This cookie policy (version no.3 dated 29 May 2024) is provided by Adasta Media S.r.l. and concerns the activities that Adasta Media and/or the third parties indicated in paragraph 4.2 below carry out in order to provide digital advertising services to the clients of Adasta Media.
1. INTRODUCTION – WHO ARE WE?
Dear Visitor (hereinafter, “You” or the “User”), This page is the property of the company Adasta Media S.r.l. with registered office in Via Privata del Gonfalone n.3, Milan, Italy, VAT no. and Tax Code 10128870960, registered in the Register of Companies of Milan under number 10128870960 (hereinafter, the “Company” or “Adasta Media”). Our Company operates as a digital advertising agency and carries out activities for the efficient management and valorization of the space available on the publishers’ web pages (hereinafter, the “Services”). Therefore, we act as a third party of the publisher’s/advertiser’s website and/or mobile app that You have just come from (hereinafter, the “Website”). In some cases, we act as an intermediary between the publisher of the aforementioned Website and other third parties (as better described in paragraph 4.2 below).
2. HOW CAN YOU CONTACT US?
Users can contact the Company at any time for any information on this cookie policy, using the following methods: • by sending a registered letter with return receipt to the registered office of the Company (Via Privata del Gonfalone n.3, 20123 – Milan, Italy); • by sending an email to: info@adasta.it. You can also contact the Data Protection Officer (DPO) of the Company, whose contact details are as follows: dpo@adasta.it.
3. WHAT DO WE DO? WHAT ARE COOKIES AND WHAT ARE THEY USED FOR?
We operate in the field of digital advertising, working with third-party publishers, advertising agencies and/or clients, as well as other third parties, to deliver advertising messages relevant to the users browsing the internet and to measure advertising campaigns carried out on behalf of advertising agencies/clients, also using owned and third-party technology. Technologies such as cookies and/or other tracking tools similar to cookies are used through our Services for various purposes, in this cookie policy we would like to explain what these tools are and how they are used and controlled by Adasta Media (paragraph 4.1 below) and/or by third parties other than Adasta Media (paragraph 4.2 below) through the Website.
Pursuant to art. 13 of the Regulation EU 2016/679 of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter, the “Regulation”) and pursuant to Italian Legislative Decree no. 196/2003 and subsequent amendments and additions (hereinafter, the “Code” and, together with the Regulation, the “Applicable Law“), in this cookie policy You will find links to the privacy policies published by third parties, which we ask You to read carefully. Cookies are small text files that visited websites send directly to the user’s terminal (usually to the browser), in which they are stored in order to be retransmitted to the same websites the next time the same user visits them (so-called first-party own cookies).
While browsing a website, the user may also receive cookies from different websites or web servers on his terminal (so-called third-party cookies). This happens because the visited website may contain elements such as, for example, images, maps, sounds, specific links to web pages of other domains that reside on servers other than the one on which the requested page is located. In other words, those cookies that are set by a website other than the one You are currently visiting. Cookies can have a lifetime limited to a single browser session (so-called session cookies), and in that case they are automatically deactivated when the user closes the browser. In other cases, cookies can have a predetermined expiration date and, in that case, they will remain stored and active until their expiration date, continuing to collect information over the course of different browser sessions (so-called persistent cookies). Cookies are used for different purposes. Some are necessary to enable the user to navigate the websites and take advantage of their functionality (so-called technical cookies). Others are used to obtain statistical information about the number of users accessing the websites and how they are used (so-called tracking or analytics cookies), in aggregated or non-aggregated form. Some others are aimed at profiling You as a consumer and display advertisements that may be interesting for You, as they are consistent with your tastes and consumption habits (so-called profiling cookies). Cookies are only one of the tools used by our Services. In fact, it is also possible that other tracking tools (such as pixels, Software Development Kits (so called SDK), etc.) may be used for the same purposes of profiling, delivery of personalized advertising and content, measurement and improvement of the Services, as set out below.
4. PROFILING TOOLS USED BY ADASTA MEDIA
4.1 WHAT TECHNOLOGIES DO WE USE
The Company uses cookies for:
- Profiling purposes: creation of the User’s profile based on his/her preferences and tastes manifested while browsing the internet;
- The provision of personalized advertising (marketing and retargeting) and content: provision of advertising messages or content consistent with the User’s profile so that the advertisement/content is more interesting;
- Measuring purposes: analysis and monitoring of the performance of advertising campaigns delivered by Adasta Media, including for the purpose of providing aggregated statistical analysis to advertisers and publishers of the Websites and/or providing recommendations on the delivery of advertising campaigns in line with the preferences expressed while browsing;
- Analysis, development, improvement and optimization of the Services.
Pursuant to the Applicable Law, your prior consent is required to install profiling tools. For this reason, when You access the Website a specific banner or a consent management platform (so-called “CMP”) will be displayed, informing You that (i) profiling cookies are used on the Website and that (ii) by clicking on the appropriate button provided therein, You will provide your consent to the use of cookies. Should You express your consent to the use of cookies through the mechanism provided by the Website’s publisher, a record of your consent will be kept.
As a proof of its commitment, Adasta Media is a member of the IAB Europe Transparency & Consent Framework (hereafter, “IAB Framework“) – the European framework for transparency and consent management – and complies with the “Specifications and Policies” of the IAB Framework. Adasta Media’s Vendor ID, in the context of the IAB Framework, is 1205. The User will be able to consult further information related to the IAB Framework on the IAB Europe website.
If the CMP used on the Website is connected to the IAB Framework, the Company may process metadata related to the granular choices made by the User through the CMP: in particular, the expression of consent, the detail of the granular purposes for which the User has given consent, as well as the choice to continue browsing by maintaining the default settings by pressing the relevant button provided by the CMP used by the Website’s publisher.
Adasta Media processes Users’ personal data, in order to provide the Services, using the tools described below, through which it installs – with the User’s consent – cookies and/or other tracking tools on the Website:
| Tool | Description |
|---|---|
| Google Ad Manager: Ad Server provided by Google Ireland Limited (hereinafter “Google”) | Adasta Media uses Google’s Ad Server on the Website to install profiling tools, through which it collects data and information related to the User, such as: IP address, approximate information on the geographic area from which the User operates, http protocol data (e.g. visited web address or URL), information related to the User’s interaction with the advertising campaign (e.g. clicks, percentage of completion of viewing the video advertisement), advertising identifiers (IDFA, AAID), cookie id, server log. The maximum duration is 6 months. To disable the profiling tools of the Ad Server used by the Company, change the settings of your browser (as better indicated in paragraph 5 below) or use the tool made available by Google at the following link. |
| Weborama DMP: Data Management Platform (so-called “DMP”) provided by Weborama SAS (hereinafter “Weborama”) | Adasta Media uses Weborama’s DMP, i.e. a technological infrastructure to collect and use the data of data subjects browsing the Website on which the DMP is used, in order to create clusters of users profiled on the basis of their browsing behaviour and/or their characteristics, also inferred through statistical algorithms specific to the DMP. In particular, profiling tracking tools are installed on the Website by Weborama, on behalf of the Company. The maximum duration of the tools installed by the DMP used by the Company is 13 months. In order to disable the profiling tools of the DMP used by the Company, change your browser settings (as better indicated in paragraph 5 below) or use the method described by Weborama at the following link. |
| Google Adsense | Use of Google’s AdSense service. After the delivery, viewing of a banner by the User (so-called impressions), clicks or other activity that results in a call to Google’s servers, AdSense uses profiling tools to improve the advertising delivered on the Websites of Adasta Media’s publishers (for example, AdSense cookies could be used to target advertising based on what is relevant to the User or to prevent the User from viewing ads that have already been shown in the past). In order to disable the profiling tools of Google AdSense used by the Company, You can change the settings of your browser (as explained in paragraph 5 below). It is also possible to disable the personalization of the ads by Google using the Google Ads settings, so that You will no longer receive personalized advertising from Google. |
| Smart Adserver | Adasta Media uses the services provided by Smart AdServer SAS, through which profiling tools are installed on the Website in order to collect data and information about the User, such as: the IP address and browser ID, technical information about the device (browser, operating system, screen size), information about the geographic location of the device when the User accesses a Website, information about other identifiers assigned to the User’s device (such as the IDFA or AAID), as well as information about the User’s activity, including the web pages and mobile apps visited or used. The data is processed for the delivery of contextual advertising (e.g., delivering an ad related to the content of the web page the User is visiting) and/or advertising based on the User’s interests and/or location, for the optimization of delivered campaigns (e.g., limiting the number of times a data subject sees a particular ad), and for the preparation of aggregate reporting related to the campaigns delivered. The maximum duration is thirteen months, depending on the cookie or other tool storing the data (more information can be found at the following link). To disable Smart AdServer’s profiling tools used by the Company, You can change your browser settings (as explained in more detail in paragraph 5 below) or use the tool provided by Smart AdServer (see the following link). |
| TNCiD Technology developed by The Newco S.r.l. (hereinafter “The Newco”) |
Use of TNCiD Technology, developed by The Newco for the collection and management of cookieless data. Through the use of a javascript code inserted on the Websites upon the User’s consent, TNCiD Technology allows to (i) collect a series of signals directly from the User’s browsing environment (such as, for example, the browser used); (ii) associate the aforesaid information with an identifier, i.e. a probabilistic ID, created by the same technology; as well as (iii) associate, to such probabilistic ID, deterministic elements (such as, for example, an e-mail address collected during the log-in procedure on the Website). TNCiD technology allows us to carry out operations of comparison of several databases (so-called clean room), by means of closed “data bunkers” that are connected with other “bunkers” referring to other subjects (all users of The Newco’s TNCiD technology). For all subsequent processing operations, i.e.:
Adasta Media acts as data controller. |
The legal basis for the processing carried out by Adasta Media is the prior consent of the User (art.6, paragraph 1, letter a) of the Regulation collected through the methods mentioned above. You are, of course, free to not give your consent to the installation of profiling tracking tools used by Adasta Media and to opt-out of using them at any time, without this affecting your ability to visit the Website and enjoy its content in any way.
4.2 TOOLS USED BY THIRD PARTIES OTHER THAN ADASTA MEDIA
The following third-party subjects act as autonomous data controller and install profiling tools on the Website (below is an indication of the links to the information pages created by the developers of these tools, also containing information on how to opt-out of installing them, and on the relevant retention periods):
The ad-serving technologies used by Adasta Media may also enable the use of cookies and/or other tracking tools linked to advertising messages by advertisers or other third parties, in order to collect information on browsing activities on the Website. Pursuant to the Applicable Law, your prior consent is required for third-party profiling tools to be installed. You are, of course, free to not give your consent to the installation of profiling cookies and to opt-out of using them at any time, without this affecting your ability to visit the Website and enjoy its content in any way.
5. HOW TO MANAGE COOKIES AND/OR OTHER SIMILAR TRACKING TOOLS AND OPT-OUT OF USING THEM
There are various options for managing, disabling and deleting cookies and/or to opt-out to the use of similar tracking tools.
(1) Change your browser settings or set up your mobile device
Follow the instructions provided by the manufacturer of the browser You use to find out how to manage, disable or delete all cookies:
- Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
- Chrome: https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies
- Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
- Safari: https://support.apple.com/it-it/guide/safari/manage-cookies-and-website-data-sfri11471/
- Opera: https://help.opera.com/en/latest/web-preferences/
If You wish to object to the use of the tracking tools used within the mobile applications, You can notify Adasta Media – using the contact details set out in paragraph 7 below – of the advertising identification (ID) of the mobile device You are using and Adasta Media will directly delete the data from the systems it uses. Alternatively, it is always possible to change the device settings and thus deactivate the use of the advertising identification (ID). To do this, please refer to your device settings and the instructions provided by your device manufacturer. Below we have provided some examples for information purposes only and on the basis of information available at the date of publication of this cookie policy:
- Apple iOS devices: “Settings” -> “Privacy and Security” -> “Apple Advertising” -> Set the “Custom Ads” option to “Off“.
Alternatively, go to “Settings” -> “Privacy and Security” -> “Tracking” -> Change the “Request activity tracking” option to “Off“. - Android devices: ‘Settings‘ -> ‘Privacy‘ -> ‘Ads‘ -> Select ‘Delete Ad ID‘ and confirm changes.
(2) Use the special interactive tools
In order to be aware of the modalities available to You to manage, disable and delete cookies and, more generally, to opt-out to their use of tracking systems, You may consult the privacy policies of the third parties that install profiling tools or the table provided in paragraph 4.2. Remember that by disabling third-party tools: (i) You opt-out of using them not only on the Website but on all websites on which they are used; and (ii) the ability to browse the Website and use its functions will not be affected in any way.
(3) Use the website Your Online Choices (www.youronlinechoices.eu/it/)
Your Online Choices is an Internet website managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA), the Italian version of which can be found at the following link. Your Online Choices provides information on behavioural advertising based on profiling cookies and allows Internet users to easily opt-out of the installation of the main profiling cookies installed by advertisers and used on websites. Before using this tool, we recommend You to read carefully the general terms and conditions of service of the Your Online Choices website, as well as the frequently asked questions (FAQ) and the help page (http://www.youronlinechoices.com/it/help). Use Your Online Choices sensibly Although Your Online Choices brings many of the world’s leading advertising companies that use cookies together, some of the third parties that install cookies through the website may not have signed up with Your Online Choices. Therefore, the use of Your Online Choices does not guarantee that You will receive third-party cookies while browsing the website. Remember, also, that if You delete all cookies from your browser, even the technical cookies issued by Your Online Choices to remember your preferences may be deleted, rendering third-party cookies active once again.
(4) CMP
For the processing of personal data that, subject to your consent, the Company and/or the third parties listed in the previous paragraph 4.2 may carry out through profiling cookies used on the Website, You can use the CMP on the Website and/or the other consent collection mechanism found therein to provide and, if necessary, withdraw consent by following the related instructions. Please note that Adasta Media S.r.l. is an IAB Framework registered vendor and, through the CMP compliant with the IAB Framework’s standard, You will always be able to make granular choices in terms of providing and/or withdraw consent already given.
6. PROCESSING METHODS, TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY AND DATA RETENTION PERIOD
As highlighted in the introduction of this cookie policy, the Company may collect and process some of your personal data through cookies and/or other tracking tools that it places directly on the Website (paragraph 4.1). The Company acts as the “data controller” (or as “joint controller”, together with the provider of the tracking tool) of these data, in accordance with the provisions of the Applicable Law. We will process the data collected only by electronic means, in a fully automated manner and without human intermediation. Therefore, our employees and partners will never access the content of the personal data obtained through cookies and/or other similar tracking tools, which means that they will never be able to access and/or have PII (Personally Identifiable Information), i.e. information which can identify You directly. Some of our employees and partners, authorised to process personal data pursuant to art. 29 of the Regulation, may carry out maintenance work on the computer systems that host the data, without ever being able to access its actual content. Personal data may be stored on servers managed by third parties (e.g. suppliers of computer systems) or may be managed by parties specialized in online advertising, who act as data processors on the basis of a written appointment by the Company, pursuant to art. 28 of the Regulation.
We inform You that, in compliance with the requirements and guarantees established by the Regulation, your data may be transferred to countries outside the European Economic Area (EEA). For example, personal data collected by Google for the provision of the AdSense service and of the Ad Server to Adasta Media, as well as data collected by Smart AdServer SAS for the provision of advertising services on the Websites, may be transferred outside the EEA on the basis of the so-called Standard Contractual Clauses or of an Adequacy Decision, in particular to the United States. In this case, the data will be transferred on the basis of the Data Privacy Framework certification that Google LLC has adopted (more information available at the following link).
To consult Google’s information and for information about the possible transfer of personal data abroad by Google, you can refer to the following link.
Your personal data will not be communicated to third-party data controllers or disseminated. Your personal data will be kept by the Company for the time considered strictly necessary to carry out the primary purposes described in this cookie policy, or as necessary for the protection in civil law of both your interests and those of the Company and, in any case, for no longer than the time period indicated in the table at paragraph 4.1 above.
7. YOUR RIGHTS
To exercise your rights, or to obtain further information or explanations on this cookie policy, please contact the Company using the following methods:
- by sending a registered letter with return receipt to the registered office of the Company (Via Privata del Gonfalone, n.3, Milan, Italy);
- by sending an email to the following address: info@adasta.it;
- by contacting the Data Protection Officer (DPO) of the Company at the following address: dpo@adasta.it.
Under the Applicable Law, Users have:
- the right to withdraw consent at any time, if the processing is based on their consent;
- the right to access personal data;
- (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and machine-readable format), the right to restrict the processing of personal data, the right to its rectification and the right to delete it (“right to be forgotten”);
- the right to object: (i) in whole or in part, for legitimate reasons to the processing of personal data, even if pertinent to the collection purposes; (ii) in whole or in part, to the processing of personal data for the purpose of sending advertising material or direct sale, or for the purpose of market research or commercial communications;
- if they consider that the processing of their personal data is in breach of the Regulation, the right to lodge a complaint with a Supervisory authority (in the Member State in which they usually reside, in the Member State in which they work or in the Member State in which the alleged infringement took place). The Italian Supervisory Authority is the “Garante per la protezione dei dati personali”, with registered offices in Piazza Venezia No. 11, 00187 – Rome (http://www.garanteprivacy.it/).
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The Company is not responsible for the updating of all links that can be viewed in this cookie policy. Therefore, whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to in these links.
