COOKIE POLICY

This policy regarding the use of Cookies applies to the current Website as well as all landing pages connected and/or related to it (hereinafter for brevity “the Site”) and to all related pages and sections within the domain, as well as to third-party platforms (for example, Facebook, Instagram, Linkedin, YouTube, Google, etc.) and to the applications that are accessed, or that are used through this Site. By using the Site, you consent to the use of Cookies in accordance with this “Cookie Policy”. If you do not consent to the use of Cookies, you must set your browser appropriately, disabling the use of the types of Cookies chosen, as better indicated in the section below “How can I give or withdraw consent to the installation of Cookies?” . However, please note that the decision to disable technical Cookies necessary for the functioning of the Site could influence the User’s browsing experience. Below we report the different types of Cookies that the Site uses, together with their respective function, so that the User can consciously express his/her consent to the use of the Cookies themselves. What are Cookies? Cookies are small text files, made up of letters and numbers, that the sites visited by the User send to his terminal (usually to the browser) and that can be saved and stored for a certain period of time on the computer (or on other enabled devices, for example, smartphones, or tablets, etc.), to then be retransmitted to the same website, so that the server of the latter can consult them on the next visit of the same User. During navigation on a site, the User can also receive on his terminal Cookies that are sent from different sites or web servers (so-called “third parties”), from which some elements (such as, for example, images, maps, sounds, specific links to pages of other domains) displayed derive. Cookies have the function of streamlining the analysis of web traffic or of signaling when a specific site or a part of it is visited or even of distinguishing visitors from each other in order to provide them with personalized content; in addition, Cookies help administrators to improve the site and the browsing experience on it. For example, some Cookies are used to perform computer authentication, monitor sessions, store information on specific configurations regarding users who access the server, etc.; other Cookies can be used to monitor and profile users during navigation, study their movements and habits of web consultation or consumption (what they buy, what they read, etc.), also for the purpose of sending targeted and personalized advertising services. COOKIES can be FIRST PARTY or OWN , when they are installed directly by the manager/administrator of the site you are visiting. THIRD PARTY COOKIES are instead defined as those installed on the terminal by a party other than the manager of the site that the User is visiting. What do we use Cookies for?

TECHNICAL COOKIES

The Site uses Cookies for its technical needs, which are essential for its correct functioning and which allow the User to navigate and view the contents and use its features. Typically, Cookies of this type are necessary, for example, to keep a browsing session open or to temporarily store texts entered while filling out a form, when you return to a previous page during the same session. Therefore, their eventual deactivation could lead to the malfunctioning of the Site. Please note that the User’s consent is not required to create this type of cookie. Within the scope of technical Cookies it is also possible to further distinguish between:

TECHNICAL COOKIES: SESSION COOKIES OR SESSION COOKIES

Among technical Cookies, we first distinguish “session Cookies” or “session Cookies”. A “session Cookie” or “session Cookie” is active only for the reference browsing session and is deleted when the User closes the browser window and allows the Site to temporarily store the information necessary for navigation from one page to another, avoiding having to re-enter it. They therefore allow, for example, to identify the status of the user and verify and detect whether the user is logged in (i.e. has accessed a reserved section of the Site by logging in/entering their credentials). The use of these Cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient exploration of the Site. This Site uses session Cookies to avoid the use of other IT techniques potentially prejudicial to the confidentiality of the Users’ navigation, as these Cookies do not allow the acquisition of Personal Data identifying the User. The User’s consent is not required to use this type of Cookie. Please note that in any case it is possible to deactivate session Cookies by consulting the specific section of this Cookie Policy called “How can I give or withdraw consent to the installation of Cookies”. By disabling these technical Cookies, the Site may not function correctly.

TECHNICAL COOKIES: PERSISTENT COOKIES

Among technical Cookies, we can distinguish “Persistent Cookies”. A “Persistent Cookie” is used to maintain information in the period between one access and another to the Site, or for technical purposes and to improve navigation on the Site, allowing to recognize a User or visitor already known. It remains on the device used by the User beyond the closure of the single session, and more precisely:

for the “lifespan” of the individual Cookie, which is set by the website and can vary from a few minutes to several years (it should be noted that each type of these Cookies has its own specific duration);
until they are manually deleted, via the browser settings, which can be changed by following the instructions found in the specific section of this cookie policy called “How can I give or withdraw consent to the installation of Cookies” .

The User’s consent is not required to use this type of Cookie. By disabling these technical cookies, the site may not function correctly.

COOKIES TECNICI: ANALYTICS COOKIES

Finally, among the technical Cookies, we can distinguish the Analytics Cookies, or Analytical Cookies, which are used to statistically analyse accesses/visits to the Site for exclusively statistical purposes (and not also for profiling and/or marketing) and which collect information in aggregate form without the possibility of tracing the identification of the individual User. Current legislation requires that for such Cookies the interested party be provided with clear and adequate indication of the simple methods for opposing (opt-out) their installation (including any mechanisms for anonymising the Cookies themselves). It is therefore always possible to deactivate Analytics Cookies without affecting the functionality of the Site by consulting the specific section of this cookie policy called “How can I give or withdraw consent to the installation of Cookies” .

B) PROFILING COOKIES

This type of Cookie, which can be either proprietary (i.e. sent by the Site) or third-party (e.g. social networks), is used to create personalized profiles relating to the User for advertising and marketing purposes, for example retargeting or advertising on social networks. This type of Cookie, therefore, is not generally necessary to guarantee navigation on the Site, or its perfect functionality and therefore the User must give his consent to its use. Consent may be denied, according to the methods indicated in the relevant section of this cookie policy called “How can I give or withdraw consent to the installation of Cookies” , which the User is invited to read carefully.

THIRD PARTY COOKIES

As already specified, it is emphasized that both technical Cookies (in particular analytics) and profiling Cookies may be from third parties. In particular, Google, Google Maps and other Google services, as well as Youtube, with regard to the use of videos and other services, as well as social networks (by way of example: Facebook, Instagram, Linkedin, etc.) may install such Cookies. However, since this list of Cookies depends on the choices of such third parties, the User is invited to consult, via the appropriate link included in the Privacy Policy of this Site, the respective cookie policies of the third parties in question, also in order to be able to disable, through the opt-out mechanism, the related Cookies installed. With reference to third-party cookies, the following is specified: The installation of Cookies and any other tracking systems that could be operated by third parties through the services used within the Site cannot be technically controlled by the Owner. Therefore, any specific reference to Cookies and tracking systems installed by third parties is to be considered indicative. To obtain complete information, the User is invited to carefully consult the privacy policy of any third-party services listed in this document before continuing to browse the Site. Given the objective complexity of identifying technologies based on Cookies, if the User wishes to receive any further information regarding the use of Cookies, he is invited to contact the Owner (as specified in the section “CONTACT INFORMATION”). -Google Analytics with anonymized IP; Google Analytics is a web analytics service provided by Google for statistical purposes to understand how visitors interact with the Site, compile reports and share them with other services developed by Google. Google Analytics may use a set of cookies to collect information and generate statistics on the use of the Site, without providing personal information on individual visitors to Google. The User’s IP address is anonymized. Anonymization works by shortening the IP address of Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google’s servers and shortened within the United States. Please note, however, that the data may also be processed outside the EEA. The User is also informed that from 16 July 2020 Google no longer bases the Processing of Users’ Personal Data on the EU-US Privacy Shield to transfer data from the European Economic Area and the United Kingdom to the United States; from 30 September 2020, more precisely, Google has updated its rules on the Processing of Personal Data and uses the standard contractual clauses approved by the European Commission and based on the adequacy decisions of the European Commission itself with respect to certain countries, as the case may be, for transfers of data from the EEA to the United States and other countries. As regards the use of cookies by Google Analytics, the User is invited, in any case, to carefully consult the relevant privacy policy and cookie policy , as well as the paragraph of this Cookie Policy “How can I give or withdraw consent to the installation of Cookies?” through the browser settings and the section of this Policy relating to the Privacy Shield.

Google Tag Manager

This Site uses Google Tag Manager. Google Tag Manager is a solution managed by Google LLC that allows you to manage the tags of managed websites using a specific interface. Google Tag Manager is a tag management system for managing JavaScript and HTML tags used for tracking and analysis on websites. Tags are small pieces of code that are used, among other things, to measure traffic and visitor behavior, to understand the effect of online advertising and social channels, to set up remarketing and targeting, and to test and optimize websites. The Tag Manager tool itself (which implements the tags) is a cookie-free domain and does not record Personal Data. This tool allows the activation of other tags that can, in turn, record Data in certain circumstances. For further information on the privacy policy of Google Tag Manager, the User is asked to consult the following link https://policies.google.com/privacy?hl=en , while for the terms of use https://www.google.com/analytics/tag-manager/use-policy/ and for the answers on the privacy of Google Tag Manager https://support.google.com/tagmanager/answer/7207086 . Personal Data : Usage Data; other types of Data.

Facebook, Facebook Widget;

The Site contains buttons for redirecting or sharing to the Facebook social platform, and to the individual social network pages attributable to the Data Controller. Facebook shares information globally, both internally with Facebook Companies and externally with its partners and people you connect and share with around the world. Information controlled by Facebook may be transferred or transmitted to, or stored and processed in, the United States or other countries outside the EEA. According to its policy , Facebook may use cookies to show ads and make suggestions for businesses and other organizations to people who might be interested in their products, services, or causes; to measure the performance of advertising campaigns of businesses that use Facebook Products; to show and measure ads across different browsers and devices used by the same person; to provide statistical data about people who use Facebook Products; to provide information about people who interact with ads, advertisers’ websites and apps; and to enable functionality that allows Facebook to provide its Products. Furthermore, when visiting the Site, the Facebook Pixel cookie may be installed , which allows the Data Controller to monitor conversions that occur on the Site as a result of the advertisements that are running on Facebook. The information collected through cookies may be shared with organizations outside of Facebook, such as advertisers and/or advertising networks for the publication of advertisements and for measuring the effectiveness of advertising campaigns. We also inform you that as of July 16, 2020, Facebook no longer bases the Processing of Users’ Personal Data on the EU-US Privacy Shield to transfer data from the European Economic Area and the United Kingdom to the United States; but uses standard contractual clauses approved by the European Commission and based on the adequacy decisions of the European Commission regarding certain countries, as applicable, for transfers of data from the EEA to the United States and other countries. In relation to the Privacy Shield, the User is referred to reading the relevant paragraph in the cookie policy. In this case the following Personal Data are processed : Cookies; Usage Data; other types of Data. For more information on the installation and use of cookies by Facebook, please read the relevant cookie policy carefully . Finally, please read the privacy policy of the service carefully to obtain detailed information on the collection and transfer of Personal Data, on the User’s rights and on how to configure the privacy settings in a satisfactory manner.

Instagram, Instagram Widget

The Site contains buttons for redirecting or sharing to the Instagram social platform, owned by Facebook, and to the individual pages of the social network attributable to the Data Controller. Facebook/Instagram shares information globally, both internally with Facebook/Instagram Companies and externally with partners and people you connect with. Based on what is indicated in the relevant policies, Instagram uses cookies, pixels, local storage technologies and other similar technologies to show the User content relevant to offer the service and for reasons related to its use, as well as to collect information relating to the use of Instagram by the User. Instagram may also use said technologies to remember the choices made by the User (e.g. User name, language or geographical area in which the User is located) and personalize the Service to offer better features and content. Instagram and its advertising partners may use these technologies to show the User ads relevant to his interests. These technologies remember the visits of the User’s device and may also be able to monitor the browsing activities of the device on sites and services other than Instagram. This information may be shared with organizations outside of Instagram, such as advertisers and/or advertising networks for the publication of ads and for measuring the effectiveness of advertising campaigns. The information controlled by Facebook/Instagram may be transferred and/or transmitted and/or stored and/or processed in the United States or in other countries outside the User’s country of residence or in any case outside the EEA for the purposes described by the legislation referred to in the following links: Facebook Terms ; Instagram Terms . The User is also informed that from 16 July 2020 Facebook/Instagram no longer bases the Processing of Personal Data of Users on the EU-US Privacy Shield (EU-US Privacy Shield) to transfer data from the European Economic Area and the United Kingdom to the United States; but uses standard contractual clauses approved by the European Commission and based on the adequacy decisions of the European Commission regarding certain countries, as the case may be, for transfers of data from the EEA to the United States and other countries. In relation to the Privacy Shield, the User is referred to reading the relevant paragraph in the Cookie Policy. In this case the following Personal Data are processed: Cookies; Usage Data; other types of Data. As regards the management of cookies installed by Instagram and the relative deactivation methods, the User is invited to carefully consult, in addition to the relative privacy policy of the service, also the cookie policy , for detailed information on the collection and transfer of Personal Data, on the User’s rights and on how to configure the privacy settings in a satisfactory manner. Finally , as regards the conditions of use of the Instagram service, the User is invited to consult the said conditions.

Google Maps

Google Maps is a map viewing service managed by Google LLC or by Google Ireland Limited, depending on the location from which the Site is viewed, which allows the Site to integrate such content within its pages. Personal Data : Cookies; Usage Data; other types of Data. In relation to the methods of processing of personal data and the place of processing, the User is invited to carefully consult the relevant Privacy Policy . The data may be processed outside the EEA. The User is also informed that from 16 July 2020 Google no longer bases the Processing of Users’ Personal Data on the EU-US Privacy Shield to transfer data from the European Economic Area and the United Kingdom to the United States; from 30 September 2020, more precisely, Google has updated its rules on the Processing of Personal Data and uses the standard contractual clauses approved by the European Commission and based on the adequacy decisions of the European Commission itself with respect to certain countries, as the case may be, for transfers of data from the EEA to the United States and other countries. As regards the use of cookies by Google Analytics, the User is invited, in any case, to carefully consult the relevant privacy policy and cookie policy , as well as the paragraph of this Cookie Policy “How can I give or withdraw consent to the installation of Cookies?” through the browser settings and the section of this Policy relating to the Privacy Shield.

Google invisible reCaptcha

reCAPTCHA is a free captcha service from Google that protects websites from spam software and misuse by non-human visitors. This service is mostly used when filling out contact forms to ensure that specific actions on the internet are performed by humans and not bots. Classic captchas work with small tasks that are easy for humans to solve, but provide considerable difficulty for machines. With reCAPTCHA, the User no longer has to actively solve puzzles. The tool uses modern risk techniques to distinguish people from bots. The only thing the User has to do is check the text field “I am not a robot”. However, with Invisible reCAPTCHA even this is no longer necessary. reCAPTCHA, integrates a JavaScript element into the source text, after which the tool runs in the background and analyzes the user’s behavior. The software calculates a so-called captcha score from the User’s actions. Google uses this score to calculate the probability that the User is a human, before entering the captcha. reCAPTCHA and Captcha in general are used whenever bots could manipulate or abuse certain actions (such as registrations, surveys, etc.). By using reCAPTCHA, data is transmitted to Google to determine whether the user is really human. reCAPTCHA thus ensures the security of our website and, consequently, also that of the user. IP addresses and other data required by Google for its reCAPTCHA service may be sent to Google, whose servers may be located in the USA. First, the reCAPTCHA algorithm checks whether Google cookies from other Google services (YouTube, Gmail, etc.) have already been placed in the User’s browser. Then reCAPTCHA sets an additional cookie in the User’s browser and takes a snapshot of the browser window. The IP address that your browser transmits to Google is generally not merged with other Google data from other company services. However, the data will be merged if the User is logged in to the Google account while using the reCAPTCHA plug-in. If you want to prevent your data and behavior from being transmitted to Google, you must log out of Google completely and delete all Google cookies before visiting our website or using the reCAPTCHA software. Typically, data is automatically sent to Google as soon as you visit our website. To delete this data, you must contact Google Support at https://support.google.com/?hl=en-GB&tid=111401120 . If you use our website, you agree that Google LLC and its representatives automatically collect, process and use data. You can find more information about reCAPTCHA on the Google Developers page at https://developers.google.com/recaptcha/ . For more information, please read Google’s Privacy Policy and Terms of Service carefully. Personal Data : Cookies; Usage Data; other types of Data.,

Facebook e Instagram Remarketing

Facebook (and Instagram) remarketing is a remarketing and behavioral targeting service provided by Facebook Inc. With the help of the Facebook pixel (or equivalent functions for transferring event data or contact information via interfaces or other software in the apps) Facebook (/Instagram) is able to frame the visitors of this Site online services as a target group for the presentation of advertisements. Therefore, this Site uses the remarketing function “Custom Audiences” of Facebook Inc.: this allows Users of the Site to display interest-based advertisements (“Facebook Ads” or “Instagram Ads”) when they browse the social networks Facebook or Instagram or other websites that use this process. In this way, advertisements that are of interest to the User are shown in order to make online offers more interesting for him/her. The use of Custom Audience causes the User’s browser to automatically establish a direct connection to the Facebook/Instagram server. The data collected is processed by Facebook Inc. in the United States. This Site has no control over the scope of the Data collected and the further use of the aforementioned Data by Facebook Inc.: please therefore carefully read the relevant Facebook Privacy Policy and the Instagram Privacy Policy . The User can obtain more information about Facebook behavioral advertising by visiting this page: https://www.facebook.com/help/164968693837950 To opt out of Facebook interest-based ads, please follow these instructions: https://www.facebook.com/help/568137493302217 Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. To opt out of Facebook and other participating companies through the Digital Advertising Alliance in the United States http://www.aboutads.info/choices/ , the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ , or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/ , or disable it using your mobile device settings. Disabling the “Facebook Custom Audiences” function is available for users logged in at https://www.facebook.com/settings/?tab=ads# . Personal Data : Usage Data; email, Cookies, other types of Data.

WordPress.com

To register for the reserved area and authenticate during access, this Site uses the WordPress platform. For more information on the processing of Data by WordPress, the User is invited to read the relevant privacy policy . Personal data : various types of Data. PRIVACY SHIELD The Privacy Shield , or “privacy shield” between the EU and the US, is a self-certification mechanism for companies established in the US that intend to receive Personal Data from the European Union. It was also deemed adequate by the European Commission in 2016. In particular, the companies undertake to respect the principles contained therein and to provide the interested parties (i.e. all the subjects whose Personal Data have been transferred from the European Union) with adequate protection tools, under penalty of elimination from the list of certified companies (“Privacy Shield List”) by the US Department of Commerce and possible sanctions by the Federal Trade Commission . However, with Decision 2016/1250 of 16 July 2020 on the adequacy of the protection offered by the EU-US Privacy Shield regime – the so-called “ Schrems II Judgment ”, the Court of Justice of the European Union (CJEU) has however stated that the Privacy Shield does not offer an adequate level of protection for Personal Data transferred from the EU to a company established in the United States. With the same ruling, the European Court of Justice confirmed decision 2010/87, deeming the standard contractual clauses for the transfer of personal data from the EU to a non-EU country to be valid. The User is invited to consult the FAQs relating to the Schrems II ruling and its effects prepared by the European Data Protection Board (EDPB), the website www.privacyshield.gov and the website of the Italian Data Protection Authority to better understand the issue. How can I give or withdraw consent to the installation of Cookies? The User can manage preferences relating to Cookies and prevent – for example – third parties from installing them in the following way:

through the appropriate browser setting –
In most of the latest generation browsers it is possible to choose the Do Not Track option , which allows you to automatically stop the collection of some navigation data. However, not all websites are set up to allow this option (discretionary).
Some browsers allow the User to navigate in “ anonymous ” mode , limiting the amount of Data set on his computer and automatically deleting persistent Cookies placed on his device when he finishes browsing. In this case, the sites visited will not detect the User, the pages viewed and the related cookies will not be stored. However, the anonymous browsing function does not guarantee anonymity on the Internet, because it only deletes Cookies from your browser but not those processed by website managers and connectivity providers.
In all browsers it is possible to manually delete Cookies. However, the User is reminded that with each connection to the Internet new Cookies are downloaded and therefore the User must delete Cookies periodically. If desired, some browsers offer automated systems for the periodic deletion of Cookies.
by expressly denying consent – generally required only for profiling Cookies – in the event that the Site uses a latest-generation banner.

The User can find information on how to manage Cookies with some of the most popular browsers, for example, at the following addresses: Google Chrome , Mozilla Firefox , Apple Safari , Microsoft Internet Explorer and Microsoft Edge . With reference to any identifiers used by third parties, Users can manage their settings and revoke their consent by visiting the relevant opt-out link (if available), using the tools described in the third party’s privacy policy or by contacting the third party directly. With specific reference to Google Analytics, the User can, for websites that use the supported version of the Google Analytics JavaScript code (analytics.js, gtag.js), opt-out/deactivate Google Analytics by clicking here . Without prejudice to the foregoing, Users are informed of the possibility of using the information provided by YourOnlineChoices (EU), Network Advertising Initiative (USA), Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. The Data Controller therefore recommends that Users also consult these sites. **** CONTACT INFORMATION Data Controller: NUOVA POMUP SICILIA SRL – P.IVA 05330190876 CONTRADA CORVO SS 124 KM, 42+0,368 95049 VIZZINI (CT) Owner’s email address: info@pomupsicilia.it DEFINITIONS AND LEGAL REFERENCES “Cookie” o “Cookies” Small portion(s) of data stored within the User’s device. “ Sensitive and/or particular data” Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as processing genetic data, biometric data intended to uniquely identify a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. “ Usage Data” This information is collected automatically through the Site and/or by third-party applications integrated into the Site, including: the IP addresses or domain names of the computers used by the User who connects to the Site, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages visited, the parameters relating to the operating system and the IT environment of the User. “ Personal Data” or “Data” or “Personal Data” or “Data” Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable. “ Interested Party” or “Interested Parties” The natural person to whom the Personal Data refers. “ Profiling” Any form of automated processing of Personal Data consisting of the use of such Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. “ Service” The Service provided by the Site as defined in the relevant terms (if any) on this site/application. “ Data Controller” or “Owner” The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the Processing of Personal Data and the tools used, including the security measures relating to the operation and use of the Site. The Data Controller, as better identified and identified above, unless otherwise specified, is the owner of the Site. “ Processing” or “Data Processing” Any operation or set of operations, performed with or without the aid of automated processes and applied to Personal Data or sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, erasure or destruction. “ European Union” or “EU” Unless otherwise specified, any reference to the European Union contained in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area (EEA). “ User” or “Users” The individual or individuals who use/use the Site and who, unless otherwise specified, coincide with the Interested Party. Legal references This privacy policy is drawn up on the basis of the legislation in force on the matter, and in particular by the provisions of articles 13 and 14 of Regulation (EU) 2016/679 (so-called GDPR), and within the limits of what is still applicable by Legislative Decree 196/2003. Last updated: February 08, 2022.

COOKIE POLICY

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