This policy aims to explain how Lynkeus, in its quality of data controller (‘Lynkeus’ or the ‘Controller’), collects and processes personal data through the cookies used on the website www.myhealthmydata.eu (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 Controller 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.
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.
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 Users have put in their shopping basket. They could also be used for security purposes such as when a User is accessing internet banking or to facilitate use of webmail. This type of cookies expires after a browsing session.
The use of 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 identifying the specific session and necessary to allow a safe and efficient Website surfing.
Persistent cookies – are stored on a Users’ device in between browsing sessions which allow the preferences or actions of the User across a website (or in some cases across different websites) to be remembered.
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 are, in basic terms, cookies set by a website visited by the User (the website displayed in the URL window), i.e. cookies set by www.myhealthmydata.eu. 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 websites other than www.myhealthmydata.eu. If a User visits the Website and a separate company sets a cookie through it, then 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, such as the click by the User of the specific box on the cookie banner published on the landing page, or continuing the navigation clicking anywhere outside the cookie banner.
4. Cookies that we use
These cookies allow Lynkeus to provide the User with a good experience when browsing the Website and to ensure its ongoing enhancement.
The cookies used by the Controller are ‘technical’ and ‘analytical’ cookies:
- 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).
- analytics: for statistical analysis of Website accesses. Information is collected on aggregate basis.
- social cookies: used to consent the interaction between the Website and social network platforms.
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 the Users to allow them to make informed choices about what is stored on their device.
In case Users wish not to receive third-party cookies on their device, they may at any time, as described below, 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.
Choosing to remove or reject cookies, or limiting the use of other similar technologies, could affect the access to the Website and 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 and preventing computer crimes and/or to enforce or defend the Controller’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:
- accessing his/her personal data;
- having incorrect personal data referred to him/her rectified without delay;
- having his/her data erased in the cases provided for by the law;
- obtaining restrictions to processing, where possible;
- requesting portability of the data provided to the Controller in the cases provided for by applicable law;
- lodging a complaint to the competent Supervisory Authority (please, find here the list of the Data Protection Authorities in Europe).
To exercise these rights, or for any further information and/or clarifications about cookies installed on this Website, please write to firstname.lastname@example.org.
9. Data controller
The Data controller is Lynkeus, with registered offices in via Livenza n. 6, Rome (00198).
10. Policy updating
Below is highlighted the date when the last version of this policy has been uploaded.
Last Update: 19/06/2019