ORTHOFIX COOKIE POLICY

1. Introduction

This policy aims to explain how Orthofix Srl, in its quality of data controller (the “Controller” or the “Company”), collects and processes personal data through the cookies used on this website http://shoulder.galaxyfixation.com/ (the “Website”) and to provide information as to the choices that any user of the Website (the “User”) can make in terms of controlling what cookies are installed when he/she accesses and browses the Website.

Please note that this policy uses the term ‘cookies’ also to refer to similar technologies covered by the law (such as, for example, Local Shared Objects – commonly referred to as “flash cookies”, web beacons or bugs, including transparent clear gifs, etc.).

The information gathered by means of such tools constitute data that, in certain cases, may allow the Company to identify the Users by associating such data with other information kept by third parties (such as, for example, the IP address, DNS and registration numbers of the computers used by people connecting to the Website). These data are used and processed only for statistical purposes.

This document shall form, according to the applicable data protection legislation, including Regulation (EU) 2016/679 (the “GDPR”), an integral and substantial part of the Company’s http://shoulder.galaxyfixation.com/privacy-policy/. We strongly recommend, therefore, to read such document as well.

2. What is a cookie

A cookie is a small file, typically made up of letters and numbers, downloaded on to a device when the User accesses the Website. Cookies are then sent back to originating Website on each subsequent visit. Cookies are useful because they allow a website to recognize a User’s device.

The use of cookies and similar technologies has for some time been commonplace and cookies in particular are important in the provision of many online services. Using such technologies is not, therefore, prohibited by the law but they do require that people are properly informed about how they operate and the consequences deriving from their use, so to have the choice to refuse them, if feasible.

2.1. Different types of cookies

Session and persistent cookies

Cookies can expire at the end of a browsing session (from when a user opens the browser window to when he/she exits the browser) or they can be stored for longer.

Session cookies – allow the Websites to link the actions of a User during a browser session. They may be used for a variety of purposes such as remembering what a User has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session cookies expire after a browsing session.

The use of the so-called session cookies (that, in any case, are not stored persistently on the User’s computer and are deleted automatically as soon as the browser is shut down) is strictly limited to the purpose of transmitting data (made up of random numbers created by the server) identifying the specific session and necessary to allow a safe and efficient website surfing. The so-called session cookies used in this Website avoid any other computer methods that could potentially compromise the privacy about Users’ web-surfing.

Persistent cookies – are stored on a users’ device in between browsing sessions which allow the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site.

First and third-party cookies – Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user (the website displayed in the URL window), i.e. cookies set by http://shoulder.galaxyfixation.com. Third party cookies are cookies that are set by a domain other than the one being visited by the user: i.e. cookies which are set by web sites other than http://shoulder.galaxyfixation.com. If a user visits the Website and a separate company sets a cookie through it, this would be a third-party cookie.

3. Consent about cookies

Some cookies are strictly necessary for the correct functioning of Internet and the Website and do not require User’s consent, such as those ensuring that the content of a page loads quickly and effectively by distributing the workload across numerous computers or else those providing security.

Other cookies are still reasonably necessary or important but they are not strictly essential and, therefore, require User’s consent.

User’s consent is collected through different techniques implemented on this Website. One mechanism is the click of the specific box on the cookie banner highlighting the use of cookies and published on the landing page.

Your consent to the use of cookies can be withdrawn any time even though the withdrawal of consent might have impacts on the functionality of the Website.

4. Cookies used on this Website

When operating this Website, the Company uses cookies to offer services, to improve User’s experience, as well as to develop aggregated statistics on the data collected for various reasons.

These cookies allow the Company to distinguish each User from the others and therefore help us to provide you with a good experience when you browse our Website and to ensure its ongoing enhancement.

The cookies used by the Controller are “technical” and “analytical” cookies:

1. technical: necessary for navigation within the Website and in order to use certain functions (e.g. to navigate from one page to the other, etc).
2. analytics: for statistical analysis of site accesses. Information is collected on aggregate basis.

This website does not use cookies to target advertising.

A few cookies used are third party-cookies. The process of getting consent for these cookies is more complex, but the Controller is striving to provide the right information to Users to allow them to make informed choices about what is stored on their device. In more detail, following are the third party cookies used on the Website:

Who serves these cookies

What they do

Google Analytics

Analytics cookies are used to collect information in aggregate to help the Controller understand the number of users of the Website and how it is being used. These cookies allow the Company to have a better knowledge of our visitors and to improve the functioning of the Website.  More information can be found, also regarding the right to opt-out, at the following links: Terms of service (here); Privacy policy (here);

In case Users wish not to receive third-party cookies on their device, they may at any time, through this link: http://shoulder.galaxyfixation.com/privacy-policy/, access to granular information and consent forms of the third parties involved and exercise the right of opt-out.

5. Disabling and deleting Cookies

Most web browsers and devices are set to accept cookies by default. If the User prefers, he/she can usually choose to disable cookies by updating the browser or device settings to remove or reject cookies (e.g. cookies may be disabled by following the instructions provided by browser, which are usually located within the “Help,” “Preferences” or “Settings” menus). In case the User wishes to delete any cookies that are already on his/her device, reference should be made to the help, support, history or tools area on the Internet browser for instructions on how to do so. Current guidance is indicated below and is subject to change at the discretion of the web browser provider:

• Firefox:

1. Open Firefox;
2. Press the “Alt” key;
3. In the toolbar at the top of the browser, select “Tools” and then “Options”;
4. Then select the “Privacy” tab;
5. Go to “Timeline Settings” and then “Use custom settings”;
6. Uncheck “Accept cookies from sites” and save preferences.

• Internet Explorer:

1. Open Internet Explorer;
2. Click on “Tools” and then “Internet Options”;
3. Select the “Privacy” tab and move the slider to the privacy level you want to set (up to block all cookies or to the bottom to allow it all);
4. Then click on “Ok”.

• Google Chrome:

1. Open Google Chrome;
2. Click on the “Tools”;
3. Select “Settings” and then “Advanced Settings”;
4. Select “Content settings” under “Privacy”;
5. In the “Cookies” you can clear the cookies and save your preferences.

• Safari:

1. Open Safari;
2. Choose “Preferences” in the toolbar, then select the panel “Security” in the dialog box that follows;
3. In the “Accept Cookies” you can specify if and when Safari should save the cookies from websites. For more information click on the Help button (labeled with a question mark);

Please be aware that choosing to remove or reject cookies, or limiting the use of other similar technologies, could affect the access to the Website or its functionalities. To find out more about cookies, please see http://www.youronlinechoices.eu or www.allaboutcookies.org, both of which contain further information about cookies, how they work and the choices that can be made by the User.

6. Data retention

Personal data collected through the cookies will be kept in a format that allows User’s identification for no longer than 7 (seven) days, or in any case, within the time limits set forth by applicable laws and regulations, especially in connection with the need of checking computer crimes damaging the Website and/or to enforce or protect the Company’s rights (consistent with the retention periods and statutes of limitations provided for by the law), where necessary.

When no longer necessary in accordance with the above, the data will be cancelled or anonymized.

7. Circulation of data

No information gathered on the Website by means of cookies will ever be either communicated or disseminated to unspecified recipients.

8. Data subjects’ rights

The User can at any time exercise his/her rights, including:

1. a)accessing his/her personal data;
2. b)having incorrect personal data referred to him/her rectified without delay;
3. c)having his/her data erased in the cases provided for by the law;
4. d)obtaining restrictions to processing, where possible;
5. e)requesting portability of the data provided to the Controller, i.e. receiving them in a structured, commonly used and machine-readable format, also for transmitting such data to another controller, without any hindrance by the Company, in all situations where it is required by the law in force;
6. f)lodge a complaint to the competent Supervisory Authority.

To exercise these rights, or for any further information and/or clarifications about cookies installed on this Website, please write to privacy@orthofix.it

9. Data controller

The Data controller is Orthofix Srl, a company duly incorporated under the Italian law, with registered office at Via Vittor Pisani n. 16, Milano (Italy). The Company shall be liable only for its own cookies, i.e. first-party cookies, while third-party cookies shall fall under the controllership of those companies identified in the table above, as updated from time to time.

10. Policy updating

This cookie policy may be updated periodically, so the User is recommended to consult it each time he/she accesses the Website, in order to be properly informed about how and why the Company uses cookies.

Below is highlighted the date when the last version of this policy has been uploaded.

Last Update: May 25, 2018