractor or user to provide such service. For the purposes of determining the simplified methods referred to in the first paragraph, the Guarantor also takes into account the proposals formulated by the most representative associations at national level of consumers and the economic categories involved, also with the aim of ensuring the use of methodologies that ensure the effective awareness of the contractor or user. 2. For the purposes of expressing the consent referred to in paragraph 1, specific configurations of computer programs or devices that are easy and clear may be used usability for the contractor or the user…”); see also page 15) of Provision no. 231 of 10.6.2021 signed by the Privacy Guarantor: “…to date, there is still no universally accepted system of semantic coding of cookies and other tracking tools that allows for an objective distinction, for example, between technical ones and analytics or profiling ones, unless based on the indications provided by the owner himself in the privacy policy […] the hope that a general coding will be achieved quickly”.

2 Cookies designed to collect and store data while a useraccesses a website , and disappear once the user has closed the relevant browsing session .​ ​

3 Cookies suitable for lasting for a pre-established period of time(e.g. minutes ; months ; years).

4 Analytical cookies are usually used to evaluate the effectiveness of an information society service provided by a publisher ,to design a website or , finally , to help measure its traffic ( i.e. , the number of visitors , possibly broken down by geographical area , time slot of connection ) .

5 See Provision no. 231of 10.6.2021 signed by the Privacy Guarantor , page . 13/14 : “The structure of the analytics cookie must then provide for the possibility that it can be referred not only to one , but to multiple devices , so as to create reasonable uncertainty about the IT identity of the subject receiving it. This effect is usually achieved by masking appropriate portions of the IP addresswithin the cookie. Taking into account the representation of IP version 4 (IPv4) addresses at 32 bits, which are usually represented and used as a sequence of four decimal numbers between 0 and 255 separated by a dot , one of the measures that can be implemented in order to benefit from the exemption consists in masking at least the fourth component of the address, an option that introduces an uncertainty in the attribution of the cookie to a specific data subject equal to 1/256 (approximately 0.4%). Similar procedures should be adopted with reference to IP version 6 (IPv6) addresses , which have a different structure and a vastly larger address space ( being made up of binary numbers represented by 128 bits). The Guarantor also underlines the need for the use of analytics cookies to be limited solely to the production of aggregate statistics and for them to be used in relation to a single site or a single mobile application , so as not to allow the tracking of the navigation of the person who uses different applications or browses different websites . It is therefore understood that third parties , who provide the publisher with the web measurement service , must not combine the data , even if minimised , with other processes (customer files or statistics of visits to other sites , for example) nor transmit them in turn to other third parties , under penalty of an unacceptable increase in the risk of user identification ; except in the case in which the production of statistics carried out by them with the minimised data concerns multiple domains , websites or apps attributable to the same publisher or business group . It is however possible to consider it lawful , even in the absence of the adoption of the prescribed minimisation measures , the use of statistical analyses relating to multiple domains , websites or apps attributable to the same owner provided that the latter carries out the statistical processing himself , without in any case such analyses resulting in an activity which , going beyond the confines of a mere statistical count , actually takes on the characteristics of processing aimed at making decisions of a commercial nature ” .