Introduction

This Cookie Policy has been specifically drafted and customized for the website https://www.lotus-instruments.it/, owned by Lotus Instruments S.r.l., headquartered in Via F.lli Lumière, 37 – 48124 Fornace Zarattini (RA), Italy. Email: info@lotus-instruments.it.

This Policy is based on the Italian Data Protection Authority’s Provision No. 229 of 8 May 2014 (“Simplified arrangements to provide information and obtain consent regarding cookies”) and the new Provision No. 231 of 10 June 2021 (“Guidelines on cookies and other tracking tools”). It supplements and updates any other information already present on the website and/or previously provided by the company, together providing all the elements required by Article 13 of EU Regulation 2016/679.

Important Notice

Any third party is hereby informed that using this policy, or even parts of it, on other websites for which it would be incorrect and/or inconsistent, may result in significant penalties imposed by the Italian Data Protection Authority.

What Are Cookies

In practical terms, cookies are small tracking files stored on the user’s device by a website, used to remember browsing preferences and improve website performance and user experience.

From a technical standpoint, cookies are text strings (generally a combination of letters and numbers) that websites (so-called first parties) visited by the user, or other websites/web servers (so-called third parties), place and store directly and/or indirectly on the user’s device (PC, tablet, smartphone, etc.). The user’s browser or device can store these cookies and later retransmit them to the same sites during subsequent visits. Specifically, these tracking tools allow the website to recognize a particular device or browser.

Types of Cookies and Their Purposes

Cookies can be classified as follows:

• Technical cookies: used solely to transmit communications over an electronic communications network or to the extent strictly necessary to provide a service explicitly requested by the user (Art. 122(1) of the Italian Privacy Code). These cookies do not require user consent but must be disclosed in the cookie policy.
• Profiling cookies: used to associate specific actions or behavioral patterns with identified or identifiable subjects, to allow the controller to personalize services and deliver advertising messages aligned with the user’s browsing preferences.
• Analytics cookies: installed on the user’s device by the website owner or by third parties. Third-party analytics cookies, mainly from Google Analytics, are used for analysis purposes.

Google Analytics 4 (GA4) is a measurement and tracking tool used with an EU-based proxy server. It collects data from both the website and app to better understand user behavior, using event-based rather than session-based data. GA4 includes privacy controls such as cookie-less measurement and predictive modeling features. Direct integrations with media platforms help drive user actions on the site or app.

More information: https://support.google.com/analytics/answer/10089681?hl=en

Applicable Law

For technical cookies and other technical tracking tools, the controller is only required to provide this specific notice. For cookies or tracking tools used for non-technical purposes, consent must be obtained through a clear and affirmative action by the user, as per Recital 32 of the GDPR.

Consent Mechanism

The controller ensures that user consent is obtained through a banner displayed upon the user’s first visit to the site.

The banner includes:

• An “X” at the top right, which means the user does not consent.
• A short notice indicating that the site uses technical cookies and, with the user’s consent, profiling cookies.
• Links to the Privacy Policy and this Cookie Policy.
• A control button through which the user can provide consent.
• A link to a dedicated area where users can select and customize their cookie preferences by category or provider.

If the user does not consent to cookies or gives consent only for specific ones, this choice is saved and will not be requested again unless:

• One or more processing conditions change significantly.
• The site operator cannot verify whether a cookie is already stored.
• At least six months have passed since the banner was last displayed.

Legal Basis for Processing

For technical cookies, the legal basis is the controller’s legitimate interest under Article 6(f) GDPR, as they are necessary for the website’s operation. For non-technical cookies, the legal basis is the user’s explicit and revocable consent under Article 6(a) GDPR.

Cookies Used on This Site – Retention Periods – Purposes – Third-Party Data Transfers

Browser Settings

Users can configure their browser’s privacy settings at any time to control the installation and use of cookies. Most browsers also allow “private browsing,” which prevents storing site history, passwords, cookies, and other browsing data.

Note: disabling all cookies (including technical ones) may severely affect the quality and speed of website services and limit access to certain sections.

Data Subjects’ Rights

Data subjects have the following rights under GDPR:

• Right of access (Art. 15) – to confirm whether personal data are being processed and access related information.
• Right to rectification (Art. 16) – to correct inaccurate or incomplete personal data without undue delay.
• Right to erasure (“right to be forgotten,” Art. 17) – to have personal data deleted without undue delay.
• Right to restriction of processing (Art. 18) – to limit processing in specific cases (e.g., contesting data accuracy, pending verification, or for legal defense).
• Right to data portability (Art. 20) – to receive personal data in a structured, commonly used, machine-readable format and to transmit them to another controller.
• Right to object (Art. 21) – to object, at any time and for reasons related to one’s particular situation, to processing based on legitimate interest or profiling.

Requests should be addressed to the Data Controller:

Lotus Instruments S.r.l.
Via F.lli Lumière, 37 – 48124 Fornace Zarattini (RA), Italy
Email: info@lotus-instruments.it

Contact methods:
– By registered mail: Lotus Instruments S.r.l., Via F.lli Lumière, 37 – 48124 Fornace Zarattini (RA)
– By email: info@lotus-instruments.it

If you believe your personal data has been processed in violation of applicable data protection law, you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), Piazza Venezia 11 – 00187 Rome, Italy.