Cookie Policy

Last update: July 2024

Dear Visitor (hereinafter, “You” or the “User”),

This website and all its subdomains ( https://ucv.online, hereinafter, “Site”) are owned by uCV Tech OÜ, with registered office in Tallinn (Estonia), Harju maakond, Kesklinna linnaosa, Tornimäe tn 3 // 5 // 7, 10145, registration number in the Business Register n. 16824430 (hereinafter, “We” or the “Company”).

Since our Site uses so-called cookies for various purposes, with this information we want to explain what cookies are and how they are used on the Site.

Some cookies (so-called own or first-party cookies) are conveyed and controlled directly by Us. Through these cookies, the Company collects and processes some personal data concerning you. In this information, pursuant to Article 13 of the EU Regulation 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data (hereinafter, “Regulation”) and the Legislative Decree 196/2003 (hereinafter, “Privacy Code” and, together with the Regulation, “Applicable Legislation”), we explain how we collect this data, for what purposes and what your rights are.

Unless otherwise specified, this information refers to European legislation and Italian law.

Other cookies (so-called third-party cookies), instead, are conveyed and controlled by third parties, as detailed below. In this information, you will find links to the information published by these third parties, which we ask you to read carefully.

If you are not familiar with cookies, we ask you to carefully read this information and the general privacy policy of the Site, so that you can be aware of your choices.

The Company holds the right to privacy and the protection of personal data of its Users in the highest regard. For any information related to this cookie policy, Users can contact the Company at any time, using the following methods:

  • Sending a registered letter to the legal headquarters of the Owner in Tallinn (Estonia), at Harju maakond, Kesklinna linnaosa, Tornimäe tn 3 // 5 // 7, 10145
  • Sending an email to the address: [email protected]

The Data Protection Officer (DPO) has not been identified, as the Owner is not subject to the designation obligation provided by Article 37 of the Regulation.

A. What are cookies and what are they used for

Cookies are small text files that websites visited by the user send directly to their device (usually to the browser), where they are stored to be later retransmitted to the same sites upon the next visit by the same user (so-called first-party cookies). While browsing a site, the user may receive on their device cookies from different sites or web servers (so-called third-party cookies); this happens because there might be elements such as, for example, images, maps, sounds, specific links to web pages of other domains that reside on servers other than the one on which the requested page is located. In other words, these are cookies that are set by a website other than the one currently being visited.

Cookies can have a duration limited to a single browsing session (so-called session cookies), and in such cases, they deactivate automatically when the user closes the browser; or they can have a predetermined expiration and, in that case, they will remain stored and active on your hard disk until that expiration date, continuing to collect information over multiple browsing sessions (so-called persistent cookies).

Cookies are used for different purposes. Some are necessary to enable you to navigate the Site and use its features (so-called technical cookies). Others are used to obtain statistical information, in aggregated or non-aggregated form, about the number of users accessing the Site and how the Site is used (so-called monitoring or analytics cookies). Others, finally, are used to track your consumer profile and display advertisements on the Site that may be of interest to you, as they align with your tastes and consumption habits (so-called profiling cookies).

To learn more about these different categories of cookies, continue reading this information. Discover how they work and what they are used for, and freely choose whether to consent to their use or prevent it.

B. Technical tools

B.1. Technical cookies

Technical cookies are used on the Site solely to enable your navigation on the Site and allow you to use its features. These are always first-party cookies, as they are directly conveyed by Us on the Site.

Some technical cookies are essential to provide you with an optimal browsing experience or to allow you to authenticate on the site, for example to make a purchase on the Site or access your reserved area (so-called navigation cookies). Navigation cookies are normally session cookies and, therefore, once you close the browser, they are automatically deactivated.

Other technical cookies are useful to allow you to save some of your preferences (e.g., language or country of origin) without having to reset them during subsequent visits (so-called functionality cookies). For this reason, functionality cookies are often persistent cookies, as they remain stored on your computer even after closing the browser, until their expiration date or until you decide to delete them.

The following technical cookies are currently used on the Site:

Cookie Name Cookie Category Cookie Function
_uCV_session - First-party technical cookie;
- Session cookie;
- Persistent (6 months).
Without this cookie, you cannot log in to the site and therefore cannot access your personal area.

B.2. Saving User Preferences

As required by applicable regulations, your prior consent is not required for the installation of technical cookies referred to in the previous paragraph B.1. Of course, you are free to block the installation of technical cookies by changing your browser settings (read paragraph E, no. 1 to find out how). However, note that blocking the installation of technical cookies or subsequently deleting them may compromise the ability to access the Site, use it in whole or in part, enable or disable certain functions, or receive certain services, in whole or in part.

Conversely, your prior consent is required for the installation of cookies and/or other tracking tools other than technical ones (such as profiling cookies). For this reason, when you access the Site, a specific banner (also called Consent Management Platform; hereinafter "CMP") is prominently displayed informing you that non-technical cookies are used on the Site with your prior consent and that you can consent to the use of the cookies by pressing the designated button provided there.

If you express your consent to the installation of cookies in this manner, we will keep track of your consent through a specific technical cookie or other technical methods related to the use of the CMP, allowing us to always keep the documentation of User choices up-to-date. In this case, the Company may process metadata related to the granular choices made by the User: possible expression of consent, detail of the granular purposes for which the User has given consent, as well as the User's possible choice to continue browsing while keeping the default settings by pressing the relevant button provided by the CMP.

In this way, we will avoid showing you the CMP on cookies during your subsequent visits to the Site and will keep track of your choices in accordance with applicable regulations.

Please note that if the Company uses a technical cookie or other methods to keep the documentation of User choices up-to-date to demonstrate the acquisition of your consent, and you delete this technical cookie or other tool used for this purpose from your browser as described in paragraph E, no. 1, your consent trace may be lost, and therefore, during your next visit to the Site, the CMP might be displayed again.

D. Profiling Cookies

Profiling cookies are used to create a user profile based on your preferences and tastes expressed while browsing the Internet, and to show you advertising messages consistent with your profile. This way, the advertising messages you see on our site may be more interesting for you.

At the moment, we do not use profiling cookies.

E. How to manage cookies and oppose their use

There are several options for managing, disabling, and deleting cookies.

E.1. Change your browser settings

Follow the instructions provided by the manufacturer of the browser you use to find out how to manage, disable, or delete all cookies:

Make your choices carefully. By indiscriminately blocking the receipt of all cookies, including technical ones, without making a specific exception for the Site, you may not be able to navigate the Site or use its functionalities in whole or in part. Furthermore, by deleting all cookies from the browser, technical cookies might also be removed, and therefore you may remove the preferences you have set while using the Site.

E.2. Use the interactive tools provided by third parties

To disable first-party profiling cookies, i.e., those installed directly by Us, you can simply use the interactive button(s) highlighted in paragraph D of this policy. Your choice to oppose the use of these cookies will not affect your ability to navigate the Site and use its functionalities, and you can revoke it at any time using the same interactive button.

To disable third-party cookies, refer to the informational pages of the third parties that install analytics cookies (see previous paragraph C) or profiling cookies (see previous paragraph D) to learn about the tools available to you to manage, disable, and delete cookies, and more generally, to oppose their use. Remember that by disabling third-party cookies, (i) you oppose their use not only on the Site but on all websites where such cookies are used, and (ii) your ability to navigate the Site and use its functionalities will not be compromised in any way.

E.3. Use the website www.YourOnlineChoices.eu

Your Online Choices is a website managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA), whose Italian version is accessible at www.youronlinechoices.eu/it/, which provides information on behavioral advertising based on profiling cookies (http://www.youronlinechoices.com/it/a-proposito) and allows Internet users to easily opt-out of the installation of major profiling cookies installed by advertising operators and used on websites (http://www.youronlinechoices.com/it/le-tue-scelte). Before using this tool, we recommend that you read the general terms of service of the Your Online Choices site (http://www.youronlinechoices.com/it/condizioni-generali-di-servizio), FAQs (http://www.youronlinechoices.com/it/faqs), and user guide (http://www.youronlinechoices.com/it/help).

Use Your Online Choices responsibly. Although Your Online Choices brings together many of the most important companies in the advertising world that use cookies, some of the third parties that install cookies through the Site may not have adhered to Your Online Choices. Therefore, using Your Online Choices does not guarantee that you will not receive third-party cookies while browsing the Site. Also remember, by deleting all cookies from your browser, even the technical cookies released by Your Online Choices to remember your choices could be deleted, making third-party cookies active again.

E.4. Use the CMP

For the processing of personal data that, with the User's consent, third-party companies may carry out through cookies, the User can also use the CMP implemented on the Site to provide or withdraw consent by following the related instructions.

F. Methods of processing and data retention periods

As stated in the premise of this policy, the Company may collect and process some of your personal data through cookies that it directly conveys on the Site or cookies conveyed by third parties acting on behalf of the Company based on an act of appointment as data controller pursuant to art. 28 of the Regulation (first-party cookies). The Company acts as the data controller of this data, in accordance with the provisions of applicable law. We will process your data only with electronic instruments, in a completely automated manner and without human intervention. Therefore, our employees will never access the content of your personal data obtained through cookies, meaning they will never be able to access and/or have PII (Personally Identifiable Information), i.e., information from which you can be identified directly.

Some of our employees and/or collaborators, appointed by us as data processors pursuant to art. 29 of the Regulation, may perform maintenance interventions on the IT systems hosting your data, without ever being able to access their actual content.

Personal data may be stored on servers managed by third parties (e.g., IT system providers) or may be managed by entities specializing in online advertising, acting as data processors pursuant to art. 28 of the Regulation, based on a specific written appointment by the Company.

Your personal data will not be communicated to third-party data controllers nor will it be disseminated.

Your personal data, collected by the Company through the technical cookies referred to in the previous paragraph B, will be retained for the time strictly necessary to fulfill the primary purposes illustrated in this policy, or in any case according to what is necessary for the protection of the rights and interests of both Users and the Company.

As for the duration of the cookies themselves, including third-party cookies, and the retention periods of the data collected by third parties, please refer to the tables included in this policy.

G. Transfer of personal data to a third country

We inform you that, in compliance with the conditions and guarantees established by the Regulation, your data may be transferred to countries outside the European Economic Area (EEA). These countries may not offer a level of privacy and data protection comparable to that guaranteed by the Applicable Law; where the Company acts as a data controller, we will take maximum consideration of data security and, therefore, will handle such transfers with all due caution and guarantees in accordance with the Applicable Law and, in particular, in accordance with Articles 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to appropriate safeguards) of the Regulation.

Specifically, for the provision of the Google Analytics service (referred to in the previous paragraph C), the Company's provider, Google Ireland Limited, may transfer the pseudonymized personal data of Site Users outside the EEA, based on so-called Standard Contractual Clauses and, in particular, to the United States, adopting additional measures to ensure that the transfer takes place in compliance with the Regulation itself. More information about the additional security measures applied by Google Ireland Limited for the transfer of personal data outside the European Union can be found within the following resources provided by the provider: "Regarding international data transfers in Google Analytics" (at the link: https://support.google.com/analytics/answer/11609059) and "Safeguards for international data transfers with Google's advertising and analytics products" (at the link: https://services.google.com/fh/files/misc/safeguards_for_international_data_transfers.pdf). Given the scope of processing, the nature of the processed data, and the risks associated with the processing performed by the provider, the Company has deemed the additional security measures that the provider ensures to adopt in order to protect the personal data processed on behalf of the Company to be adequate.

It is noted that some of the third parties indicated in the tables included in this policy and/or in the CMP may - as independent data controllers of the data collected through third-party cookies - process the personal data collected through the cookies installed on this Site from a location outside the European territory and, therefore, it is advisable to read their information policies above for more details on this.

H. Your rights

To exercise your rights or obtain any further information or clarification regarding this cookie policy, please contact the Company using the following methods:

  • Sending a registered letter with return receipt to the Data Controller's registered office in Tallinn (Estonia), at Harju maakond, Kesklinna linnaosa, Tornimäe tn 3 // 5 // 7, 10145;
  • Sending an email to: [email protected]

In accordance with the Applicable Law, Users have:

  1. The right to withdraw consent at any time, if the processing is based on their consent;
  2. The right of access to personal data;
  3. (where applicable) The right to data portability (right to receive all personal data concerning them in a structured, commonly used, and machine-readable format), the right to restriction of processing of personal data, the right to rectification, and the right to erasure ("right to be forgotten");
  4. The right to object:
  1. In whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
  2. In whole or in part, to the processing of personal data concerning them for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication;
  1. If they believe that the processing concerning them violates the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State where they usually reside, work, or where the alleged violation occurred). The Italian Supervisory Authority is the Garante per la protezione dei dati personali, located at Piazza Venezia, n. 11, 00186 - Rome (RM) (http://www.garanteprivacy.it/).

The Company is not responsible for updating all the links viewable in this cookie policy; therefore, whenever a link is not functional and/or updated, Users acknowledge and agree that they must always refer to the document and/or section of the websites referred to by such link.

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