Full Cookie Policy
Dear user (hereinafter, “You” or the “User“),
the website you come from (hereinafter, the “Website“) is property of Refine Direct S.r.l, with registered office address at Viale Monza, 265, Milan, Italy, with VAT Number 09419240966 (hereinafter, “Us” or the “Company“).
As the Website uses cookies and/or other tracing technologies for a number of purposes (hereinafter, the “Cookies“), with this cookie policy (hereinafter, the “Cookie Policy“), we wish to explain to you the reasons why they are used.
Some Cookies (known as “First-Party Cookies”) are transmitted and controlled directly by Us. Through these Cookies, the Company collects and processes some of the personal data concerning You. In this Cookie Policy, pursuant also to Legislative Decree 196 of 30 June 2003 (the “Privacy Code“) and pursuant to Article 13 of Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter the “Regulation” and, collectively with the Privacy Code, the “Applicable Law“), we wish to explain to you how we collect these data, the purposes for which they are collected, and what your rights are.
Other Cookies (known as “Third-Party Cookies”), on the other hand, are transmitted and controlled by third parties. This Cookie Policy contains links to the cookie policies published by these third parties, which we invite you to carefully examine.
If you are not familiar with Cookies, we invite you to carefully read this Cookie Policy and the general Privacy Policy for the Website, so that you can make informed choices.
The Company is highly committed to the right to privacy and in the protection of the personal data of its Users. For any information concerning this Cookie Policy, Users can contact the Company at any time, by
• sending a registered letter with proof of receipt to the registered office address of the Company (Viale Monza 265, Milan, Italy);
• sending an-email to: richieste_privacy@refine.direct.
You may also contact the Data Protection Officer (DPO) of the Company via e-mail, by writing to: dpo@refine.direct.
A. What are Cookies, and what are they used for?
Cookes are small text file the websites browsed by the User send directly to the User’s own device (typically, to the browser), where they are stored to then be sent back to the same websites on the User’s next visit (these Cookies are known as First-Party Cookies). When browsing a website, the User’s device may also receive cookies from other websites or web servers (known as “Third-Party Cookies”); this happens because the website browsed by the User may have elements such as images, maps, sounds, specific links to web pages from other domains that are hosted in servers other than the server hosting the web page requested. In other words, these cookies are set by a website other that the website browsed.
Cookies may have a duration limited to one single browsing session (these are known as session cookies), in which case cookies are automatically deactivated when Users close their browser; or they may have a pre-set expiration date, in which case they are stored and remain active on your hard disk until said expiration date, and continue to collect information over the course of different browsing sessions (these cookies are known as “persistent cookies”).
Cookies are used for a number of functions. Some are necessary to allow you to browse on the Website and access its functionalities (known as technical cookies). Other cookies are used to obtain statistical information, in aggregate or non-aggregate form, on the number of Users accessing the Website, and on how the Website is used (known as monitoring or analytics cookies). Finally, others are used to track your consumer profile and display advertising messages on the Website that may be interesting to you, reflecting your tastes and consumption habits (known as profiling cookies).
For more detailed information on these different categories of cookies, continue to read this Cookie Policy. Find out how cookies work and what they are for, and freely choose whether to consent to their use or block 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 allow you to use its functionalities. They are always First-Party Cookies, as they are transmitted directly by us on the Website.
Some Technical Cookies are indispensable to offer you a better browsing experience. Navigation Cookies are normally session cookies, meaning that once the browser is closed, they are automatically deactivated.
Other Technical Cookies are used to allow you to store some of your preferences (such as language or country of origin), so they don’t have to be set every time you visit the same website (known as functionality cookies). For this reason, Functionality Cookies are often persistent, as they remain stored on your computer even after your browsing session is closed, until the expiration date set for said Cookies, or until you decide to delete them.
Our Website currently uses the following Technical Cookies:
| Name | Category | Function |
|
wordpress_xxxx wp_settings-xxxx |
Technical Cookie: – navigation – functionality |
These cookies are necessary to the WordPress software through which the Website was created, and are used for technical functions such as login, panel preferences, Website interface and session configurations, and to remember the User’s settings. |
| Iubenda | Technical Cookie: – functionality |
Cookies from the Website consent management platform (hereinafter, “CMP“), which informs the User accessing the Website that, with their consent, the Website uses non-technical cookies, and that by clicking on the relevant button, Users may consent to the use of said cookies. Where Users grant their consent to the installation of cookies as detailed above, the Company shall keep track of the consent through a dedicated technical cookie or other technical methods connected to the use of the CMP, which allow to keep the documentation concerning the Users’ choices updated at all times. Lastly, the Company may, to such end, process metadata concerning the granular choices made by Users, and namely the granting of consent, the detail of the granular purposes for which said consent is granted by Users, and the Users’ choice to continue browsing by keeping the default settings by selecting the relevant button displayed on the CMP. This way, we will not need to show you the CMP over the course of your next visits to the Website, and we will keep track of your choices in line with the requirements of the Applicable Law. |
In compliance with Applicable Law, your prior consent is not required for the installation of these Cookies. Naturally, you can always block the installation of Technical Cookies, by changing your browser’s settings (read paragraph E, No. 1 to learn how to block the installation of these cookies). Consider, however, that by blocking the installation of Technical Cookies, or by deleting these Cookies in the future, the possibility to access the Website, to use all or part of the Website, to enable or disable certain functions, or to receive certain services, may be compromised in whole or in part.
Conversely, to install Cookies other than Technical Cookies (such as Profiling Cookies), your prior consent is required. For this reason, when you access the Website, the CMP is prominently displayed, to inform you that, with your consent, the Website will use tools non-technical cookies, and that by selecting the relevant button, you may give your consent to the use of cookies.
If you wish to grant your consent to the installation of cookies as detailed above, we will keep track of your consent through a dedicated technical cookie or other technical methods connected to the use of the CMP, which allow to keep the documentation concerning the Users’ choices updated at all times, in compliance with Applicable Law. In this last case, the Company may, to such end, process metadata concerning the granular choices made by Users, and namely the granting of consent, the detail of the granular purposes for which said consent is granted by Users, and the Users’ choice to continue browsing by keeping the default settings by selecting the relevant button displayed on the CMP. Please bear in mind that, should the Company use, in order to demonstrate to have obtained your consent, a Technical Cookie, or other methods that allow to keep the documentation concerning the User’s choices updated at all times, if you were to eliminate this Technical Cookie, or other tool used to such end, from your browser, following the steps detailed in paragraph E, No. 1 below, the trace of your consent may be lost; therefore, on your next visit to the Website, the CMP may be displayed again.
C. Monitoring or “Analytics” Cookies
Analytics Cookies are used on the Website to collect statistical information, in aggregate or non-aggregate form, on the number of Users who access the Website, and how such Users visit the same.
| Name | Category | Cookie Policy Link |
| Google Analytics | Analytics service provided by Google Ireland Limited (“Google“). Google uses the data collected and anonymised, on behalf of the Company, for the purpose of producing aggregate statistics on the Website. The collected data are not shared with any other third parties, nor combined with other information. This Cookies is installed on the Website without your prior consent. | Please follow this link to Google’s information page diand Google’s opt-out mechanism. Google Analytics supports an additional, optional component of the browser, which, once installed and activated, deactivates Google Analytics’ measurement of any website visited by a User. Keep in mind that this additional component only deactivates Google Analytics’ measurement. |
| Google Analytics | Google’s monitoring platform, used to monitor traffic on the Website and to calculate conversion actions, visits, viewed pages, etc.. This Cookies is installed on the Website with your prior consent. | Please follow this link to Google’s information page diand Google’s opt-out mechanism. Google Analytics supports an additional, optional component of the browser, which, once installed and activated, deactivates Google Analytics’ measurement of any website visited by a User. Keep in mind that this additional component only deactivates Google Analytics’ measurement. |
You can block the installation of Analytics Cookies at any time, without compromising in any way the possibility for you to visit the Website and using its contents.
D. Profiling Cookies
Profiling Cookies are used to create your User profile, based on the preferences and tastes you manifest when browsing the Internet, and show you advertising messages that are in line with your profile. This way, the advertising messages you will see on the Website may be more relevant to you.
You can refuse to give your consent to the installation of Profiling Cookies at any time, without compromising in any way the possibility for you to visit the Website and using its contents. If you decide to deactivate behavioural advertising, this does not mean that you will no longer receive advertisement on the Website. However, the banners you will see displayed on the Website may not reflect your interests or preferences on the browser you are currently using.
(1) First-Party Profiling Cookies
Some of the Profiling Cookies are installed directly by the Company, or are tools through which the Company collects data in its capacity as data controller, or, in some cases, as joint controller together with the provider of those Cookies (as expressly indicated by the Cookie provider in the privacy policy reported on the table featured in this paragraph D, No. 1).
Please find below the list of First-Party Profiling Cookies we use on the Website, and the steps you can take to revoke your consent, once given.
| Tool Used | Additional information |
| Fido |
– profiling first-party tool – persistent – maximum duration 7 days Once you have given your consent, to disable these Profiling Cookies you may (i) change your browser’s settings (see paragraph E, No. 1), or (ii) revoke your consent through the CMP platform on the Website. In order to give (or revoke) your consent to the First-Party Profiling Cookies used by the Company, you will need to select/deselect the vendor Fido s.r.l. (who acts on behalf of the Company with respect to the data collected on the Website), on the CMP section -> “Services Adhering to IAB Transparency and Consent Framework” -> “Manage your preferences for each advertising service”. |
| Refine | On-line conversion tracking solution, property of the Company, which allows to count the commercial actions carried out within the Website in real time (in order to measure the impact of campaigns). By using this system, the Company can collect, in its capacity as data controller, data concerning the User, such as IP address (stored after hashing, and therefore encrypted), user agent, information on the User’s type of browser and settings. The above data may be associated to information relative to the advertising campaign delivered by a publisher, and to the User’s interaction with the same advertising campaign (e.g., clicks, time, party who delivered the campaign, type of campaign, etc.), in order to attribute conversion to a specific publisher, and draft accurate reporting. |
| Google Tag Manager | Google tool to manage tags on web pages: information page. |
| Display & Video 360 | Google’s advertising platform (Demand Side Platform – DSP): information page. |
| Campaign Manager 360 | Google’s advertising platform (Adserver): information page. |
| Google Ads |
Google’s advertising platform (delivery of advertising on search engines and on Google’s website network) information page.
The Company also uses a Google Ads service known as “Enhanced Conversion” to monitor conversion relative to the campaigns delivered through Google Ads. If the User give their consent, the provider, Google, processes, on behalf of the Company, personal data property of Refine (such as the e-mail address entered in the Website’s registration form, and the IP address of the User), in order to more accurately measure the conversions relative to the campaigns delivered on the Google Ads’ network. The “Enhanced Conversion” functionality does not use unencrypted data, as it uses the one-directional hashing algorithm known as SHA256 on Refine’s data before they are sent to Google. More information on the security measures and processing operations conducted by Google can be found at the following link. |
| Meta |
Meta Platforms Ireland Limited (with registered office address at 4,Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; hereinafter, “Meta“) is joint controller, together with the Company, of the collection, through the Meta pixel on the Website, and subsequent transmission to Meta, of data relative to the Users’ actions on the Website. The necessary information as set out under Article 13(1)(a) and (b) of the Regulation are contained in the Meta Privacy Policy available at the following link. Any additional information on how Meta processes personal data, including the legal basis used by Meta for processing, and on how to exercise the data subjects’ rights in respect of Meta, can be found on the Meta Privacy Policy at the following link. The Company and the provider stipulated the Data controller Addendum to establish their respective responsibilities in connection to their compliance with the obligations laid down in the Regulation with respect to the process for which they are joint controllers. Among joint controllers, Meta is responsible for the rights of data subjects under Articles 15-20 of the Regulation in respect of the personal data stored by Meta following joint-processing operations conducted jointly with the Company.
If the User grants their consent, the Company also uses the “advanced matching” functionality. By using API (server side), Meta collects and processes, on behalf of the Company, the contact information of the User (as well as e-mail address), for the sole purpose of User ID correspondence search, and to combine the same with the actions performed on the Website, in order to improve conversion attribution and improve the service of advertising on the spaces made available by Meta. Contact details are subject to a hashing procedure before they are transmitted to Meta. More information can be found at the following link. |
| Outbrain | Use of technologies offered by Outbrain UK Limited (with registered office address at 100, New Bridge Street, EC4V 6JA London, United Kingdom; “Outbrain“) to deliver ads and relative measurement. The Company and Outbrain act as joint controllers of processing on the basis of the provisions of an agreement concluded between the parties to such end. The information relative to the processing of personal data by Outbrain, as well as information on how to exercise the rights of data subjects in respect of Outbrain can be found at the following address. Users can object to the processing operations conducted by Outbrain, and exercise the other rights afforded to data subjects, at the following link. |
| TikTok | TikTok’s pixel is used by the Company to collect and analyse data relative to the advertising campaigns conducted through TikTok’s services, in order to monitor and improve them. TikTok (the term “Tiktok” refers to TikTok Information Technologies UK Limited, 6th Floor, One London Wall, EC2Y 5EB, London, United Kingdom (“TikTok UK”) and TikTok Technology Limited, 10 Earlsfort Terrace, D02 T380, Dublin, Ireland (“TikTok Ireland”)) is joint controller with the Company, and the necessary information established by the Regulation (including how to exercise the data subject’s rights against TikTok) are contained in TikTok’s Privacy Policy. The Company and the provider stipulated an agreement (see link) to establish their respective responsibilities in connection to their compliance with the obligations laid down in the Regulation with respect to the process for which they are joint controllers. Among joint controllers, TikTok is responsible for the rights of data subjects under Articles 15-20 of the Regulation in respect of the personal data stored by TikTok following joint-processing operations conducted jointly with the Company. |
| Adform | Use of Demand Side Platform and Ad Serving services provided by Adform A/S, with registered office address at Silkegade 3B, stuen & 1st floor, DK-1113 Copenhagen, Denmark (“Adform“). Through Adform’s services, the Company is able to plan and manage the delivery of profiled advertising campaigns on the Website, monitor and enhance the same, and track impressions and clicks relative to the ads delivered on the Website. Personal Data as well as information relative to the User’s browser/device are collected by using Adform’s tags on the Website, by the Company and by Adform in their capacity as joint controllers pursuant to Article 26 of the GDPR. The joint controllers shall furthermore pair and combine said data and information with data originating from other data sources, and will link several devices, create profiles to deliver personalised advertising, select personalised or contextual advertising, and see to the technical delivery of advertising. Additional information on joint controllership are provided by Adform on the following link. Users may also read Adform’s Product and Services Privacy Policy at the following link. To exercise their rights, Users may also use the information provided by Adform at the following link. |
(2) Third-Party Profiling Cookies
The Website also uses the following Third-Party Profiling Cookies, installed by third parties who act in the capacity as autonomous controllers (third-party cookies). Here is a list of the Third-Party Profiling Cookies currently used on the Website, with links to the information provided by the relative developers (also containing information on how to object to, or opt out of, the installation of said cookies, and on the relative retention time-frames).
| Third-Party Cookie | Cookie Policy Link |
| Adform | https://site.adform.com/privacy-center/platform-privacy/product-and-services-privacy-policy/ |
| Amazon | https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=201909010 |
| LeadGen | https://leadgenapp.io/privacy-policy |
| Tradedoubler | https://www.tradedoubler.com/it/privacy-policy/ |
| Unbounce | https://unbounce.com/privacy/ |
| Zeta Global |
(3) Additional Partners of the Company
Should you grant the relevant consent, additional partners of our Company may process personal data, through the Website, to delivery advertising and/or make measurements on the advertising served. For the relevant privacy or cookie policies, please refer to the policies i) which links are next to each vendor in the CMP and/or which links are provided by the publishers who delivery advertising content, with whom the User has interacted prior to landing on the Website, inside their properties.
E. How to Manage Cookies and Object to their Use
There are a few options to manage, disable, and delete Cookies.
(1) Change Your Browser’s Settings
Follow the instructions provided by the producer of the browser you use, to learn how to manage, disable, or delete all the cookies (technical, analytics, and profiling cookies).
• Explorer
• Edge
• Chrome
• Firefox
• Safari
• Opera
Make your choices after careful consideration. By indiscriminately blocking all cookies, including technical cookies, without setting a specific exception for the Website, you may no longer be able to browse on the Website or use all or part of the functionalities of the Website. In addition, by deleting all the cookies from your browser, technical cookies may also be removed, so you could remove the preferences you set when using the Website.
(2) Use our interactive tools or the tools provided by third parties
To disable Third-Party Cookies, check the privacy policies published by the third parties who install Cookies (see paragraphs C and D above), to know more about the other tools available to you to manage, disable, and delete Cookies, and more generally object to their use. Remember that by disabling Third-Party Cookies, (i) you object to their use not just on the Website but on all the Internet sites where said Cookies are used; and that (ii) the possibility to browse the Website and use its functionalities will not be compromised in any way.
(3) Use the Your Online Choices Website
Your Online Choices is website managed by the not-for-profit organisation European Interactive Digital Advertising Alliance (EDAA); the Italian version is available at the following link, where you can find information on online behavioural advertising based on profiling cookies, allowing Internet users to easily (opt-out) of the installation of the main profiling cookies installed by advertising servers and used on websites. Before using this tool, we recommend reading carefully the terms and conditions for the Your Online Choices website, frequently asked questions (FAQ) and help page.
Make an informed use of Your Online Choices. Though Your Online Choices does include many of the major advertising companies using cookies, some of the third parties who install cookies through the Website may not have joined Your Online Choices. Therefore, using Your Online Choices does not guarantee that no third-party cookies will be received when browsing the Website. Please also remember that by eliminating all the cookies from your browser, even the technical cookies issued by Your Online Choices to remember your choices may be eliminated, thus re-activating third-party cookies.
(4) Mobile Advertising ID
To opt-out, many devices such as iPhones, iPads or Android devices recommend checking the device’s settings and following the instructions provided by the device manufacturer. Please find below some information examples, which we provide for illustrative purposes only, and for which we assume no responsibilities or guarantees as to their proper operation or current version.
• Apple iOS
Open settings, then select “Privacy” -> “Location Services” -> “System Services” and change the “Location-Based iAds” option to “off“.
Open settings, then select “Privacy” -> “Advertising” and set the “Limit Ad Tracking” option to “on“.
To reset your Advertising ID on iOS, open settings, then select “Privacy” -> “Advertising” and select “Reset Advertising Identifier“.
• Android
Open Google settings, select “Ads” and then “Reset advertising ID” and “Opt out of interest-based ads“.
(5) CMP
For personal data processing operations that may be carried out, with the User’s prior consent, by third-party companies through Cookies, the User may also use the CMP implemented on the Website to provide or revoke their consent by following the relative steps.
F. Personal Data Processing Methods and Retention Time-Frames
As mentioned in the foreword of this Cookie Policy, the Company collects and processes some of your personal data through the Cookies it transmits directly on the Website (First-Party Cookies). The Company acts in the capacity as controller of these data, in compliance with the provisions of Applicable Law.
We will process your data exclusively through electronic tools, through fully automated processes without human intermediation. This means that our employees and associates will never access the content of your personal data obtained through cookies. Some of our employees and associations, who have been appointed by us as persons in charge of processing under Article 29 of the Regulation, may perform maintenance operations on the computer systems hosting your data, but will never have access to the actual content of said data. Personal data may be stored in servers managed by third parties (e.g., providers of computer systems), or they may be managed by parties specialised in on-line advertising, who act in the capacity of data processors on the basis of a written agreement in place between said parties and the Company under Article 28 of the Regulation.
Your personal data shall not be communicated to third-party controllers, nor shall your data be disclosed or otherwise published.
Your personal data shall be retained by the Company for the time strictly necessary to accomplish the primary purposes illustrated in this Cookie Policy, or according to what may be necessary to protect both your as well as the Company’s interests in civil proceedings, and in any case for no more than 24 months. The User’s personal data collected on the Website shall be processed by the Company, through Refine’s proprietary conversion tracking solution, for the purpose of correct attribution of conversions, for the time strictly necessary, and in any case for no longer than 24 hours. Once the origin of a conversion is attributed to a specific publisher, the User’s personal data are anonymised.
G. Transfer of Personal Data to Third Countries
Please be informed that, in compliance with the conditions and guarantees established by Applicable Law, your data may be transferred to Countries outside the European Economic Area (hereinafter, “EEA“), which may not offer a level of privacy or personal data protection comparable to that which is guaranteed under Italian and European privacy laws and regulations.
In detail:
– for the provision of the Google services, the Company’s provider, and namely Google Ireland Limited, may transfer pseudonymised data of the Website Users outside of the EEA, on the basis of the Standard Contractual Clauses or Adequacy Decision. In particular, if the data is transferred to the United States of America, they shall be transferred on the basis of the Data Privacy Framework adopted by Google LLC (more information available at the following link). In consideration of the scope of processing, the nature of the data processed, and the risks posed by the processing operations performed by the provider, the Company deemed the security measures which the provider guarantees to adopt to protect personal data to be appropriate.
– for the provision of the services offered by Adform, the Company’s provider, and namely Adform A/S, may transfer pseudonymised data of the Website’s Users outside of the EEA, on the basis of the Standard Contractual Clauses and particularly to the United States of America, adopting to such end the supplementary measures designed to ensure that such transfer occurs in compliance with the Regulation.
Please note that some of the third parties listed in the tables in this Cookie Policy and/or in the CMP may – in their capacity as autonomous controllers of the data collected through Third-Party Cookies, or, in any case, for processing operations carried out in the capacity as autonomous controllers after data collection in joint controllership with the Company – process the personal data collected through the Cookies installed on the Website from a location outside of the European territory; therefore, we recommend to carefully read their privacy and cookie policies reported above for additional information in such regard (for example, more information on Tradedoubler’s transfers can be found at the following link). Also note the transferred carried out by Meta (more information here and here), and by Outbrain (more information here and here) and by Outbrain (more information here) with respect to the further processing operations carried out by these latter in their capacity as autonomous controllers after initial collection in joint controllership with the Company.
H. Your Rights
In order to exercise your rights, and obtain additional information or clarifications relative to this Cookie Policy, please contact the Company by
• sending a registered letter with proof of receipt to the registered office address of the Company (Viale Monza 265, 20126 Milan, Italy);
• sending an-email to: richieste_privacy@refine.direct.
You may also contact the Data Protection Officer (DPO) of the Company via e-mail, by writing to: dpo@refine.direct.
Under Applicable Law, Users have
a. the right to revoke their consent at any time, where processing is based on their consent;
b. the right of access to personal data;
c. (where applicable) the right to data portability (right to receive all the personal data concerning them in a structured, commonly used and machine-readable format), the right to restrict the processing of their personal data, the right to obtain the rectification and the right to obtain the erasure of e personal data (“right to be forgotten).
d. the right to object
i. in whole or in part, on legitimate grounds, to the processing of the personal data regarding them, including where pertinent to the purpose for which they were collected;
ii. in whole or in part, to the processing of the personal data regarding them for the purpose of sending advertisement material or for direct sales, or to perform market surveys or for the purpose of commercial communication;
e. where they believe that the processing regarding them is in violation of the Regulation, the right to lodge a complaint with the supervisory Authority (in the member State in which they habitually reside, in the member State in which they work, or in the member State where the alleged violation took place). The Italian supervisory Authority is the Italian Data Protection Authority (or “Garante per la Protezione dei Dati Personali”), with address at Piazza Venezia, 11, 00186 – Rome (RM) Italy (https://www.garanteprivacy.it/).
The Company is not responsible for updating all the links featured in this Cookie Policy. Therefore, if a link doesn’t work properly and/or is not updated, the Users acknowledge and accept that they should always refer to the document and/or section of the websites referred to by said link.