Cookies policy

(version 1.0 of 18 May 2023)

Dear Visitor (hereinafter referred to as "You" or the "User"),

This website rulingcompanies.com (hereinafter the "Website") is owned by the company The Ruling Companies S.r.l., with registered office in Via F.lli Ruffini 9, 20123 Milan, Italy, tax code 04309110965, VAT number 04309110965 and registration number in the Business and Trade register of Milan 1738557 (hereinafter "We" or the "Company").

Since cookies are used on our Website for various purposes, we would like to explain to you with this information sheet what cookies are and how they are used on the Website.

Some cookies (so-called own or first-party cookies) are conveyed and controlled directly by us. Through these cookies, the Company collects and processes certain personal data about you. In this notice, pursuant to Art. 13 of the EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter "Regulation"), we explain how we collect this data, for what purposes and what your rights are.

Other cookies (so-called third-party cookies), on the other hand, are conveyed and controlled by third parties. In this notice you will find links to the notices published by these third parties, which we kindly ask you to read carefully.

If you are not familiar with cookies, please read this policy and the Website's general privacy policy carefully so that you will be aware of your choices.

The Company takes into the utmost consideration the right to privacy and protection of personal data of its Users. For any information related to this cookie policy, Users may contact the Company at any time, using the following methods:

• by sending a registered letter with return receipt to the Controller's registered office in Via F.lli Ruffini 9, 20123 Milan, Italy;
• by sending an e-mail to: privacy@rulingcompanies.com

The Controller has not identified the figure of the Data Protection Officer (DPO), since it is not subject to the designation obligation provided for in Art. 37 of the Regulation.

A. What are cookies and what are they used for

Cookies are small text files that websites visited by the user send directly to the user's terminal (usually to the browser), where they are stored and then retransmitted to the same websites the next time the same user visits it (so-called first-party cookies). When 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 website visited may contain elements such as, for example, images, maps, sounds, specific links to web pages of other domains residing on servers other than the one on which the requested page is located. In other words, these are the cookies that are set by a website other than the one you are currently visiting.

Cookies may have lifetime limited to a single browser session (session cookies), in which case they are automatically deactivated when the user closes the browser; or they may have a predetermined expiry date, in which case they will remain stored and active on your hard disk until that expiry date, continuing to collect information over the course of several browser sessions (permanent cookies).

Cookies are used for different functions. Some are necessary to enable you to browse the Website and benefit from the relevant functionalities (so-called technical cookies). Other cookies are used to obtain statistical information, in aggregate or otherwise, on the number of users accessing the Website and on how the Website is used (so-called tracking or analytics cookies). Finally, other cookies are used to trace your consumer profile and display advertisements on the Website that may be of interest to you, as they are consistent with your tastes and consumption habits (so-called profiling cookies).

To learn about these different categories of cookies in more detail, continue reading this policy. Find out how they work and what they are used for, and freely choose whether to consent to their use or prevent it.

B. Technical cookies

Technical cookies are used on the Website for the sole purpose of making it possible for you to browse the Website and to use its functionalities. These cookies are always first-party cookies, as they are placed directly by us on the Website.

Some technical cookies are necessary in order to provide you with an optimal browsing experience or to allow you to authenticate yourself on the Website, for example in order to make a purchase on the Website or enter your private area (so-called navigation cookies). Browsing cookies are normally session cookies and are therefore automatically deactivated once you close your browser.

Other technical cookies are useful to allow you to store certain preferences (e.g. language or country of origin) without having to reset them during subsequent visits (so-called functionality cookies). For this reason, functionality cookies are often persistent cookies, as they remain stored on your computer even after you close your browser, until their expiry date or until you decide to delete them.

The following technical cookies are currently used on the Website:

As provided for in the current privacy policy, your prior consent is not required for the installation of such cookies. You are of course free to block the installation of technical cookies by changing your browser settings (read para. E, no. 1 to find out how to do this). Please note, however, that by blocking the installation of technical cookies, or subsequently deleting them, your ability to access the Website, to use all or part of it, to enable or disable certain functions or to receive certain services may be wholly or partly impaired.

C. Tracking or "analytics" cookies

Analytics cookies are used on the Website to collect statistical information, in aggregate or otherwise, on the number of users accessing the Website and how they visit the same Website.

The analytics cookies on this Website are third-party cookies, as they are not directly conveyed by us but by third parties. These are therefore not installed directly by the company but by third parties.

The following third-party analytics cookies are installed on the Website without your prior consent, because they are less invasive as they are anonymised, as third parties cannot access disaggregated analytics data at IP address level (in other words, by using these cookies, third parties cannot trace your identity):

Other third-party analytics cookies are, on the other hand, installed on the Website only with your prior consent, because those are not anonymised, as third parties can access disaggregated analytics data at IP address level (in other words, by using these cookies, third parties could theoretically trace your identity through your IP address):

For this reason, when you access the Website, a special banner is displayed prominently, informing you that third-party analytics cookies are used on the Website and that by pressing the appropriate button provided therein, you may consent to the use of cookies. Should you consent to the installation of cookies in this way, we will keep track of your consent by means of a technical cookie. In this way, we will avoid having the cookie banner displayed during your subsequent visits to the Website. Please note that if you were to delete this technical cookie from your browser in the manner set out in para. E, no. 1 below, the trace of your consent would be lost and, therefore, during your next visit to the Website the cookie banner would be displayed again.

You are of course free to block the installation of analytics cookies at any time, without your ability to visit the Website and enjoy its contents being affected in any way. To find out how to do this, please read the third-party cookie policies carefully by following the links in the table above.

D. Profiling cookies

Profiling cookies are used to create your user profile, based on the preferences and tastes you expressed when surfing the Internet, and to display advertising messages consistent with your profile. In this way, the advertisements you see on our Website can be more interesting for you.

As required by the current privacy policy, your prior consent is required for the installation of such cookies. For this reason, when you access the Website, a special banner is displayed prominently, informing you that subject to your consent, profiling cookies are used on the Website and that by pressing the appropriate button provided therein, you may consent to the use of cookies. Should you consent to the installation of cookies in this way, we will keep track of your consent by means of a technical cookie. In this way, we will avoid having the cookie banner displayed on your subsequent visits to the Website. Please note that if you were to delete this technical cookie from your browser in the manner set out in para. E, no. 1 below, the trace of your consent would be lost and, therefore, during your next visit to the Website the cookie banner will be displayed again.

You are of course free to block the installation of profiling cookies at any time, without your ability to visit the Website and enjoy its contents being affected in any way. If you decide to deactivate behavioural advertising, it does not mean that you will no longer receive advertising on the Website. However, the banners you see on the Website may not reflect your interests or preferences on the browser you are currently using.

There are currently no profiling cookies on the Website..

E. How to manage cookies and object their use

There are several options for managing, disabling and deleting cookies.

(1) Change your browser settings

Follow the instructions provided by the manufacturer of the browser you are using to find out how to manage, disable or delete all cookies (technical, analytics and profiling):

• 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/

Make your choices carefully. By indiscriminately blocking the reception of all cookies, including technical cookies, without providing a specific exception for the Website, you may, in fact, no longer be able to navigate on the Website or to use all or part of its functionalities. Moreover, if you delete all cookies from your browser, technical cookies may also be removed and, therefore, you may remove preferences you have set using the Website or no longer find products or services in your shopping cart.

(2) Use interactive tools provided by third parties

To disable third-party cookies, please consult the privacy policies of third parties that install analytics cookies (see paragraph C above) or profiling cookies (see paragraph D above) to learn about the other tools available to you to manage, disable and delete cookies, and more generally to object to their use. Remember that, by disabling third-party cookies, (i) you object to their use not only on the Website but on all Internet websites on which such cookies are used and (ii) your ability to navigate on the Website and use its functionalities will not be affected in any way.

(3) Use the Internet website www.youronlinechoices.eu/it/

Your Online Choices is an Internet website managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA), that can be reached at www.youronlinechoices.eu, which provides information on behavioural advertising based on profiling cookies (http://www.youronlinechoices.com/it/a-proposito) and allows Internet users to easily oppose (opt-out) the installation of the main profiling cookies installed by advertising operators and used on Internet sites (http://www.youronlinechoices.com/it/le-tue-scelte). Before using this tool, we advise you to carefully read the general terms of service of the Your Online Choices website (http://www.youronlinechoices.com/it/condizioni-generali-di-servizio), the frequently asked questions (FAQ) (http://www.youronlinechoices.com/it/faqs) and the user guide (http://www.youronlinechoices.com/it/help).

Use Your Online Choices consciously. Although Your Online Choices brings together many of the world's leading advertising companies that use cookies, some of the third parties that install cookies through the Website may not have signed up to Your Online Choices. Therefore, using Your Online Choices does not guarantee that you will receive third-party cookies by browsing the Website. Please also remember that if you delete all cookies from your browser, the technical cookies issued by Your Online Choices to remember your choices may also be deleted, making the third-party cookies active again.

F. Processing methods and data retention periods

As outlined in the introduction to this policy, it is possible that the Company collects and processes some of your personal data through cookies that it places directly on the Website (first-party cookies). The Company acts as the controller of this data, in accordance with the provisions of the Regulation. We will process your data only by electronic means, in a fully automated manner and without human intermediation. Therefore, our employees and contractors will never have access to the content of your personal data obtained through cookies, which means that they will never be able to access and/or have PII (Personally Identifiable Information), i.e. information from which you can be directly identified.

Some of our employees and contractors, appointed by us as data processors, may perform maintenance work on the computer systems that host your data, without ever being able to access their actual content. Your personal data may be stored on servers operated by third parties (e.g. computer system providers) or may be managed by parties specialising in online advertising, who act as data processors on the basis of a specific written appointment by the Company. We inform you that, in compliance with the assumptions and guarantees established by the Regulation, your data may be transferred to countries outside the European Economic Area, which may not offer a level of privacy and personal data protection comparable to that guaranteed by Italian and European privacy laws, but where the Company will act as data controller we will take data security into the utmost consideration; therefore, we will proceed in handling such transfers with all due care and guarantees. Your personal data will not be disclosed to third-party data controllers or disseminated.

Your personal data will be kept for the time strictly necessary to fulfil the primary purposes outlined in this policy, or as necessary to protect the rights and interests of both the Users and the Company.

Specifically, for the provision of the Google Analytics service, the Company provider, Google Ireland Limited, may transfer the pseudonymous personal data of the Website Users outside the EEA, on the basis of the so-called Standard Contractual Clauses and, in particular, to the United States, taking additional measures to ensure that this is done in accordance with the Regulation. Further information on the additional security measures applied by Google Ireland Limited for transfers of personal data outside the European Union can be found in the following resources provided by the provider itself: "Regarding international data transfers in Google Analytics" (as referred to following the link: https://support.google.com/analytics/answer/11609059 and "Safeguards for international data transfers with Google's advertising and analytics products" (as referred to following the link: https://services.google.com/fh/files/misc/safeguards_for_international_data_transfers.pdf). In view of the scope of the processing, the nature of the data processed and the risks of the processing carried out by the supplier, the Company considered the additional security measures that the supplier guarantees to take to protect the personal data processed on behalf of the Company to be appropriate.

G. Your rights

To exercise your rights, or to obtain any further information or clarification in relation to this cookie policy, please contact the Company by the following means:

• by sending a registered letter with return receipt to the Controller's registered office in Via F.lli Ruffini 9, 20123 Milan, Italy;
• by sending an e-mail to: privacy@rulingcompanies.com

The Controller has not identified the figure of the Data Protection Officer (DPO), since it is not subject to the designation obligation provided for in Art. 37 of the Regulation.

Pursuant to the Regulation, the Company informs Users that they have the right to obtain information on (i) the origin of personal data; (ii) the purposes and methods of processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) the identification details of the data controller and data processors; (v) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of such data in their capacity as data processors or persons in charge of processing.

Furthermore, Users have the right to obtain:
a) access, update, rectification or, when interested, integration of the data;
b) the cancellation, transformation into anonymous form or blocking of data processed in breach of the law, including data whose storage is not necessary in relation to the purposes for which the data were collected or subsequently processed;
c) certification to the effect that the operations as per letters A and B have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

Furthermore, Users have:
a) the right to withdraw consent at any time, if the processing is based on their consent;
b) (where applicable) the right to data portability (the right to receive all personal data concerning themselves in a structured, commonly used and machine-readable format), the right to restriction of the processing of personal data and the right to erasure (“right to be forgotten”);
c) the right to object:

1. in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even though they are relevant to the purpose of collection;
2. in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication;

d) if they consider that the processing concerning them is in breach of the Regulation, the right to lodge a complaint with a Supervisory authority (in the member state where they have their habitual residence, in the member state where they work or in the member state where the alleged breach has occurred). The Italian supervisory authority is the Data Protection Commissioner, with its head office in Piazza Venezia 11, 00186 - Rome (RM) (www.garanteprivacy.it).

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The Company is not responsible for updating all the links displayed in this cookies policy; therefore, whenever a link is not working and/or updated, Users acknowledge and accept that they should always refer to the document and/or section of the websites referred to by that link.