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beMail › Legal › Cookie policy

Cookie policy

(version no. 3 of 27 February 2025)

Dear Visitor (“you” or the “User”),

this website (the “Site”) is owned by Ketchup Adv S.p.A., with registered office at Piazza Borromeo 14, 20123 Milan (Italy), VAT and tax code 09211640967, registered with the Milan Companies Register under number MI-2076027 (“we” or the “Company”).

Because our Site uses cookies for various purposes, in addition to giving you the details of the cookies used (in the tables on this page), with this extended notice (the “Cookie Policy”) we want to explain what cookies are and how they are used on the Site.

Some of the cookies listed in the tables (first-party cookies) are served and controlled directly by us. Through these cookies, the Company collects and processes some personal data about you. In this Cookie Policy, pursuant to Article 13 of EU Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (the “Regulation”) and Legislative Decree 196/2003 (the “Privacy Code” and, together with the Regulation, the “Applicable Law”), we explain how we collect these data, for what purposes and what your rights are.

Other cookies (third-party cookies) are served and controlled by third parties. In the consent management platform (Consent Management Platform, the “CMP”) implemented on the Site, as well as in the tables on this page before this Cookie Policy, you will find links to the notices published by these third parties, which we ask you to read carefully.

The Company gives the utmost consideration to its Users’ right to privacy and to the protection of their personal data. For any information about this Cookie Policy, Users may contact the Company at any time:

  • By sending a registered letter with return receipt to the Company’s registered office (Piazza Borromeo 14, 20123, Milan, Italy); by sending an email to: richieste@ketchupadv.com.

You can also contact the Company’s Data Protection Officer (DPO) at: lapo.curinigalletti@ketchupadv.com.

A. What cookies are and what they are for

Cookies are small text files that the sites a user visits send directly to the user’s device (usually to the browser), where they are stored and then sent back to the same sites on the user’s next visit (first-party cookies). While browsing a site, the user may also receive cookies from other sites or web servers (third-party cookies); this happens because the website visited may contain elements such as images, maps, sounds or links to pages on other domains hosted on servers other than the one hosting the requested page. In other words, these are cookies set by a website other than the one you are currently visiting.

Cookies may last only for a single browsing session (session cookies), in which case they are automatically deactivated when the user closes the browser; or they may have a set expiry date, in which case they remain stored and active on your hard drive until that date, continuing to collect information across different browsing sessions (persistent cookies).

Cookies serve different functions. Some are needed to let you browse the Site and use its features (technical cookies). Others are used to obtain statistical information, aggregated or not, on the number of users accessing the Site and how the Site is used (monitoring or analytics cookies). Others are used to build your consumer profile and show you advertising on the Site that may interest you because it matches your tastes and consumption habits (profiling cookies).

To learn more about these categories of cookies, keep reading this Cookie Policy. Find out how they work and what they are for, and choose freely whether to accept or prevent their use.

B. Technical tools – necessary

B.1. Technical cookies – necessary

Technical cookies are used on the Site solely to make browsing possible and to let you use its features securely: in the tables on the Site they are listed as “Necessary”.

Some technical cookies are essential to give you the best browsing experience or to let you log in, for example to make a purchase on the Site or access your reserved area (browsing cookies). Browsing cookies are normally session cookies and are therefore automatically deactivated once you close the browser.

Other technical cookies let you save some of your preferences (for example, language or country) without having to set them again on later visits (functionality cookies). For this reason, functionality cookies are often persistent cookies, as they remain stored on your computer even after the browser is closed, until their expiry date or until you decide to delete them.

The Site currently uses the technical cookies listed in the “Necessary” table above.

In particular, we may use the “Google reCAPTCHA” service on some pages of the Site, which installs tracking tools to protect against spam and fraudulent behaviour: this service is provided by Google, which will process User data to provide, maintain and improve reCAPTCHA and for spam protection purposes. The data will not be used by Google for personalized advertising. User data are subject to the Google Privacy Policy and Google’s Terms of Service.

B.2. Saving the User’s preferences

As provided by Applicable Law, your prior consent is not required to install the technical cookies described in section B.1. Of course, you are free to block technical cookies by changing your browser settings (see section E, no. 1 for how). Please note, however, that blocking technical cookies, or deleting them later, may fully or partly compromise your ability to access the Site, use all or part of it, enable or disable certain features or receive certain services.

Conversely, your prior consent is required to install cookies and/or other tracking tools other than technical ones (such as profiling cookies). For this reason, when you access the Site the CMP is prominently displayed, informing you that, subject to your consent, the Site uses non-technical cookies and that you can accept them by pressing the relevant button.

If you consent to cookies in this way, we will keep track of your consent through a dedicated technical cookie or other technical means linked to the CMP that keep the record of the User’s choices up to date. In the latter case, the Company may process metadata about the User’s granular choices for this purpose: whether consent was given, the specific purposes for which the User gave consent, and any choice to continue browsing with the default settings by pressing the relevant CMP button.

This way, we will avoid showing you the cookie CMP on your later visits to the Site and will keep track of your choices as required by Applicable Law.

The tools used by the Company to demonstrate that your consent was obtained are those provided by Usercentrics A/S (Cookiebot), listed as “Necessary” in the tables on the Site. Please note that if the Company uses a technical cookie or other means to keep the record of the User’s choices up to date, and you delete that technical cookie or other tool from your browser as described in section E, no. 1, the record of your consent may be lost and the CMP may therefore be shown again on your next visit to the Site.

C. Analytics cookies – statistics

Analytics cookies are used on the Site to collect statistical information, aggregated or not, on the number of users accessing the Site and how they visit it: in the tables on the Site they are listed as “Statistics”.

Some of these cookies are installed directly by the Company or are tools through which the Company collects data as data controller (e.g. Google Analytics).

Analytics cookies are installed on the Site only with your prior consent, collected through the CMP. Of course, you are free not to consent to analytics cookies and to object to their use at any time, without this affecting in any way your ability to visit the Site and use its content.

The Site currently uses the analytics cookies listed in the “Statistics” table above. You are free not to consent to analytics cookies and to object to their use at any time, without this affecting in any way your ability to visit the Site and use its content. To find out how, read the cookie notices carefully by following the links in the “Statistics” table.

D. Profiling cookies – marketing

Profiling cookies are used to build a user profile based on the preferences and tastes you show while browsing the Internet, and to show you advertising consistent with your profile. This way, the ads you see on our Site may be more interesting to you. In the tables on the Site they are listed as “Marketing”.

Of course, you are free not to consent to profiling cookies and to object to their use at any time, without this affecting in any way your ability to visit the Site and use its content. Turning off behavioural advertising does not mean you will no longer see ads on the Site. However, the banners you see may not reflect your interests or preferences in the browser you are currently using.

Some profiling cookies are installed directly by the Company or are tools through which the Company collects data as data controller or, in some cases, as joint controller with the cookie provider (as specified by the provider in the privacy notice linked in the “Marketing” table). Other profiling cookies on the Site are installed by third parties (third-party cookies: the “Marketing” table links to the notices written by their developers, which also explain how to refuse them, known as opt-out, and their retention periods).

The Site currently uses the profiling cookies listed in the “Marketing” table above.

E. How to manage cookies and object to their use

There are several ways to manage, disable and delete cookies.

  • Change your browser settings

Follow the instructions of your browser’s maker to learn how to manage, disable or delete all cookies:

Choose carefully. If you block all cookies indiscriminately, including technical ones, without making a specific exception for the Site, you may no longer be able to browse the Site or use all or part of its features. Also, by deleting all cookies from your browser, technical cookies may be removed too, and with them the preferences you set while using the Site.

2) Use the interactive tools in the notices listed in the tables

To disable analytics and profiling cookies, you can consult the notices of the third parties that install cookies (see the “Statistics” and “Marketing” tables) to learn about the tools available to manage, disable and delete cookies and, more generally, to object to their use. Remember that by disabling third-party cookies (i) you object to their use not only on the Site but on all websites where those cookies are used, and (ii) your ability to browse the Site and use its features will not be affected in any way.

3) Use the Your Online Choices website

Your Online Choices is a website run by the non-profit European Interactive Digital Advertising Alliance (EDAA), available at this address, which provides information about behavioural advertising based on profiling cookies and lets Internet users easily object (opt out) to the main profiling cookies installed by advertisers and used on websites. Before using this tool, we recommend you read the Your Online Choices terms of service, FAQ and user guide.

Use Your Online Choices with care. Although it brings together many of the most important advertising companies that use cookies, some of the third parties that install cookies through the Site may not have joined Your Online Choices. Using it therefore does not guarantee that you will not receive third-party cookies while browsing the Site. Also remember that by deleting all cookies from your browser, the technical cookies set by Your Online Choices to remember your choices may be deleted too, re-enabling third-party cookies.

4) Use the CMP

Users can also use the CMP implemented on the Site to give or withdraw consent by following its instructions.

F. Processing methods and data retention

As noted at the beginning of this Cookie Policy, the Company may collect and process some of your personal data through cookies it serves directly on the Site or cookies served by third parties acting on the Company’s behalf under an appointment as data processor pursuant to Article 28 of the Regulation (first-party cookies). These include, for example, cookies stored on your device after you make a choice in the CMP, which are needed to save your preferences.

The Company acts as data controller for these data, in accordance with Applicable Law. We will process your data only electronically, in a fully automated way and without human intervention. Our staff will therefore never access the content of your personal data obtained through cookies, which means they will never be able to access and/or hold PII (Personally Identifiable Information), i.e. information that could directly identify you.

Some of our employees and/or contractors, authorized by us to process data pursuant to Article 29 of the Regulation, may carry out maintenance 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 handled by online advertising specialists acting as data processors pursuant to Article 28 of the Regulation, under a specific written appointment by the Company.

Your personal data will not be disclosed to third-party controllers or disseminated.

Your personal data collected by the Company through the technical cookies described in section B will be kept for as long as strictly necessary to fulfil the primary purposes described in this Cookie Policy or, in any case, as necessary to protect the rights and interests of both the Users and the Company.

For the duration of the cookies themselves, including third-party cookies, and the retention periods of data collected by third parties, please refer to the tables before this Cookie Policy.

G. Transfers of personal data to a third country

Subject to the conditions and safeguards laid down in 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 Applicable Law; where the Company acts as data controller, we will give the utmost consideration to data security and will therefore handle such transfers with all due care and safeguards in accordance with Applicable Law and, in particular, with Articles 45 (Transfers on the basis of an adequacy decision) and 46 (Transfers subject to appropriate safeguards) of the Regulation.

To provide Google Analytics services, the Company’s provider, Google Ireland Limited, acting on the Company’s behalf as data processor under Article 28 of the Regulation, may transfer pseudonymized personal data of Site users outside the EEA on the basis of (i) the Standard Contractual Clauses or (ii) an adequacy decision. For case (ii), in particular to the United States, data will be transferred on the basis of the Data Privacy Framework certification adopted by Google LLC (more information at this link). For case (i), considering the scope of processing, the nature of the data and the risks of the processing carried out by the provider, the Company has deemed adequate the security measures the provider guarantees to adopt to protect personal data.

Please note that some of the third parties listed in the tables above and in the CMP may, as independent controllers of the data collected through third-party cookies, process personal data collected through cookies installed on this Site from locations outside Europe; we therefore recommend you read their notices above carefully for more details.

H. Your rights

To exercise your rights, or to obtain any further information or clarification about this Cookie Policy, please contact the Company:

  • By sending a registered letter with return receipt to the Company’s registered office (Piazza Borromeo 14, 20123, Milan, Italy);
  • By sending an email to: richieste@ketchupadv.com.

You can also contact the Company’s Data Protection Officer (DPO) at: lapo.curinigalletti@ketchupadv.com.

Under Applicable Law, Users have:

  • the right to withdraw consent at any time, where processing is based on consent;
  • the right of access to personal data;
  • (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and machine-readable format), the right to restriction of processing, the right to rectification and the right to erasure (“right to be forgotten”);
  • the right to object:

d1. in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if relevant to the purpose of collection;

d2. in whole or in part, to the processing of personal data concerning them for sending advertising material, direct sales, market research or commercial communications;

  • if they believe that the processing concerning them infringes the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State where they habitually reside, where they work or where the alleged infringement took place). The Italian supervisory authority is the Garante per la protezione dei dati personali, Piazza Venezia 11, 00186 – Rome (http://www.garanteprivacy.it/).

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The Company is not responsible for keeping all the links in this Cookie Policy up to date; whenever a link is broken and/or out of date, Users acknowledge and accept that they must refer to the document and/or section of the website referenced by that link.

This English version is a translation provided for convenience. In case of discrepancy, the Italian version prevails.