Cookie Policy

COOKIE POLICY

Extended notice on the use of cookies and other tracking tools

FRESH TRADE ONLINE S.R.L.

Registered and operating office: Rome, Italy ([full address: _____]).

VAT number and Tax Code: [to be assigned: ].

Economic and Administrative Index (REA) No.: [].

Website: www.freshtrade.online. Privacy contact: privacy@freshtrade.online.

Last updated: 22 June 2026. Effective date: 22 June 2026.

1. Introduction and legal framework

By means of this notice, provided by FRESH TRADE ONLINE S.R.L. in its capacity as data controller, the types of cookies and tracking tools used on the website www.freshtrade.online and on the FreshTrade Platform are described, together with the purposes pursued, the legal bases, the retention periods, and the ways in which the user may express, manage, or withdraw their choices. The document supplements the Personal Data Processing Notice (Privacy Policy) and is to be read together with it. The processing of data collected through cookies is carried out in compliance with Article 122 of Legislative Decree No. 196 of 30 June 2003 (Personal Data Protection Code), with Directive 2002/58/EC (ePrivacy Directive), with Regulation (EU) 2016/679 (GDPR), and with the Guidelines on cookies and other tracking tools adopted by the Garante per la protezione dei dati personali on 10 June 2021 (provision No. 231), fully operational since 10 January 2022.

2. Definition of cookies and tracking tools

Cookies are small text strings that the websites visited send to the user’s terminal, where they are stored to be retransmitted to those same sites on subsequent visits. Alongside cookies, other tracking technologies operate, such as pixels, web beacons, and locally stored identifiers, which perform analogous functions. Depending on the party that installs them, a distinction is drawn between first-party cookies, managed directly by the website owner, and third-party cookies, managed by different parties operating for their own purposes. Depending on their purpose, tracking tools are divided into the categories illustrated in the following paragraphs.

3. Categories of cookies used

The website and the Platform employ the following categories of tracking tools:

•            Necessary technical cookies: they allow the website to function correctly and the services expressly requested by the user to be provided, managing, by way of example, authentication, the access session, security, load balancing, and the storage of cookie preferences. Such cookies do not require the data subject’s consent, pursuant to Article 122(1) of the Privacy Code, and their deactivation may impair the usability of the Platform.

•            Analytics cookies assimilated to technical ones: they collect aggregate information on the use of the website for the sole purpose of measuring its performance. Where configured with masking of the IP address, without cross-referencing with other processing operations or transmission to third parties, and with a reduced identification capacity, they are assimilated to technical cookies and do not require consent, in accordance with the indications of the Garante.

•            Third-party analytics cookies: they measure traffic and browsing behaviour through external providers that do not adopt the anonymisation measures described above. Their use presupposes the prior consent of the user.

•            Profiling and marketing cookies: they reconstruct the user’s profile and analyse their preferences in order to send personalised communications or to measure the effectiveness of promotional initiatives. The installation of such cookies is subject to the free, specific, and informed consent of the data subject, pursuant to Article 122(1) of the Privacy Code and Article 7 of the GDPR.

4. Legal basis of the processing

Technical cookies, and analytics cookies assimilated to them, are installed on the basis of the controller’s legitimate interest in ensuring the operation and security of the website, as well as in fulfilment of a request by the user. For third-party analytics, profiling, and marketing cookies, the legal basis is the consent of the data subject, expressed through the banner described in paragraph 6 below, and revocable at any time without prejudice to the lawfulness of the processing carried out prior to the withdrawal.

5. Duration of cookies and of consent

Cookies have a variable duration depending on their type. A distinction is drawn between session cookies, which are deleted upon closing the browser, and persistent cookies, which remain on the terminal until their preset expiry or until removal by the user. The specific duration of each cookie is indicated in the summary table in paragraph 9. In accordance with the Guidelines of the Garante, the choice expressed by the user regarding cookies is recorded and is not solicited again, unless the conditions of the processing change significantly, it proves impossible to know whether a cookie has already been stored on the terminal, or at least six months have elapsed since the previous collection. Once that period has elapsed, the banner will be presented again upon the subsequent visit.

6. Management of preferences through the banner

Upon first access to the website, the user is shown a banner which, without prejudicing browsing, signals the use of cookies and allows the user to express their choices. By means of the banner it is possible to grant consent to all tools through the acceptance command, to reject all non-necessary tools while keeping only the installation of technical cookies, or to access a granular settings panel to select the individual categories. Rejection is made as easy as acceptance, and the mere continuation of browsing, scrolling of the page, or closing of the banner does not amount to the giving of consent. The user may modify the choices made at any time by recalling the cookie management panel through the dedicated command made permanently available on the website.

7. Management of cookies through browser settings

In addition to the tools made available on the website, the user may manage, limit, or disable cookies by acting on the settings of their browser. Instructions for the main browsing programs are available at the following addresses:

•            Google Chrome: https://support.google.com/chrome/answer/95647.

•            Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies.

•            Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge.

•            Apple Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac.

It is noted that the complete disabling of cookies through the browser may impair the correct functioning of certain sections of the website and access to the reserved functionalities of the Platform.

8. Absence of a cookie wall

Access to the website’s content is not conditional upon the giving of consent to the installation of profiling cookies. Consistent with the indications of the Garante, which deem the cookie-wall mechanism unlawful, a user who rejects the non-necessary tracking tools retains the possibility of consulting the public informational content and of applying to the network.

9. Summary table of cookies

The following table summarises, for transparency purposes, the types of tracking tools employed. The analytical list of the individual cookies, including the technical names and the definitive expiry periods, is kept updated within the management panel available on the website and reflects the actual configuration of the Platform:

10. Third-party cookies and transfers outside the EU

Some tracking tools are managed by third parties acting as autonomous controllers or as data processors, according to their respective notices, to which reference is made for the specific processing methods and for the exercise of rights. Where such providers are established in or process data outside the European Economic Area, the related transfers take place in the presence of the appropriate safeguards described in the Privacy Policy, including the adequacy decision relating to the EU-US Data Privacy Framework and the Standard Contractual Clauses approved by Implementing Decision (EU) 2021/914.

11. Rights of the data subject and contacts

The user may exercise at any time the rights recognised by Articles 15 to 22 of the GDPR, including the right to withdraw consent and the right to object to processing, by writing to the address privacy@freshtrade.online or by contacting the Data Protection Officer at the address dpo@freshtrade.online. The right to lodge a complaint with the Garante per la protezione dei dati personali remains unaffected, pursuant to Article 77 of the GDPR, in accordance with the procedures indicated on the website www.garanteprivacy.it.

12. Amendments to the Cookie Policy

The present notice may be updated in order to adapt it to supervening regulatory, technical, or organisational needs, or as a consequence of changes in the tracking tools employed. Amendments are published on this page, the date of last update of which, shown in the heading, identifies the version in force. Periodic consultation of the document is recommended.