Cookie Policy of www.inomluxuryauctions.com

This document contains information about the technologies that allow this Application to achieve the purposes described below. These technologies enable the Data Controller to collect and store information (for example, through the use of Cookies) or to use resources (for example, by running a script) on the User’s device when the User interacts with this Application. For simplicity, these technologies are briefly referred to as “Tracking Tools” in this document, unless there is a reason to differentiate.

For example, although Cookies can be used in both web and mobile browsers, it would be inappropriate to talk about Cookies in the context of mobile applications, since they are Tracking Tools that require the presence of a browser. For this reason, within this document, the term “Cookie” is used only to specifically indicate that particular type of Tracking Tool.

Some of the purposes for which Tracking Tools are used may also require the User’s consent. If consent is given, it can be freely revoked at any time by following the instructions contained in this document.

This Application uses Tracking Tools managed directly by the Owner (commonly referred to as “first-party” Tracking Tools) and Tracking Tools that enable services provided by third parties (commonly referred to as “third-party” Tracking Tools). Unless otherwise specified within this document, such third parties have access to their respective Tracking Tools.

The duration and expiration of Cookies and other similar Tracking Tools may vary depending on what is set by the Owner or each third-party provider. Some of them expire at the end of the User’s browsing session.

In addition to what is specified in the description of each of the categories listed below, Users can obtain more detailed and up-to-date information about the duration, as well as any other relevant information – such as the presence of other Tracking Tools – in the privacy policies of their respective third-party providers (via the provided links) or by contacting the Owner.

Activities strictly necessary to ensure the functioning of this Application and the provision of the Service.

This Application uses Cookies commonly referred to as “technical” or other similar Tracking Tools to perform activities strictly necessary to ensure the functioning or provision of the Service.

These information does not concern other websites, pages, or online services that can be accessed via hyperlinks possibly published on the Site but referring to resources external to the Owner’s domain.

This Privacy Policy refers exclusively to data collected through the Site and to cookies used for browsing the web pages of the Site and does not extend to data collected directly, or through cookies, from sites managed by other entities to which the Site may possibly refer.

Other activities involving the use of Tracking Tools.

Measurement
This Application uses Tracking Tools to measure traffic and analyze User behavior with the aim of improving the Service.

Anonymous statistical services

How to manage preferences and give or withdraw consent

There are various ways to manage preferences related to Tracking Tools and to give or withdraw consent, as necessary:

Users can manage preferences related to Tracking Tools directly through the settings of their devices – for example, they can prevent the use or storage of Tracking Tools.

In addition, whenever the use of Tracking Tools depends on consent, the User can give or withdraw such consent by setting preferences within the cookie policy or by updating such preferences through the tracking settings widget, if available.

Thanks to specific functions of the browser or device, it is also possible to remove previously saved Tracking Tools.

Other Tracking Tools stored in the local memory of the browser can be removed by clearing the browsing history.

Regarding third-party Tracking Tools, Users can manage preferences and withdraw consent by visiting the respective opt-out link (if available), using the tools described in the third-party privacy policy, or by contacting the third party directly.

Locating Tracking Tools Settings
Users can, for example, find information on how to manage Cookies in some of the most common browsers at the following addresses:

Users can also manage some Tracking Tools for mobile applications by disabling them through the appropriate device settings, such as mobile advertising settings or settings related to tracking in general (Users can consult the device settings to locate the relevant one).

Consequences of Refusing Consent
Users are free to decide whether to give their consent or not. However, please note that Tracking Tools allow this Application to provide a better experience and advanced functionality to Users (in line with the purposes outlined in this document). Therefore, in the absence of User consent, the Owner may not be able to provide the related features.

Data Controller

INOM S.R.L.
Via Giovanni Spadolini, 7
20141 Milano (MI)
VAT/Tax Code: 12510780963

Email address of the Data Controller:info@inomluxuryauctions.com

Pec: inom@legalmail.it

Since the use of third-party Tracking Tools on this Application cannot be fully controlled by the Data Controller, any specific reference to third-party Tracking Tools should be considered indicative. For comprehensive information, Users are kindly invited to consult the privacy policy of the respective third-party services listed in this document.

Given the objective complexity of tracking technology identification, Users are encouraged to contact the Data Controller should they wish to receive further information regarding the use of such technologies on this Application.

DEFINITIONS AND LEGAL REFERENCES

 

Personal Data (or Data)
Any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes it possible to identify a natural person, constitutes personal data.

Usage Data
These are the information collected automatically through this Application (also from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User connecting with this Application, URI (Uniform Resource Identifier) addresses, the time of the request, the method used in submitting 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 features of the browser and operating system used by the visitor, various time details of the visit (such as the time spent on each page), and the itinerary details within the Application, with specific reference to the sequence of pages consulted, parameters related to the operating system, and the User’s computer environment.

User
The individual who uses this Application, unless otherwise specified, corresponds to the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (o Processor)
The natural or legal person, public authority, agency, or any other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (o Controller)
The natural or legal person, public authority, agency, or other body which, individually or jointly with others, determines the purposes and means of the processing of Personal Data and the tools adopted, including the security measures related to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application
The hardware or software tool through which the Personal Data of Users is collected and processed.

Service

The Service provided by this Application as described in the relevant terms (if any) on this website/application.

European Union (EU)

Unless otherwise specified, any reference to the European Union in this document is intended to encompass all current member states of the European Union and the European Economic Area.

This Cookie Policy specifically aims to illustrate the types of cookies installed on the website www.inomluxuryauctions.com, their purposes, and methods of use, as well as to provide guidance on how users can refuse consent, even at a later time, and/or change, at any time and easily, the options related to the use of cookies by the Site.

To change cookie settings, the user must access the settings of the browser used following the instructions provided in this Cookie Policy.

What are cookies?
Cookies are typically text strings that websites (so-called Publishers, or “first parties”) visited by the user or different websites or web servers (so-called “third parties”) place and store – directly, in the case of publishers and indirectly, i.e., through the former, in the case of “third parties” – on a terminal device available to the user themselves.

The information encoded in cookies may include personal data, such as an IP address, a username, a unique identifier, or an email address, but may also contain non-personal data, such as language settings or information about the type of device that a person is using to browse the site.

Cookies can perform important and varied functions, including monitoring sessions, storing information about specific configurations regarding users accessing the server, facilitating the enjoyment of online content, etc. They can, for example, be used to track items in an online shopping cart or information used for filling out a computer form.

While cookies can allow web pages to load faster and route information over a network – thus in line with obligations closely related to the operation of websites – they can also be used to deliver behavioral advertising and then measure the effectiveness of the advertising message, or tailor the type and mode of services rendered to the behavior of the user subject to previous observation.

The Italian Data Protection Authority, in the “Cookie and Other Tracking Tools Guidelines” of June 10, 2021, which came into force on January 10, 2022, identified the following macro-categories of cookies:

  1. Technical cookies: they are those used for the sole purpose of “carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide that service” (cf. art. 122, paragraph 1, of Legislative Decree no. 196/2003, also Privacy Code). For the use of such cookies and other technical identifiers, the prior consent of users is not required, while the obligation to provide information pursuant to art. 13 of Regulation (EU) no. 2016/679 remains unchanged, which the website manager may provide in the manner deemed most appropriate.
  1. Profiling cookies: used to track specific actions or recurring behavioral patterns in the use of offered functionalities (patterns) with the aim of grouping different profiles into homogeneous clusters of various sizes, so that the data controller can, among other things, tailor the service delivery in a more personalized way beyond what is strictly necessary for the service provision, as well as send targeted advertising messages, i.e., in line with the user’s preferences expressed during online browsing.

Due to the significant intrusion into users’ privacy that such cookies may have, European and Italian regulations require that users be adequately informed about their use and express their valid consent. Article 122 of the Privacy Code refers to them where it provides, in paragraph 1, that “the storage of information on a user’s device or access to information already stored is allowed only if the user has given his or her consent after being informed by simplified means”.

How do you delete cookies?

Each user can change the use of cookies by adjusting the settings of the browser in use. The user is able to modify the default configuration and, by setting the highest level of protection, permanently disable all cookies. However, it is important to note that this setting may render the Website unusable if essential cookies for the proper functioning of the functionalities are blocked.

The methods for blocking or deleting cookies from your device vary depending on the type of device (PC, smartphone, etc.) and the type of browser used.

Below are the links to instructions for the most common browsers:

  • Microsoft Edge – guide
  • Google Chrome – guide
  • Mozilla Firefox – guide
  • Apple Safari – guide

For information and to disable third-party analytical cookies, please visit the website:
www.youronlinechoices.com

What types and categories of cookies does the Data Controller use on the Website and for what purposes?

The Website uses technical cookies only to the extent necessary to allow safe and efficient exploration of the site. Analytical cookies are also used to produce statistics that do not allow the identification of IP addresses of those who browse the Authority’s website. The installation and use of such cookies do not require the prior consent of the user as they are comparable to technical cookies. No cookies are used for user profiling (nor are other tracking methods employed).

In particular, the data acquired by the Website through analytical cookies are processed in an aggregated, and therefore anonymous, form in order to understand which are the most visited pages and, more generally, the ways in which it is used. This type of cookie is provided exclusively by third parties:

Changes to the Cookie Policy
The Data Controller reserves the right to amend the Cookie Policy at any time. Users are advised to check the date of the last revision at the bottom of the page. Any changes to this policy will take effect from the date of publication on the Website.

Tracking Tool
A Tracking Tool refers to any technology – e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting – that enables the tracking of Users, such as by collecting or storing information on the User’s device.

Legal References
This privacy policy is drafted based on multiple legislative frameworks, including Articles 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy policy exclusively concerns this Application.

TYPES OF DATA PROCESSED AND PURPOSES OF PROCESSING

Browsing Data

The computer systems and software procedures used to operate this Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This category of data includes IP addresses or domain names of the computers and terminals used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters relating to the user’s operating system and computer environment.

Such data is processed exclusively in aggregate and anonymized form.

These data, necessary for the provision of web services, are processed for the following purposes:

  • obtaining statistical information on the use of services (most visited pages, number of visitors per hour or day, geographical areas of origin, etc.);
  • checking the proper functioning of the services offered;
  • understanding how to improve the quality of website navigation.

 

Voluntarily Provided Data by Users

The optional, explicit, and voluntary sending of messages to the contact addresses of the controller, private messages sent by users to the profiles/pages of the controller on social media platforms (where this possibility is provided), as well as the completion and submission of forms on the controller’s website, involve the acquisition of the sender’s contact data, necessary to respond, as well as all personal data included in the communications.

Specific information for data subjects pursuant to Article 13 of the Regulation will be published on the pages of the Website set up for the provision of certain services.

Information about the Processing of Personal Data via Social Media Platforms Used by the Controller

Regarding the processing of personal data carried out by the administrators of the Social Media platforms used by the controller, reference is made to the information provided by them through their respective privacy policies. The controller processes the personal data provided by users through the pages of the Social Media platforms dedicated to the controller, within the scope of its commercial purposes, exclusively to manage interactions with users (comments, public posts, etc.) and in compliance with applicable regulations.

Data Recipients

The personal data collected is also processed by the personnel of the Data Controller (and therefore processors), who act on the basis of specific instructions provided regarding the purposes and methods of the same processing.

Processing Methods
The Data Controller will process the data in compliance with confidentiality guarantees and appropriate security measures provided by current regulations through computer tools with logic strictly related to the purposes of the processing.

Communication and Transfer of Personal Data
Personal data will be processed within the European Union and stored on servers located within the European Union. Under no circumstances will personal data be disclosed to third parties, except upon express request by the judicial authority.

Retention Period of Personal Data
The data will be processed for the duration of the browsing session and, at the end of the browsing session, anonymized and aggregated solely for statistical purposes.

Rights of Data Subjects
In relation to browsing data, pursuant to Articles 15-22 of the GDPR, the user has the right to:

  1. access and request a copy;
  2. request rectification;
  3. request erasure;
  4. obtain restriction of processing;
  5. object to processing;
  6. receive the data provided to the Controller in a structured, commonly used, and machine-readable format.

For exercising these rights, the user can contact the Controller at the contact details provided here.

The request will be responded to as soon as possible and, in any case, within the timeframes specified by the Regulation.

Right to Lodge a Complaint

Individuals who believe that the processing of their personal data carried out through this website violates the provisions of the Regulation have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), as provided for in Article 77 of the Regulation, or to take appropriate legal action (Article 79 of the Regulation).

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