​​Further information for Italian Residents

We process the personal data of Italian residents in accordance with:

• the EU General Data Protection Regulation 2016/679 ("GDPR");
• the Italian Personal Data Protection Code, Legislative Decree no. 196/2003 as amended by Legislative Decree no. 101/2018 (the "Privacy Code"), in particular Article 122 (storing or accessing information on your device) and Article 130 (unsolicited communications);
• the guidelines of the Italian Data Protection Authority (Garante per la protezione dei dati personali) on cookies and other tracking tools of 10 June 2021, and any later guidance it issues on tracking pixels.

We only use tracking pixels in emails sent to you, or on our websites and campaign pages, if you have given your prior consent. You can refuse or withdraw consent at any time, and doing so will not affect your ability to receive our emails or take part in our promotions.

What a tracking pixel is. A tracking pixel (also called a web beacon or spy pixel) is a tiny, usually invisible image embedded in an email or web page. When the email or page is opened and the image loads, information is sent from your device to us or to our service provider.

What information it collects:

• whether and when you opened an email, and how many times;
• whether you clicked a link in the email;
• your IP address and approximate location (city or country level) derived from it;
• your device type, operating system and email client or browser.

Why we use it:

• to measure whether our communications reach and interest you;
• to improve the content, timing and frequency of our communications;
• to produce aggregated statistics on campaign performance for us and our clients.
• We do not use pixel data to make decisions that produce legal or similarly significant effects on you.

We do not use pixel data to make decisions that produce legal or similarly significant effects on you.

Legal basis. Under Article 122 of the Privacy Code and the Garante's guidelines, reading information from your device through a pixel requires your consent unless it is strictly necessary to deliver the service you asked for. Pixels used for measurement and analytics are not strictly necessary, so we rely on your consent (Article 6(1)(a) GDPR). Where we combine pixel data with your profile to personalise communications, this is also based on your consent.

Service providers. Pixels are operated on our behalf by our email and analytics providers, who act as our data processors under a written contract.

How long we keep it. We keep individual pixel data for 3 years from collection, after which it is deleted or anonymised. Aggregated statistics that no longer identify you may be kept longer.

Withdrawing consent is as easy as giving it, and you can do it at any time:

• use the "manage preferences" link at the bottom of any of our emails to switch off email tracking while still receiving our emails;
• use the "unsubscribe" link to stop receiving our marketing emails altogether;
• change your choices on our websites through the cookie and tracking settings link in the footer;
• email us at [email protected].

You can also block pixels yourself by turning off automatic image loading in your email client.

Withdrawing consent does not affect processing carried out before you withdrew it. Under the Garante's guidelines, if you refuse consent we will not ask you again for at least six months unless something material changes, such as the purposes or the providers we use.

We send marketing emails, SMS or other electronic communications to Italian residents only with your prior consent, as required by Article 130 of the Privacy Code. Consent to receive marketing and consent to email tracking are asked for separately, so you can accept one without the other.

If you are an existing customer, we may send you emails about our own products or services similar to those you have already bought, using the email address you gave us (Article 130(4) of the Privacy Code). You can object to this at the time we collect your address and in every message we send.

Age of consent. In Italy, a person aged 14 or over can give consent themselves for online services offered directly to them (Article 2-quinquies of the Privacy Code). For anyone under 14, consent must be given by a parent or guardian. Our promotions are not directed at children under 14.

Deceased persons. The rights described below may be exercised in relation to a deceased person's data by anyone with an interest of their own, acting on the deceased's behalf, or for family reasons worthy of protection, unless the person prohibited this in writing during their lifetime (Article 2-terdecies of the Privacy Code).

Under Articles 15 to 22 GDPR you have the right to:

• access your personal data, including pixel data, and receive a copy;
• have inaccurate data corrected;
• have your data erased;
• restrict our processing;
• receive your data in a portable format;
• object to processing, including at any time to direct marketing;
• withdraw consent at any time.

To exercise these rights, contact us using the details below. We will reply within one month, which may be extended by two further months for complex requests; we will tell you if this happens.

International transfers. Some of our providers may process pixel and contact data outside the European Economic Area. Where this happens we rely on an adequacy decision (including the EU–US Data Privacy Framework where the provider is certified) or on the European Commission's Standard Contractual Clauses, as described in the UK and EEA residents section.

Updates. We may update this section, for example to reflect new guidance from the Garante. The date at the top shows when it was last updated.