PRIVACY AND COOKIE POLICY

(pursuant to EU Regulation 2016/679 – GDPR and current national legislation)

1. Data controller

The Data Controller of the personal data processed through the site www.lamilano.it is:

La Milano – Lorenzo Chiaro Editor
Viale Monza 347, 20126 Milano (ME)
Certified email: ppgad@pucrs.br
Email: ppgad@pucrs.br
Telephone: +39 (02) 82196406

The Data Controller determines the purposes and means of processing the personal data of users who consult the site, access the published content, use any services available, and send communications to the addresses indicated.

2. Scope of the information

This information describes how the site is managed. www.lamilano.it with reference to the processing of personal data of users who consult it, navigate it, use its features and interact with the services present therein.

The site is a digital editorial publication and may offer journalistic content, news, articles, images, audio-video contributions, streaming services, multimedia content, links to other sites, contact tools, communication forms, newsletters, as well as other services related to the editorial, informational, and dissemination activities of the Data Controller.

The processing of personal data also applies to services used through Smart TV applications, connected devices, and digital platforms possibly linked to the site, through which audiovisual content and streaming services may be provided.

The technical methods of use on these devices may involve the processing of technical data necessary for the operation of the service, as described in this policy.

This policy applies to the site www.lamilano.it, to the related subdomains, as well as to the digital applications and platforms attributable to La Milano through which related content and services are provided.

This policy does not apply to third-party websites that may be accessed via links, references, embeds, or connections on the site.

3. Place of data processing

The processing operations related to the website's web services take place at the Data Controller's headquarters and/or at the technical infrastructures of third parties used by the Data Controller to provide services related to the website itself.

The data may be processed by external parties expressly authorized or appointed, where necessary, as data processors pursuant to Art. 28 of the GDPR, such as, for example, hosting providers, cloud services, email providers, technical maintenance services, content distribution services, streaming platforms, monitoring services, statistical services, technical consultants, or other suppliers strictly related to the management and operation of the site.

4. Types of data processed

4.1 Navigation 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, by way of example:

• the IP addresses or domain names of the devices used by users who connect to the site;
• the URI addresses of the requested resources;
• the time of the request;
• the method used in submitting the request to the server;
• the size of the file obtained in response;
• the numeric code indicating the status of the response provided by the server;
• other parameters relating to the user's operating system, browser, device and IT environment.

This information is not collected to be associated with identified data subjects, but by its nature could, through processing and association with data held by third parties, allow users to be identified.

This data is used for the sole purpose of:

• obtain aggregate or anonymous statistical information on the use of the site;
• check the correct functioning of the site and the services provided;
• ensure the security of the technological infrastructure;
• determine any liability in the event of computer crimes, unauthorized access, threats, attempted intrusions, illicit uses, or abuses to the detriment of the site, the Owner, or third parties.

4.2 Data provided voluntarily by the user

The optional, explicit, and voluntary sending of emails to the addresses indicated on the site, as well as the possible completion of contact forms, information request forms, communication forms, newsletter subscriptions, or other similar tools, entail the subsequent acquisition of the sender's address and any other personal data included in the communication.

These may include, by way of example:

• name and surname;
• email address;
• telephone number;
• message content;
• any attachments;
• any further data communicated spontaneously by the user.

The data thus provided is used solely for the purpose of following up on requests, responding to communications received, providing any requested services, managing informational, editorial, technical, or commercial relationships related to the site's activity, and for any legal obligations.

4.3 Data relating to streaming services and multimedia content

The site may offer audio-video content, live streaming, integrated players, multimedia services, web TV, real-time or on-demand video, including through third-party platforms, technologies, or infrastructures.

During the use of these services, technical and usage data may be processed, including, for example:

• IP address;
• device used;
• browser;
• operating system;
• access hours;
• connection quality data;
• reproduction events;
• technical data necessary for the correct functioning of the streaming.

This information is processed for the sole purpose of enabling the transmission of content, improving the stability of the service, monitoring its technical quality, preventing malfunctions, ensuring the security of the infrastructure, and protecting the rights of the Data Controller.

4.4 Data processed for statistical and analysis purposes

The site may use internal or third-party analysis tools to collect statistical information on the use of the pages, content, and services offered.

The data collected through these tools may concern, for example:

• number of visits;
• pages viewed;
• residence time;
• interactions with content and services;
• approximate geographical origin;
• device and browser used;
• how to consume content.

Where possible, such data is processed in aggregate or anonymized form.

4.5 Data related to advertising, promotional or sponsored content

The site may host banners, promotional content, advertising messages, sponsored content, informational or commercial campaigns, including those provided by third parties.

Viewing and interacting with such content may involve the processing of technical data or the use of cookies and similar tools, as indicated in this policy and in the Cookie Policy section.

5. Purpose of the treatment

Personal data collected through the site are processed for the following purposes:

a) allow navigation on the site and correct use of the published contents;
b) provide the services requested by the user;
c) allow the viewing of audio-video content, live streaming and multimedia content;
d) respond to requests for information, reports, communications or contacts sent by the user;
e) manage any subscriptions to newsletters or other information services requested;
f) fulfill obligations established by laws, regulations or community legislation;
g) protect the rights of the Owner, collaborators, readers, users and third parties;
h) guarantee the security of the site, IT infrastructure and related services;
i) prevent, detect and combat abuse, fraudulent activity, unlawful conduct, unauthorized access or unlawful use;
j) perform statistical analyses on the use of the site and improve the services offered;
k) manage any contractual, pre-contractual, administrative, technical, or organizational relationships connected to the site's editorial and informational activities.

6. Legal basis of the processing

The processing of personal data occurs when at least one of the following conditions of lawfulness is present:

• consent of the interested party, where required;
• execution of pre-contractual measures adopted at the request of the interested party;
• performance of a contract to which the interested party is a party;
• fulfillment of legal obligations to which the Data Controller is subject;
• Pursuit of the Data Controller's legitimate interest, within the limits permitted by applicable law, in particular for security purposes, site protection, abuse prevention, protection of the Data Controller's rights, and technical management of the service.

7. Nature of the data provision

With the exception of navigation data, the provision of personal data by the user is, in general, optional.

However, failure to provide any requested data may make it impossible to respond to requests, use certain services, receive requested communications, or access specific features of the site.

8. Method of treatment

Personal data is processed using electronic, computerized, and telematic tools, and, where necessary, also manually, in compliance with the principles of lawfulness, fairness, transparency, data minimization, accuracy, integrity, and confidentiality set forth in the GDPR.

Appropriate technical and organizational security measures are adopted to prevent data loss, illicit or incorrect use, unauthorized access, alteration, improper disclosure, or unauthorized processing.

9. Communication of data

Personal data may be disclosed, within the limits strictly relevant to the purposes indicated above, to:

• entities that provide services for the management of the IT system, the network, the website, the contents, streaming and communications;
• hosting, cloud, CDN, maintenance and technical support providers;
• platforms or providers of email services, newsletters, statistical analysis and technical monitoring;
• consultants, collaborators, professionals or individuals acting on behalf of the Data Controller for administrative, legal, fiscal, organizational or technical purposes;
• authorities, public bodies, law enforcement agencies, judicial authorities, or other authorized entities, in cases provided for by law or at their request.

Personal data are not subject to indiscriminate dissemination.

10. Transfer of data to non-EU countries

The site may use suppliers, platforms, or IT services that involve the transfer of data to countries located outside the European Economic Area.

In such cases, the transfer will take place in compliance with the conditions set forth in Articles 44 et seq. of the GDPR, through the adoption of appropriate safeguards required by applicable law, such as adequacy decisions, standard contractual clauses approved by the European Commission, or other suitable legal instruments.

11. Data retention period

Personal data is retained for the time strictly necessary to achieve the purposes for which it was collected and subsequently processed, except for any legal obligations or the need to protect the Data Controller's rights.

In particular:

• Browsing data is retained for the time technically necessary to manage the site and, where applicable, for security purposes and for the detection of illegal activities;
• Data voluntarily transmitted by the user for contact requests or communications is retained for the time necessary to process the request and, if applicable, for further administrative, organizational, or protection needs;
• data relating to subscriptions to newsletters or information services are retained until the consent is revoked or the interested party unsubscribes;
• data processed for legal obligations are retained for the terms established by applicable legislation;
• Data relevant to the protection of the Data Controller, site security, or the detection of illegal activities may be retained for the period necessary to manage the case, defend rights, or fulfill requests from the competent authorities.

12. Security, unlawful use of the site and communications to the competent authorities

The Data Controller adopts security measures aimed at protecting the site, connected systems, contents and processed data from unauthorized access, alteration, loss, destruction, improper use or illicit processing.

In case of unlawful use of the site or the contact details connected to it, including, but not limited to:

• sending threats;
• harassment;
• offensive, defamatory or threatening messages;
• transmitting fraudulent, deceptive, or unlawful content;
• attempts to unauthorized access, intrusion, damage or compromise systems;
• conduct likely to harm the Owner, its collaborators, readers, users or third parties,

The Owner reserves the right to use the available information, including the data contained in the communications received and the technical data connected to access and navigation, to protect its rights and to ascertain any responsibilities.

In such cases, the data and communications received may be retained, documented, and, where necessary or appropriate, transmitted to the competent authorities, law enforcement agencies, judicial authorities, or other authorized entities for the purposes of preventing, detecting, and suppressing illicit activities or crimes, as well as to protect the Data Controller in judicial or extrajudicial proceedings.

13. Links, references, embeds and external sites

The site may contain links, hyperlinks, banners, widgets, embeds, referrals, references, or links to external pages, platforms, or websites, including those of third parties.

These links may refer to content, pages, or services that are not owned by the Data Controller, that are not managed or controlled by him, and of which the Data Controller may not have direct, continuous, or updated knowledge.

The Owner does not exercise any control over these external sites and is not responsible for their content, availability, operating methods, services offered, terms of use, privacy policies, use of cookies or other tracking tools, or any processing of personal data by third parties through such sites or services.

Access to external sites that may be accessible through the site is under the sole responsibility of the user, who is invited to read the relevant information and applicable conditions.

14. Rights of the interested party

As a data subject, the user may exercise, in the cases provided for by the GDPR, the rights set forth in Articles 15 et seq. of the Regulation, including the right to:

• obtain confirmation as to whether or not personal data concerning him or her is being processed;
• access your personal data;
• request its rectification;
• request its cancellation;
• obtain treatment limitation;
• object to the treatment;
• receive the data in a structured, commonly used and machine-readable format, where applicable;
• withdraw consent at any time, without prejudice to the lawfulness of the processing based on the consent given before the withdrawal;
• lodge a complaint with the Italian Data Protection Authority.

Requests can be sent to the Data Controller's contact details indicated in this policy.

15. Changes to this Policy

This information may be updated, modified, or supplemented over time, including in light of regulatory changes, updates to the services offered, or technical developments of the site.

Users are encouraged to check this page periodically.

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COOKIES POLICY

16. What are cookies

Cookies are small text files that websites you visit send to your device, where they are stored before being re-sent to the same sites on your next visit.

Cookies improve the browsing experience, facilitate the use of online services, store preferences, perform authentication, collect statistical information, and, in some cases, offer content or promotional messages consistent with the user's expressed interests.

In this document, the term "cookie" is also used to indicate similar technologies, such as pixel tags, web beacons, identifiers, and other technical tools that allow us to collect information on the use of the site and its related services.

17. Types of cookies used by the site

17.1 Technical cookies

Technical cookies are those strictly necessary for the proper functioning of the site and the provision of the services requested by the user.

They allow, for example, to:

• navigate between the pages of the site;
• maintain a browsing session;
• store technical preferences;
• ensure the security of the site;
• allow the correct use of players, multimedia content or services requested by the user;
• manage any authentication tools or consent preferences.

The user's prior consent is not required for the use of these cookies.

17.2 Analytical or statistical cookies

The site may use analytical cookies or equivalent tools to collect statistical information, whether aggregated or not directly identifying, on users' use of the site.

These tools can be used, for example, to:

• understand the number of visitors;
• analyze the most visited pages;
• monitor dwell times;
• evaluate interaction with content;
• improve the structure, services and performance of the site;
• verify the functioning of informational, editorial or multimedia sections, including any streaming services.

If these cookies or tools are not fully anonymized or otherwise require consent under applicable law, they will be activated only with the user's prior consent.

17.3 Profiling cookies

The site may use, directly or indirectly through third parties, cookies or profiling tools to collect information on the user's browsing behavior, preferences, or interests in order to propose more relevant content, messages, or promotional communications.

These cookies are installed and used exclusively with the user's explicit consent, where required by applicable law.

17.4 Third-party cookies

The site may integrate services, content, or features provided by third parties, such as:

• video player;
• streaming services;
• maps;
• social widgets;
• analysis tools;
• advertising platforms;
• sharing services;
• embedded content;
• technical distribution or monitoring services.

These third parties may install cookies or other tracking tools on the user's device via the site. The data processing carried out by these third parties is governed by their respective privacy and cookie policies, to which reference is made.

The Data Controller does not fully control these third-party technologies nor the processing carried out independently by the relevant suppliers.

18. Purpose of the use of cookies

Cookies and similar tools can be used to:

• allow the site to function correctly;
• improve the user's browsing experience;
• store preferences and settings;
• collect statistical data on traffic and use of the site;
• ensure safety, stability and technical reliability;
• support the delivery of multimedia content and streaming services;
• measure the effectiveness of informational, editorial, promotional or advertising content;
• personalize content or messages, where permitted and with prior consent.

19. Consent management

Upon first accessing the site, the user may view a special banner or cookie consent management tool, through which they can:

• accept all cookies;
• reject unnecessary cookies;
• select or customize your preferences.

The preferences expressed by the user can subsequently be modified or updated according to the methods made available by the site, the cookie banner, or the tools made available by the browser or system used.

Simply continuing to browse does not, in itself, constitute valid consent to the installation of non-essential cookies, where such consent is required by applicable law.

20. How to disable or manage cookies via browser

The user can manage, limit, block, or delete cookies at any time through the settings of the browser used.

Disabling all or part of technical cookies may compromise the proper functioning of the site or limit the availability of certain services, sections, or content.

Cookie management methods vary depending on the browser used, and users are encouraged to consult their browser's documentation to learn about the relevant options.

21. Web beacons, pixels and similar technologies

The site, communications sent by the Data Controller, or any related services may use technologies similar to cookies, such as web beacons, pixel tags, or similar technical tools, for statistical, technical, security, interaction measurement, or verification purposes of content, newsletters, or information services.

Such tools, where they involve processing requiring consent, will be used in compliance with applicable legislation.

22. Relationships with external sites, contents and services

The presence on the site of embedded content, links, videos, players, banners, widgets, or other tools from third parties may involve interaction with external systems that may independently install cookies or similar tools.

The Data Controller is not responsible for the ways in which these third parties process the user's personal data, nor for the cookies they install, even if the user accesses them from the site.

23. Cookie Policy Updates

This Cookie Policy may be subject to changes, updates, or additions over time, including in relation to regulatory, technical, or organizational changes.

Users are encouraged to check this page periodically for the latest updated version.