The Policy has been drafted in accordance with Italian laws (Legislative Decree 196/2003 “Data Protection Code”) and the EU Directive 95/46/EC.
Customer/Client: THRON’s customer, a company that is using THRON service to manage content and its distribution.
User: end user accessing content through Customer’s sites and applications.
Device: software tool used to access content (includes but not limits to Internet Browser and mobile app).
The Data owner is the person who is responsible for taking decisions about which personal information is collected and how and why the personal information is used, the data processing methods used, and the security profile. The Data Coordinator is the person appointed by the Data owner to process the data.
THRON acts as data coordinator for its customers (that are data owners).
We do not collect personally identifiable information (“PII”) from users online through contents we manage on behalf of our clients unless users affirmatively and deliberately choose to release that information by submitting it through customer’s interfaces and applications, in a text field for example. PII generally refers to identifying information such as an individual’s name, mailing address, phone number or e-mail address.
We do collect non-personally identifiable information (“Non-PII”) to identify computers that we have interacted with before. For instance, by using Non-PII, we may be able to identify a computer that has previously seen a content we launched on behalf of a client. In the context of Non-PII, whenever we refer to ‘you’ or ‘yours‘, please remember that we may be referring to a computer and not an identifiable person since we generally do not know who is using a computer at any particular time (unless he willingly provides that information himself).
Through the collection and use of Non-PII, we offer a range of Services to allow customers to show you the most useful and relevant content across numerous websites and to prevent excessive or repeated deliveries of the same content.
When a User accesses THRON content, we automatically receive the URL (uniform resource locator) of the Site from which the User originated or visits when leaving the Site, the IP (internet protocol) address of the User’s computer (which will be masked to reduce its power of user identification), the type of operating system and browser, whether they are using a mobile device, details of the mobile device, the operating system and the name of the device’s ISP (internet service provider).
This data is only used to obtain anonymous statistical information on the use of the Site and to check that it is functioning correctly.
See Section titled: Allow THRON tracking.
The data gathered using cookies is processed electronically.
Even though most of the browsers currently being used automatically accept cookies, the User has the option to configure his/her browser to block the downloading of cookies at any time and also to delete already-downloaded cookies from their navigation device.
For an illustration of the procedure used to block any cookie for the main browsers, follow these links:
Nonetheless, blocking cookies can slow down your browsing or prevent you accessing certain sections of the site. Deleting cookies already received will result in the deletion of the favourites saved and managed by those cookies.
NV4ME-bacheca-[client-id]: First party. Used to store user preferences and optional “remember me” hashed login info. Duration: never expires.
NV4ME-bacheca-last-searched: First party. Optional list of recently searched contacts strings, used to improve search speed. Duration: never expires.
NV4ME-bacheca-tabs: First party. Lists all open dashboard tabs to manage desktop notifications. Duration: current session.
_TA_tracking: Third party, used to identify subsequent content views from same device. Duration: 1 year.
_TA_privacy: Third party, used to store user opt-out status. If value is 1, user will not be tracked. Duration: 1 year.
_sp_ses: session cookie. First party. It is used to identify different browsing sessions. Duration: 30 minutes.
_sp_id: user visits cookie. First party. Lasts 2 years. Stores last user visits timestamps, per domain.
sp: clojure collector cookie. Third party. It is used by the tracking library gather anonymous analytics data. Duration: 1 year.
_ga: Used to distinguish users. Duration: 2 years.
_gat: Used to throttle request rate. Duration: 10 minutes.
THRON cookies are designed to last 12 months. Collected PII and non-PII will be stored for the whole duration of THRON contract with its customers. THRON customer is data Owner and can decide data retention.
We follow generally accepted industry standards to protect against the unauthorized access to, retention of, and disclosure of information. This includes undertaking necessary physical, electronic, and management activities required to protect information integrity, access, and use. Any information that is stored on our server is treated as confidential information. Please keep in mind, however, that despite these reasonable efforts to protect information on our servers, no method of transmission over the Internet is guaranteed to be secure. Therefore, while we strive to protect your information at all times, we cannot guarantee its absolute security.
Further, we encourage our clients, as applicable, to use any Non-PII they receive in compliance with applicable laws and regulations and to publish privacy policies that tell you about how the information they are gathering is being used. We urge you to always read the Privacy Policies of the websites you visit to understand issues relating to your online privacy.
We may disclose a user’s Non-PII to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, but not limited to, fraud and situations involving potential threats to the physical safety of any person. In addition, and if permitted by applicable law, we may also disclose and provide access to a user’s PII and Non-PII to our vendors and contractors who are performing services on our behalf. However, such vendors and contractors are not permitted to use such user information for any purpose other than providing services to us.
The User’s Personal Information can be accessed by THRON’s technicians in relation to the provision of products or services through the Service. By way of example only, these parties may include personnel responsible for management and maintenance of the Service.
The Personal Information may be disclosed to public authorities where required by law.
The User’s Personal Information will not be circulated.
However, certain details such as the User’s nickname and/or image, and any other information published by the User on his/her profile or in other communications on the Service, will be accessible to other Users when the User chooses to participate in the blog or Community.
Some of the Personal Information supplied by the User may also be circulated during specific events (online competitions or promotions).
The User (“data subject”) may, at any time, exercise his or her rights under current legislation and in particular under Article 7 of Legislative Decree 196/2003 (“Italian Data Protection Act”). These include the right to obtain confirmation of the existence of personal information concerning the User, to amend the information, request its cancellation, know the purpose and method of processing, object to processing particularly for the purposes of the sending of advertising or direct selling materials, or for market research and promotional communications.