EXTENDED COOKIE POLICY INFORMATION

INTRODUCTION

This cookie policy is drafted in accordance with the indications contained in the guidelines of the data protection authority of June 2021, at the end of a consultation period, and published in July 2021, according to which, in compliance with the provisions of the EU General Data Protection Regulation 2016/679 (GDPR), no cookies, except those of a technical nature, which are to be considered necessary for the operation of the site, may be installed without the user’s prior consent. Consequently, when the user first accesses the site he/she is shown a banner in which he/she is allowed to check how many cookies may be installed on the site and of what nature (necessary or profiling) and is asked to choose which of the unnecessary cookies he/she wishes to activate, usually by moving the cursor. For convenience the user is also allowed to make the choice between ‘Accept all’ and ‘Reject all’. As soon as the choice has been made, instead of the window for the expression of consent, which closes, a graphic sign appears in the bottom right-hand corner, upon selection of which the window for the expression of consent reopens.

1.Data controller and legal basis

1.1. Extended Cookie Policy of www.soundtrack.eu (‘Website’)

The company SOUNDTRACK, with registered office in street degli Imbriani 20, c.a.p. 20158, in Milan (MI), in its capacity as website owner and data controller (hereinafter referred to as the “Owner‘), provides this notice on the use of technologies that enable the holder and selected third parties (such as the holder’s suppliers) to collect and store information (via cookie), or to use resources on the site user’s (‘user’s’) device when the user interacts with the site to, among other things, save the user’s preferences and settings, provide targeted advertisements and social media features, and analyse and improve the operation of the site according to the user’s expressed preferences.

User navigation data collected by the company or third parties through the use of cookie or other tracking tools are processed by the company in accordance with the privacy policy in relation to navigation data and in accordance with the provisions of this policy.

2. What are cookies

Cookies are small text files that sites you visit send and store on your computer or mobile device, where they are stored for six months, only to be retransmitted to the same sites on subsequent visits.

It is precisely thanks to cookies that a site remembers the user’s actions and preferences (such as, for example,login data, chosen language, le dimensioni dei caratteri, altre impostazioni di visualizzazione, ecc.) in modo che non debbano essere indicate nuovamente quando l’utente torni a visitare il sito o navighi da una pagina all’altra di esso. I cookiesTherefore, they are used to perform computer authentication, session monitoring and storage of information relating to the browsing preferences of users accessing a site and may also contain a unique identification code that allows tracking of the user’s navigation within the site for statistical or advertising purposes. Some operations could not be carried out without the use of the cookie (technical), which in certain cases are therefore necessary for the site to function.

In the course of browsing a site, the user may also receive on his or her computer or mobile device cookies from sites or web server other than the one he or she is visiting(so-called. cookies. of ‘third parties’, it being understood that in this case it is precluded that the user may be identified through their use). cookies, depending on their characteristics and functions, may remain on the user’s computer or mobile device for different periods of time: for example, a so-called session. cookie di sessione viene automaticamente cancellato alla chiusura del browser mentre il c.d. cookieis automatically deleted when the browser is closed, while a so-called persistent cookie remains on the user’s device until a predefined expiry date..

According to current Italian legislation, for the use of cookies express consent of the user is not always required. In particular, consent is not required for the so-called ‘. cookie technical’, i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communication network, or to the extent strictly necessary to provide a service explicitly requested by the user. These are, in other words cookies indispensable for the operation of the site or necessary to perform activities requested by the user.

Technical cookies which do not require the user’s express consent for their use, include:

• Analytics cookies used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site, or by third parties in aggregate and anonymised form,
• navigation or session cookies (for authentication),
• functionally cookies which allow the user to navigate according to a set of selected criteria (e.g. language, etc.) in order to improve the service rendered to the user.

These cookies are necessary for the proper functioning of the site and to allow the user to navigate on the site; they also make it possible to manage access operations (so-called login) to the sites,record configuration preferences where avaiable, produce statistical and perfomance analyses, in aggregate and anonymous form.

For so-called “cookies profiling”, i.e. those aimed at creating user profiles and used to send advertising messages in line with the preferences expressed by the user while browsing the web the user’s prior consent is required,which,if given,may be revoked by the user at any time through the site and in accordance with the provisons of this privacy policy of through the relevant web pages of third parties available at the links set out in this notice. These cookies are used, for example, to track the location of the advertisement and check whether a user has already seen the advertisement, but also to follow the user as he or she browses in order to define his or her profile and present him or her with advertisements linked to personal interests and socio-demographic characteristics.

3. Cookies used by the Website

The website uses 4 cookies divided into technical cookies(falling into the category “first party cookies”), anonymised third-party analytical cookies and profiling cookies.

3.1. Technical cookies

Technical cookies are those used for the sole purpose of carrying out the transmission of a communication over an electronic communication network or to transmit to the provider information strictly necessary to provide a service explicitly requested by the user.

They are normally installed when accessing the website directly by the owner or operator of the website (if different).

They can be subdivided into:

• Browising or session Cookies: they ensure normal navigation and use of the website; they are, in fact, necessary for its proper functioning.
• Analytical Cookies assimilated to technical cookies where used directly by the website operator [o da terze parti] to collect information in aggregate form on the number of users and how they visit the site, in order to improve the performance of the site. This category includes the cookies set by the the technological solution Google Analytics that collect information on the use of the site by visitors in an anonymised form.
• Functionality cookies: they allow the user to navigate according to a set of selected criteria (e.g. language, etc.) in order to improve the service rendered to the user.

Below are the technical cookies used by the website:

3.2. Profiling cookies

I cookies profiling may be used, also by third parties, to create a profile based on your interests and show or send you relevant advertisements on this and other sites. These cookie can only be set, via our site, by our advertising partners and are therefore third-party cookies. These cookies are based solely on the identification of your browser and your Internet device. If you do not accept these cookie, you will not be shown or sent these advertisements, nor will profiles of your interests be created.

The User may freely give or refuse consent for the use of profiling cookies by accessing the appropriate preference panel or may, at any time, revoke any consent given or change any preferences previously expressed through the ‘manage preferences’ function.

Please note that the cookies on the website are listed and updated on a regular basis by the owner in the table above.

Regarding third parties sendingcookies via the website, in particular, we provide links to their respective privacy policies as indicated aboveto such third parties we delegate the responsibility for providing their own information. The responsibility of third parties also extends to any further cookies sent via the website by virtue of the use of services from which the third parties themselves benefit. With respect to such cookies, ehat may be sent by other service providers of the aforementioned third parties, the holder has no control over them and does not know their characteristics or purposes.

There are also links to the social pages of Facebook, YouTube and Linkedin to which the holder refers to their respective cookie policies.

4. Duration of processing or cookies/Data retention period

Session cookies at the end of a browser session (normally when the browser is closed or when the session expires). The retention period of persistent cookies is instead equal to the duration indicated in the table above.

5. Scope of communication and dissemination of personal data

5.1. How will the data be processed?

The processing of navigation data collected by the owner with the cookies managed by it will be carried out by means of electronic and/or telematic tools, with logic strictly related to the purposes set out in the preceding paragraph, and, in any case, in such a way as to ensure the security and confidentiality of the data.

Please refer to the respective privacy and cookie policies for details on how navigation data collected by third parties throught te use of cookis managed by them is processed.

5.2. What rights do users have with regard to their browsing data?

With regard to your personal data, you may, at any time, exercise your rights under Articles 15 to 22 of the GDPR in the manner and within the terms set out therein.

In particular, the user has the right to:

1. request from the controller access, rectification, deletion of navigation data (‘right to be forgotten’) concerning him or her, or the restriction of the processing of such data;
2. object to the processing of navigation data;
3. obtain portability of browsing data;
4. revoke the consent required by the controller and the user, if any, at any time by accessing the cookie preference control panel and without affecting the lawfulness of the processing based on the consent given before revocation.

4. How to exercise your rights. how to contact the data controller.

The user may at any time exercise the rights referred to in the preceding paragraph by sending a communication to the data controller at the following e-mail address e-mail: info@soundtrack.eu.

With regard to the processing of data by third parties throught the use of cookies managed by them, the user may exercise his or her rights by sending a notice in accordance with the provisions of the privacy and/or cookie policy available at the links of the third parties link themselves.

4.1. Submission of Complaints

In relation to any type of data processed by the data controller, without prejudice to the user’s right to seek redress in any other jurisdiction, if he/she considers that the processing of his/her browsing data has been or is being carried out in breach of the GDPR and of the regulatory provisions applicable from time to time, the user has the right to lodge a complaint with the Garante per la protezione dei dati personali in accordance with the procedures set out in the www.garanteprivacy.it.

4.2. How can cookies be deactivated?

You can handle your preferecens concerning cookie, modifying your choices or revoking the consent(s) given, by accessing the preferences control panel on the cookies and without affecting the lawfulness of the processing based on the consent given before revocation. You can also manage your preferences on cookie by third party, modifying your choices or revoking the consent(s) given, via the appropriate areas available at the third-partyi link

4.3. Managing preferences via the browser

Remember that you can also manage your cookie preferences via your browser.

If you do not know the type and version ofbrowser you are using, click on ‘Help’ in the browser window at the top, from which you can access all the necessary information.

If you know your browser click on the one you are using to access the i cookie management page.

• Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d#ie=ie-10
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en&ref_topic=14666
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
• Safari: https://support.apple.com/it-it/guide/safari/sfri11471/mac
• IOS: https://support.apple.com/en-us/HT201265
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies