Privacy notice for users on the use of cookies

Pursuant to the legislation applicable to protection of personal data (“Privacy Legislation”), including EU Regulation 2016/679 (“GDPR”), DATA4 Services S.A.S.U. (hereinafter, “DATA4”, or the “Company“, or “Data Controller”), as data controller, provides users (hereinafter the “Users” or in the singular, the “User”) with the following information regarding cookies installed on the following domain www.data4group.com (the “Website”).

Who is the Data Controller?

The Data Controller is DATA4 Services S.A.S.U., with registered office in 6 rue de la Trémoille, 75008 Paris (FR), fiscal code no. FR35493254643, to be contacted at the following e-mail address privacy@data4group.com. DATA4 Services S.A.S.U. is one of the companies of the DATA4 Group (the “DATA4 Group”).

What are cookies?

Cookies are text files and numbers that are installed while browsing on a website, in the memory of the device (PC, smartphone or tablet) connected to the Internet through the browser application installed therein.

Cookies, which are usually present in substantial numbers in users’ browsers and sometimes also with wide temporal persistence, are used for several purposes such as, by way of example and not limited to, for IT authentication, for monitoring of browsing sessions, for storage of information on specific user configurations in accessing a given server, etc.

There are different macro-categories of cookies:

(i)            “Technical cookies”, which are used to carry out browsing or to provide a service requested by the User. Such cookies are not used for further purposes and are usually installed directly by the Website’s owner or manager. In addition, these cookies can be grouped into:

  • browsing or session cookies, which guarantee the normal browsing and use of a website (allowing, for example, to purchase items online or authenticate to access certain sections);
  • functional cookies, which allow Users to navigate as a function of certain pre-determined criteria (such as, for example, language, products selected for purchase) in order to improve the quality of service provided to the same.

(ii)          “Analytics cookies”, which are used to monitor the use of a Website by Users for optimization purposes (number of visitors, pages browsed, time spent on the Website, etc.).

In order for analytics cookies to be equated to technical cookies, it is necessary that they are realized and used directly by the first party website (without the intervention of third parties) to improve its usability and it is necessary to prevent the possibility that, through their use, direct identification of data subjects is achieved, which is tantamount to preventing the use of analytics cookies that, due to their characteristics, can work as direct, unique identifiers of Users.

In order to consider analytics cookies, including third party cookies, as technical cookies, it is necessary that: (i) analytics cookies are only used for the production of aggregated statistics and in relation to a single website or a single mobile application, so as not to allow tracking an individual’s navigation across different applications or websites; (ii) at least, for third-party analytics cookies, the fourth component of the IP address is masked out; (iii) the third parties refrain from match such analytics cookies with any other information (such as customer records or statistics concerning visits to other websites) or from forwarding them to third parties.

For the installation of analytics cookies which can be assimilated to technical cookies, the Users’ prior consent is not required; where, however, analytics cookies cannot be assimilated to technical cookies, the Users’ consent to their installation is then required;

(iii)         “Profiling cookie”, which are intended to create User’s profiles and are used to send targeted advertising messages in line with the preferences expressed by the user in the context of his/her web-browsing activities. Due to the particular invasiveness that these cookies may have on the private sphere of the Users, the Privacy Legislation provides that User shall be adequately informed about the use of such cookies and express his/her valid consent for the installation of the same.

For the installation of profiling cookies, the Users’ prior consent is therefore necessary, which should be provided after the User has been informed in a simplified manner.

Moreover, cookies may be installed directly by the Website visited by the User (also called “first party cookies”), or they may be installed by other websites (also called “third party cookies”).

Lastly, under the temporal prospective, cookies can be divided into: (i) “persistent cookies”, i.e. cookies that are permanently stored on the User’s device until a predetermined expiry date (minutes, days, years); (ii) “session cookies”, i.e. cookies that are automatically deleted when closing the browser.

What cookies does the Website use and for what purposes?

When the User connects to the Website, the following cookies may be installed on the User’s device:

(i)               Technical cookies

These cookies are necessary in order to allow the operation of the Website and cannot be deactivated within Company’s systems. They are usually set only in response to actions taken by the User that constitute a service request, such as setting privacy preferences, logging in, or filling out forms. It is possible to set the browser so that it blocks these cookies but, as a result, some parts of the Website will not work properly. These cookies do not store any personal data.

For the installation of technical cookies, the Users’ prior consent is not necessary.

Technical cookies
Cookie name Domain Ownership of cookies Duration Purposes Cookie desactivation mode
visit .data4group.com 3rd Party Session Allows to anonymously distinguish Users N/A
visitor .data4group.com 3rd Party 12 months Anonymously consolidate all the pages viewed during a visit N/A
wp-wpml_current_language .data4group.com 1st Party Session Stores the current language. This cookie is enabled by default on sites that use the Language filtering for AJAX operations feature.
moove_gdpr_popup .data4group.com 1st Party 12 months To store cookie consent preferences N/A
CONSENT .google.com 3rd Party 24 months To store cookie consent preferences N/A

(ii)             Analytics cookies

Analytics cookies that cannot be assimilated to technical cookies are those that, due to their features, may be direct and unique identifiers of Users. They therefore allow the collection of statistical information in NON-aggregated form regarding the number of Users and how they visit the Website.

The installation of these cookies requires the User’s consent.

Analytics cookies
Cookie name Domain Ownership of cookies Duration Purposes Cookie deactivation mode
_ga_* .data4group.com 3rd Party 12 months To store and count pageviews Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
_ga .data4group.com 3rd Party 24 months To store and count pageviews Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
_pk_ses.* .data4group.com 3rd Party 30 minutes Short lived cookies used to temporarily store data for the visit Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
_pk_id.* .data4group.com 3rd Party 13 months Used to store a few details about the User such as the unique visitor Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
AnalyticsSyncHistory .linkedin.com 3rd Party 30 days Used to store data at the moment when synchronization has been carried out with the Cookie LMS_Analytics Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
UserMatchHistory .linkedin.com 3rd Party 30 days Used for the identifier synchronization process. This allows you to record the time of the last synchronization in order to avoid repeating the synchronization process frequently Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
lidc .linkedin.com 3rd Party 24 hours To optimize the selection of data centers Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
li_sugr .linkedin.com 3rd Party 90 days Used to find a probability correspondence with the identity of a user outside the designated countries Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
bcookie .linkedin.com 3rd Party 12 months Browser cookie to identify each device accessing LinkedIn to detect any abuse on the platform and for diagnostic purposes Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
li_gc .linkedin.com 3rd Party 6 months Used to store the consent of invited users concerning the use of cookies for non -essential purposes Disallow Analytics Cookies following our “Cookies desactivation mode” Section below

(iii)            Profiling cookies

These cookies may be set through our Website by our advertising partners. They can be used by these companies to build a profile of the User’s interests and show the User relevant ads on other websites. They do not collect personal data directly, but are based solely on identifying the User’s Internet browser and device. If the User does not accept these cookies, the User will receive less targeted advertising.

The installation of these cookies requires the User’s consent.

Profiling cookies
Cookie name Domain Ownership of cookies Duration Purposes Cookie deactivation mode
_hjSessionUser_{site_id} .data4group.com 3rd Party 12 months Set when a User first lands on a page.

Persists the Hotjar User ID which is unique to that site. Hotjar does not track users across different sites.

Ensures data from subsequent visits to the same site are attributed to the same user ID

 Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
_gcl_au .data4group.com 3rd Party 3 months To store and track conversions Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
_hjFirstSeen .data4group.com 3rd Party Session Used to store data at the moment when synchronization has been carried out with the Cookie LMS_Analytics Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
_hjSession_{site_id} .data4group.com 3rd Party Session Holds current session data.

Ensures subsequent requests in the session window are attributed to the same session.

 Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
_hjIncludedInSessionSample_{site_id} .data4group.com 3rd Party 2 minutes, extended every 30 seconds Set to determine if a User is included in the data sampling defined by your site’s daily session limit. Disallow Analytics Cookies following our “Cookies desactivation mode” Section below
_hjAbsoluteSessionInProgress .data4group.com 3rd Party 30 minutes duration, extended on User activity Used to detect the first pageview session of a User. Disallow Analytics Cookies following our “Cookies desactivation mode” Section below

Please note that:

  1. first party cookies are under the direct and exclusive responsibility of the Data Controller;
  2. third party cookies are under the direct and exclusive responsibility of the third party itself.

It follows that third party cookie providers are also required to comply with the Privacy Legislation. For this reason, the Users shall refer to the links to the third party’s webpages, where they can find the third party’s cookie consent forms (where necessary) and the related privacy notice.

How can the User manage and/or deactivate cookies?

When the User visits the Website for the first time, he/she will be informed about the type of cookies used by the Website by means of an information banner that appears immediately at the top of the Website. In the same banner, the User has the possibility to manage his/her preferences regarding the installation of cookies through appropriate commands. Following the display of the banner, by continuing to browse the Website, the User accepts the use of technical cookies, as well as those for which the User has expressly given consent (e.g., analytics cookies).

However, it is always possible to modify the cookie settings at any time by clicking here: Privacy Preference Center.

How can the User manage his/her cookie preferences through the browser?

Each browser allows the User to limit and delete cookies. The User can manage cookie preferences directly in his/her browser and prevent – for example – the installation of third-party cookies.

Please find below the instructions[1] to deactivate the cookies directly through the configuration settings of the main browser applications:

Internet Explorer
  1. Open Internet Explorer;
  2. Click on the “Tools” button and then on “Internet Options”;
  3. Select the “Privacy” tab and, under “Settings,” select “Advanced,” then choose whether to accept, block, or be prompted for first-party or third-party cookies.
Microsoft Edge
  1. Open Microsoft Edge;
  2. Select “Settings and More” in the upper right corner of the browser window;
  3. Select “Settings,” then select “Privacy, Search and Services.”
  4. Select “Choose items to delete” under “Clear browsing data” and then “Clear browsing data now.”
  5. Select a time range in “Time range”;
  6. Select “Cookies and other site data,” then “Delete now.”
Google Chrome
  1. Open Google Chrome;
  2. Click, in the upper right corner, on the button  and then select “Settings.”
  3. In the “Privacy and Security” section, click on “Cookies and other site data.”
  4. In the opened tab you can select an option (i.e. accept all cookies, block all cookies, block third-party cookies in incognito browsing modes, block third-party cookies) and save your preferences.
Firefox
  1. Open Firefox;
  2. Press on the menu button , top right, and then select “Settings.”
  3. Then select the “Privacy and Security” tab;
  4. In the “Advanced Anti-Tracking Protection” section, select the “Custom” option and check the “Cookies” box;
  5. Use the drop-down menu to select the types of cookies to block (i.e. cookies from unvisited websites, all third-party cookies, or all cookies);
  6. Close the “about: preferences” page, the changes made will be saved automatically.
Opera
  1. Open Opera;
  2. Click on “Settings” in the browser menu and select “Go to full settings.”
  3. Select the “Confidentiality & Security” item and then click on “Site Setting.”
  4. Click on “Cookies and Site Data” and select your preferences (i.e. accept all cookies, block third-party cookies in private mode, block third-party cookies, block all cookies), the changes you make will be saved automatically.
Safari
  1. Open Safari;
  2. Choose “Preferences” in the toolbar, then select the “Privacy” panel in the dialog box that follows;
  3. In the “Accept Cookies” section you can specify if and when Safari should save cookies from websites. For more information click on the “Help” button (marked with a question mark);
  4. For more information about the cookies that are stored on your computer, click on “Show Cookies”.

After these operations, however, some functions of the Website may not be performed and/or work properly.

With whom are the data collected by using cookies shared?

The data collected by using cookies may be processed by Company’s personnel, in their capacity as authorized persons pursuant to the Privacy Legislation.

Such data may also be processed by companies which carry out technical and organizational activities on behalf of the Company. These companies are direct collaborators of the Company and operate by virtue of a specific deed of appointment as data processors.

The list of all appointed data processors involved in processing operations through the Website is constantly updated and is available upon request by sending a communication to the e-mail address privacy@data4group.com.

Personal data collected by using cookies will not be shared to third parties and will be processed exclusively within the European Economic Area. Should the need to transfer data outside the European Economic Area arise, the Company will ensure that such transfers are carried out only in presence of appropriate safeguards pursuant to Article 46 of the GDPR, as better described in this Cookies Privacy Notice.

Data collected by using cookies will not be disseminated.

What rights can User exercise?

The User, as data subject, in accordance with the law, will always have the right to withdraw at any time his/her consent, where given, which does not affect the lawfulness of processing based on consent before its withdrawal,as well as to exercise, at any time, the following rights:

  1. the “right of access” and, specifically, the right to obtain confirmation as to whether or not personal data concerning the User are being processed and the communication of such data in an intelligible form;
  2. the “right to rectification” i.e. the right to request the rectification or, if interested, the integration of personal data;
  3. the “right to erasure” i.e. the right to request the erasure or the anonymization of personal data that have been processed unlawfully, including data whose storage is unnecessary for the Purposes for which they were collected or further processed;
  4. the “right to restriction of processing” i.e. the right to obtain from the Data Controller the limitation of the processing in certain cases provided for under the Privacy Legislation;
  5. the right to request the Data Controller to indicate the recipients to whom it has notified any rectification or erasure or restriction of processing (carried out in accordance with Articles 16, 17 and 18 GDPR, in fulfillment of the notification obligation unless this proves impossible or involves disproportionate effort);
  6. the “right to data portability” i.e. the right to receive (or transmit directly to another data controller) personal data in a structured, commonly used and machine-readable format;
  7. the “right to object”, i.e. the right to object, in whole or in part:
    •       the processing of personal data carried out by the Data Controller for its own legitimate interest;
    •       the processing of personal data carried out by the Data Controller for direct marketing or profiling purposes.

In the above cases, where necessary, the Data Controller will inform the third parties to whom the User‘s personal data have been disclosed of his/her exercise of rights, unless it is not possible or is too onerous and, in any case, in accordance with the provisions of the Privacy Legislation.

It is expressly understood, as provided in Article 21 of the GDPR, that in the event that the data subject exercises his/her right to object, the Data Controller will refrain from any further processing of the personal data, unless the Data Controller demonstrates the existence of binding legitimate reasons to proceed with the processing that override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of a right in court.

In any case, the Company – where it has reasonable doubts as to the identity of the data subject making the request referred to in Articles 15 to 21 of the GDPR – may request additional information to confirm the identity of the data subject.

How can I exercise my rights?

The User is entitled to exercise his/her rights at any time in the following manner:

–             by e-mail, to the address: privacy@data4group.com

–             by sending a letter to the address of the registered office of DATA4 as indicated in this privacy notice.

The Data Controller hereby informs the User that, pursuant to the Privacy Legislation, he/she has the right to lodge a complaint with the competent supervisory authority (in particular in the Member State of User’s habitual residence, place of work or place of the alleged breach), if he/she is of the opinion that his/her personal data are being processed in a way that would lead to breaches of the GDPR.

In order to facilitate the exercise of the right to lodge a complaint, the name and contact details of the European Union Supervisory Authority are available at the following link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Last update on July 2024

[1] Please note that these might have been changed from time to time by the browsers’ providers.