Cookies Policy &
Consent Management Framework

1. Scope and Applicability

This Cookies Policy applies to cookies and similar technologies used through VISAC Technologies websites, digital platforms and online services.

It applies to individuals who access or interact with VISAC digital properties.

This framework explains:

• what cookies are;
• how VISAC uses cookies and similar technologies;
• the purposes for which cookies may be used;
• how users can manage their preferences.

2. Regulatory Framework

VISAC manages cookies and similar technologies according to:

• Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR);
• applicable national data protection legislation;
• Directive 2002/58/EC concerning privacy and electronic communications (ePrivacy Directive), where applicable;
• Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018;
• applicable guidance issued by competent data protection authorities.

VISAC periodically reviews its cookie management practices considering evolving legal, technological and operational requirements.

3. Cookie Governance Principles

VISAC applies the following governance principles when managing cookies and similar technologies.

3.1 Transparency

VISAC provides clear information regarding:

• the use of cookies;
• their purpose;
• their category;
• applicable consent requirements.

Users receive information designed to support informed choices regarding their digital experience.

3.2 User Choice

VISAC respects user preferences regarding non-essential cookies.

Where required by applicable law, cookies that are not strictly necessary for website operation are activated only following valid user consent.

Users may:

• accept cookies;
• reject non-essential cookies;
• manage individual preferences;
• withdraw previously provided consent.

3.3 Privacy by Design

Cookie management mechanisms are designed according to VISAC data governance principles, including:

• data minimisation;
• purpose limitation;
• security-by-design;
• responsible technology practices.

4. What Are Cookies?

Cookies are small text files stored on a user's device when visiting a website.

Cookies allow websites to:

• operate correctly;
• remember user preferences;
• improve functionality;
• analyse performance;
• support security mechanisms.

Cookies may be:

First-Party Cookies

Cookies created and managed directly by VISAC Technologies.

Third-Party Cookies

Cookies created by external providers that may support specific functionalities, analytics or services.

Session Cookies

Cookies temporarily stored during a browsing session and generally deleted when the browser is closed.

Persistent Cookies

Cookies that remain stored on a device for a defined period or until manually deleted.

5. Categories of Cookies

VISAC may use the following categories of cookies, depending on the functionality and configuration of the relevant digital service.

6. Cookies Used by VISAC

VISAC applies a principle of transparency regarding cookies deployed on its digital properties.

The specific cookies used may vary depending on website functionality, technological configuration and enabled services.

A cookie inventory may include:

VISAC updates cookie inventories when technological configurations change.

No analytics or marketing cookies are activated before obtaining the required user consent.

7. Third-Party Technologies

VISAC may use third-party technologies that place cookies or similar identifiers on user devices.

Examples may include:

• analytics providers;
• embedded content providers;
• professional communication platforms;
• technology service providers.

Third-party providers may process information according to their own privacy policies and applicable contractual arrangements.

VISAC evaluates third-party technologies according to security, privacy and governance principles.

Where a third-party technology requires consent under applicable law, VISAC will seek the relevant consent before activating the associated technology.

8. Consent Management Framework

VISAC uses consent management mechanisms designed to provide users with meaningful control over cookie preferences.

The VISAC Consent Management Layer distinguishes between technically necessary cookies and optional cookies requiring user preference selection.

Where required, users are provided with options to:

• accept all cookies;
• reject non-essential cookies;
• manage cookie preferences by category.

Consent mechanisms are designed according to principles of:

• transparency;
• informed choice;
• user control;
• accountability.

Consent Records

Where consent is required, VISAC may maintain information necessary to demonstrate that consent was obtained in accordance with applicable requirements.

Consent records may include information such as the date and time of the consent action, the relevant preference configuration and technical information necessary to associate the preference with the applicable consent mechanism.

VISAC seeks to ensure that consent mechanisms remain accessible, understandable and capable of being withdrawn without undue difficulty.

9. Withdrawal and Modification of Preferences

Users may change or withdraw cookie preferences at any time.

Where available, preference settings can be modified through the cookie management interface provided on the website.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Where technically applicable, withdrawal of consent will prevent or discontinue the activation of the relevant non-essential cookies or technologies.

Strictly necessary cookies required for the operation, security or basic functionality of the website may continue to operate where permitted by applicable law.

10. Browser Controls

Users may also manage cookies through browser settings.

Most browsers allow users to:

• view stored cookies;
• delete existing cookies;
• block future cookies;
• receive notifications before cookies are stored.

Users should refer to their browser provider documentation for specific instructions.

11. Security and Data Protection

Cookie-related information is managed according to VISAC security governance principles.

VISAC applies appropriate technical and organisational measures designed to protect information against:

• unauthorised access;
• misuse;
• alteration;
• loss;
• unauthorised disclosure.

Cookie management is considered part of VISAC's broader approach to responsible digital governance.

12. Relationship with Privacy Policy

This Cookies Policy should be read together with the:

VISAC Privacy Policy & Data Protection Framework

The Privacy Policy provides broader information regarding:

• personal data processing;
• security governance;
• data lifecycle management;
• international data transfers;
• individual rights and accountability.

Where cookies or similar technologies involve the processing of personal data, the relevant processing is also governed by the principles and safeguards described in the Privacy Policy.

13. Updates to this Framework

VISAC may update this Cookies Policy and Consent Management Framework to reflect:

• regulatory developments;
• technological changes;
• changes to digital services;
• changes to third-party technologies;
• improvements in governance practices.

Material changes may be highlighted through appropriate notices where required by applicable law.

The updated version will be published on this page together with the corresponding revision date.

VISAC encourages users to periodically review this framework to remain informed about how cookies and similar technologies are governed.

14. Contact Information

VISAC welcomes privacy-related enquiries, requests and concerns.

Individuals may contact the Data Controller using the following information:

Document Status