EN / IT
GARAGE RAW S.r.l., (VAT no.: 03734090362) (hereinafter “GARAGE RAW”), represented by its pro tempore legal representative, with its registered office in Bologna, Via Galliera, 8, as Data Controller pursuant to Articles 4(7) and 24 of EU Regulation no. 2016/679 (GDPR), provides the following cookie policy (“Policy”) applicable exclusively to this website www.garageraw.com (the “Website”).
1.1. This Policy is based on the following EU and/or national legislative measures (primary and/or secondary level):
(i) Directive 2002/58/EC of 12.7.2012 (the “ePrivacy Directive”), as amended by Directive 2009/136/EC;
(ii) Article 122 of the amended Legislative Decree no. 196/2003 (Privacy Code), which transposed the ePrivacy Directive into national law;
(iii) GDPR: Articles 4(11), 7, 12, 13, 25, and 95 (particularly Recitals 30, 32, and 173);
(iv) Guidelines 5/2020 adopted on 4.5.2020 by the EDPB, replacing the Article 29 WP Guidelines of 10.4.2018;
(v) Decision no. 231 of 10.6.2021 [doc. web no. 9677876] issued by the Italian Data Protection Authority (Garante Privacy);
(vi) Recommendation no. 2/2001 by the Article 29 WP;
(vii) Opinion no. 2/2010 by the Article 29 WP;
(viii) Opinion no. 4/2012 by the Article 29 WP;
(ix) Guidelines 8/2020 by the EDPB;
(x) Decisions no. 224 of 9.6.2022 [doc. web no. 9782890], no. 243 of 7.7.2022 [doc. web no. 9806053], and no. 254 of 21.7.2022 [doc. web no. 9808698] issued by the Italian Data Protection Authority;
(xi) EDPB Guidelines 2/2023 adopted on 7.10.2024.
2.1. “Cookies” are, in general, text strings that a website (the “publisher” or “first-party” website) visited by the user, or a different website (“third-party” website), places and stores—directly (in the case of a first-party website) or indirectly (via the first-party website in the case of a third-party website)—on a terminal device available to the user. The Italian Data Protection Authority (Garante Privacy) has specified that the information encoded in cookies may include both personal data as per Article 4(1) of the GDPR (e.g., IP address, username, email address, unique identifier) and non-personal data as per Article 3(1) of EU Regulation no. 1807/2018 (e.g., language, type of device used).
In addition to cookies, there are “other tracking tools” that can also be used. These can be classified as “active” (which have characteristics similar to cookies) and “passive” (e.g., fingerprinting).
2.2. Beyond their intrinsic characteristics, cookies (and other tracking tools) can differ in temporal scope (and thus be classified as “session” or “persistent,” depending on their duration), subjective scope (depending on whether the publisher operates independently or on behalf of a “third party”), and most notably, in their purpose of processing. Based on the latter, cookies can be divided into two main categories:
“Profiling”/“marketing” cookies (non-technical cookies), used to associate specific actions or recurring behavioral patterns (patterns) of identified or identifiable subjects with the use of the offered features. These aim to group different profiles into homogeneous clusters of varying sizes, enabling the Data Controller to personalize the service beyond what is strictly necessary and to send targeted advertisements (aligned with the user’s preferences during web browsing).
3.1.
4.1. GARAGE RAW highlights the possibility for the user to delete and block the operation of the cookies described in the previous article 3 at any time by using the appropriate settings available within the browser being used: in this regard, GARAGE RAW adds that, if the user decides to disable the technical cookies mentioned in article 2.2, point i), the quality and speed of the services and functionalities offered and made available on the Site may deteriorate.
Information on how to manage cookies with some of the most popular browsers can be found by visiting the following web pages:
Google Chrome Cookie Management
Mozilla Firefox Cookie Management
5.1. In relation to the user’s personal data, GARAGE RAW informs that the relevant data subject, pursuant to Article 4, No. 1) of the GDPR, has the right to exercise the following rights, which may be subject to limitations as provided by Articles 2 undecies and 2 duodecies of the Privacy Code: right of access under Article 15 of the GDPR: the right to obtain confirmation of 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 processing, retention period); right of rectification under Article 16 of the GDPR: the right to correct, update, or supplement personal data; right to erasure under Article 17 of the GDPR: the right to obtain the deletion, destruction, or anonymization of personal data, provided the conditions listed in the same article are met; right to restriction of processing under Article 18 of the GDPR: a precautionary right aimed at obtaining the limitation of processing when the conditions set out in the same article apply; right to data portability under Article 20 of the GDPR: the right to obtain personal data provided to GARAGE RAW in a structured, commonly used, and machine-readable format (and, if requested, to transmit them directly to another data controller), provided the specific conditions set out in the same article apply (e.g., legal basis of consent and/or execution of a contract; personal data provided by the data subject); right to object under Article 21 of the GDPR: the right to obtain the permanent cessation of a specific personal data processing; right to lodge a complaint with the Supervisory Authority (i.e., the Italian Privacy Authority) under Article 77 of the GDPR: the right to lodge a complaint when it is believed that the processing being analyzed violates national and community legislation on personal data protection.
5.2. In addition to the rights described in the previous article 5.1., GARAGE RAW specifies that, in relation to the personal data of the data subject, where applicable and relevant, there is the right to exercise, on the one hand, the (sub) right provided by Article 19 of the GDPR (“The data controller shall inform each of the recipients to whom the personal data has been disclosed of any rectifications, deletions, or restrictions of processing carried out under Articles 16, 17(1), and 18, unless this proves impossible or involves disproportionate effort. The data controller shall inform the data subject of these recipients if the data subject so requests”), which is related and connected to the exercise of one or more rights regulated in Articles 16, 17, and 18 of the GDPR; on the other hand, GARAGE RAW specifies that, in relation to the personal data of the data subject, where applicable and relevant, the data subject may exercise the right provided by Article 22(1) of the GDPR (“The data subject shall not 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”), subject to the exceptions provided for in paragraph 2.
5.3. In compliance with Article 12(1) of the GDPR, GARAGE RAW undertakes to provide the data subject 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 plain language: such information will be provided in writing or by other electronic means, or, at the data subject’s request, orally, provided that the data subject’s identity is verified by other means.
5.4. In compliance with Article 12(3) of the GDPR, GARAGE RAW informs that it undertakes to provide the data subject with information regarding the action taken concerning a request pursuant to Articles 15 to 22 of the GDPR without undue delay and, in any case, no later than one month from the receipt of the request; this period may be extended by two months if necessary, considering the complexity and number of the requests (in such case, the data controller undertakes to inform the data subject of this extension and the reasons for the delay, within one month from the receipt of the request).
5.5. The data subject may exercise the above-mentioned rights (except for the right under Article 77 of the GDPR) at any time using the contact details provided in Article.
6.1. GARAGE RAW can be contacted at the following address: garageraw@legalmail.it
6.2. The Data Protection Officer (DPO) pursuant to Article 37 of the GDPR, appointed by GARAGE RAW, is attorney Gabriele Borghi, who can be contacted at the following address: dpo@garageraw.com
Bologna, October 21, 2024 (date of last update).
GARAGE RAW S.r.l.
(Represented by its legal representative pro tempore)