Cookie policy

POLICY REGARDING THE PROCESSING OF PERSONAL DATA OF ONLINE USERS - COOKIE POLICY PURSUANT TO THE REGULATION (EU) 2016/679 (“GDPR”)

WHAT ARE COOKIES?

Cookies are data created by a server which are saved in a text file on the hard disk of a computer or on any device used by the user to access the Internet (smartphone, tablet), and allow for the gathering of information regarding the navigation carried out by the user on the website.

Cookies can be saved permanently on your computer, and can be of variable duration (known as persistent cookies), but can also disappear on closure of the browser, or be of limited duration (known as session cookies).

Cookies can be installed by the website being visited (known as first party cookies) or by other websites (known as third party cookies).

HOW WE USE COOKIES

 

  1. Technical cookies
    1. session/navigation cookies: The use of session cookies (which are not permanently saved on the user’s computer and which disappear when the browser is closed) is strictly limited to the sending of session identifiers (made up of numbers randomly generated by the server) which are necessary in order to allow safe and efficient exploration of the website and its applications. The session cookies used by BULLFROG avoid the need for other IT techniques which are potentially detrimental to the confidentiality of navigation carried out by the users, and do not allow the gathering of personal data identifying the user. They do not require consent.
    2. Persistent cookies: persistent cookies remain on the device after exiting from the website, until they are deleted by the user or until they reach their expiry date. The BULLFROG website creates this kind of cookie and saves them on the device in order to be able to read them again when the user returns to the website. This, for example, allows users to find previously set preferences (e.g. wish list, shopping cart, etc.). They do not require consent.
  2. Analytic cookies: cookies installed to collect aggregated information of a prevalently statistical nature (the time spent on a website, the number of visitors to the site, etc.).
    1. First party analytic cookies: similar to technical cookies in that they are installed directly by the website being visited in order to improve the user experience. They do not require consent.
    2. Third party analytic cookies: analytic cookies created and installed by third parties in order to analyse user navigation for the creation of statistics on visits, or to improve the content, show products of a certain category and, if necessary, place targeted advertising on the website. The system used is Google Analytics, which is a web analysis service supplied by Google LLC (“Google”). Like other systems, Google Analytics employs cookies to allow the website to analyse how users use the website. The information generated by the cookies regarding the use of the website by the users (including their IP address) will be sent to, and deposited in, the Google servers located in the United States. Google will use this information in order to trace and examine the use of the website, prepare reports on the activity of the website and provide other services regarding the use of the internet. Google may also transfer this information to third parties when required to do so by law, or when said third parties process the aforementioned information on behalf of Google. Google will not associate the IP address of the user to any other data in Google’s possession. The user may, in any case, refuse to accept the cookies by selecting the relative setting on their browser, but this may hinder the use of all of the functions of the website. As the IP address is unencoded, the use of these cookies requires your consent. By clicking on the “Continue” button present in the banner, or by continuing to navigate the BULLFROG website, the user provides their consent for the processing of data by Google for the means and purposes indicated above.
  3. Profiling cookies: cookies used to track the navigation of the user online and create profiles regarding their tastes, habits, choices etc. Through these cookies, advertising messages can be sent to the user’s terminal in line with the preferences shown by the same user during online navigation.
    1. First party profiling cookies: used and installed by BULLFROG to collect information on the navigation habits of the user with the aim of proposing advertising messages which are as relevant as possible to their interests. This means that they are also used to limit the number of times in which a user sees a particular advert: for BULLFROG the result is more efficient communication, for the user the result is advertising which is less invasive and which better reflects their interests. During navigation within the BULLFROG website, promotional cookies allow for confirmation that the user is examining the advertising messages, showing promotional content which can be of interest according to what has previously been visited. These cookies also allow the showing of promotional messages regarding recently-consulted content from the BULLFROG website while the user continues to navigate to other websites. The BULLFROG website uses promotional cookies in an exclusively anonymous manner: the advertising is targeted, but the user is not identifiable. The promotional cookies used are permanent, although they remain on the user’s device for a limited period of time. They require consent.
    2. Third party profiling cookies: used and installed by third parties in order to track the navigation of the user on the internet and create profiles according to their tastes, habits, choices etc. These cookies are managed by third party companies such as TagMan, DoubleClick and AddThis. On the BULLFROG website it is also possible to find social buttons/widgets, i.e. those special “buttons” which carry the icons of the various social networks (for example Facebook and Twitter). These buttons allow users who are navigating the website to directly reach and interact with social networks with a click. Thanks to clicks on social buttons/widgets, the social network in question acquires data regarding the visit by the user to the BULLFROG website, and at the same time it releases its own profiling cookies.

MANAGEMENT OF COOKIE PREFERENCES

The consent for the use of cookies is presented in one of the following ways:

  • by clicking on the “Continue” button present in the banner containing the summarised privacy policy, which appears the moment the user enters the website;
  • by continuing navigation on the BULLFROG website by accessing another area of the website or by selecting an element on the same page.

HOW TO MODIFY COOKIE SETTINGS

The majority of Internet browsers are set by default to accept cookies automatically. This means that the user has the possibility, at any time, to set their browser to accept all cookies, only certain cookies, or to refuse them, deactivating their use by websites. Furthermore, the user can usually set their browser preferences in such a way as to be advised every time a cookie is saved by their computer. At the end of each navigation session, the user can also cancel the cookies collected from the hard disk of their computer. If you want to eliminate the cookies installed in the cookie folder of the browser used, you need to remember that each browser has different procedures for the management of settings.
By clicking on the links below, the user may receive specific instructions regarding some of the most common browsers:
Microsoft Windows Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Google Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies
Mozilla Firefox: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
Apple Safari: http://docs.info.apple.com/article.html?path=Safari/5.0/en/9277.html
If the user prefers not to receive cookies sent by Google Analytics, they can exercise this right by visiting the page: https://tools.google.com/dlpage/gaoptout/ 
If the user wants to learn more about cookies in general, they can visit the page http://www.allaboutcookies.org
If the user wants to learn more about behavioural advertising and online privacy, they can visit the page http://www.youronlinechoices.com
If the user wants to learn more about cookies by Google Analytics, they can visit http://www.google.com/intl/it/analytics/privacyoverview.html
If the user wants to learn more about the cookies by Criteo used by our website, they can visit http://www.criteo.com/en/privacy-policy

MANDATORY NATURE OF THE PROVISION OF DATA

The personal data processed via the installation of first party technical and analytic cookies is necessary in order to guarantee the correct navigation within the website.

The granting of consent for the installation of third party analytic and profiling cookies is optional. Your personal data will be processed by said cookies only if you have expressed you consent in the aforementioned manners.

RECIPIENTS OF THE DATA

The data can be processed by external entities operating as autonomous Data controllers such as, for example, supervisory authorities and bodies.

The data may also be processed on behalf of the Company by external entities designated as Data processors, who are provided with appropriate operating instructions. Said entities are fundamentally included in the following categories:

  1. companies offering email services;
  2. companies which offer services necessary for the fulfilment of the purposes indicated in this policy (IT suppliers, companies which deal with the management and maintenance of the website, etc.).

ENTITIES AUTHORISED FOR PROCESSING

The data may be processed by employees of the business functions charged with the fulfilment of the purposes indicated above, who are expressly authorised for the processing and have received appropriate operating instructions.

TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE OF THE EUROPEAN UNION

There is no provision for the transfer of data outside of the European Union

RIGHTS OF THE DATA SUBJECT - LODGING OF COMPLAINTS WITH THE SUPERVISORY AUTHORITY

By contacting the Privacy Office, by mail, at the address BULLFROG S.r.l., Via Giorgio e Guido Paglia, n. 1/D, 24122, Bergamo, Italy, for the kind attention of the Data Protection Officer, by calling +39 035280111 or by email at the address privacy@percassi.com, data subjects may ask the Data controller for access to the data concerning them, its erasure, the rectification of incorrect data, the completion of incomplete data, the restriction of processing in the cases provided for by article 18 of the GDPR, as well as object to processing in the eventual legitimate interests of the data controller.

Data subjects also, in the case in which the processing is based on consent or contract and is carried out with automated tools, have the right to receive the data in a structured, commonly used, machine-readable and interoperable format, and, if technically possible, to transmit it to another controller without hindrance.

Data subjects have the right to revoke the consent given at any time for marketing and/or profiling purposes, as well as to object to the processing of data for marketing purposes, including profiling connected to direct marketing. Data subjects who prefer to be contacted for the aforementioned purpose exclusively via traditional methods may express their objection solely for the reception of communications via automated systems.

Data subjects have the right to lodge a complaint with a supervisory authority in the Member State of his or her habitual residence, place of work or place of the alleged infringement.