Cookie Policy

Introduction

This Cookie Policy aims to provide clear and transparent information about what cookies are, how they are generally used by websites and, most importantly, to explicitly declare the policy adopted by Pulsar Real Estate SRL on its institutional website www.pulsar-re.it.

What are cookies

Cookies are small text files that websites visited by users send to their devices (computers, smartphones, tablets), where they are stored and then retransmitted to the same websites on subsequent visits. Cookies are used for various purposes: performing computer authentication, monitoring sessions, storing information about specific configurations regarding users accessing the server, storing preferences, collecting statistical data, and carrying out advertising profiling activities.

In addition to cookies proper, there are similar technologies that allow information to be collected about the user's device or browsing: these include web beacons, tracking pixels, local shared objects, technical fingerprinting and data stored in localStorage or sessionStorage. All these technologies, when used for purposes not strictly necessary for the functioning of the service requested by the user, are subject to the same regulations as cookies.

Classification of cookies

Cookies are distinguished according to different criteria.

By duration

• Session cookies: automatically deleted when the browser is closed
• Persistent cookies: remain stored on the user's device for a predetermined period of time

By origin

• First-party cookies: installed directly by the website the user is visiting
• Third-party cookies: installed by entities other than the operator of the website visited, typically providers of analytics, advertising or integrated functionality services (social plugins, video embeds, maps, external fonts, etc.)

By purpose

• Technical cookies: essential for the website to function or necessary to provide a service explicitly requested by the user (e.g. authentication cookies, shopping cart cookies, load balancing cookies)
• Analytical cookies: used to collect information, in aggregate or individual form, about the number of users and how they visit the website
• Profiling cookies: aimed at creating user profiles and used to send advertising messages in line with the preferences expressed by the user during web browsing

Regulatory framework

The use of cookies is regulated at European and national level by a layered set of rules that protect the privacy and personal data of users.

• Directive 2002/58/EC (the "ePrivacy" Directive), as amended by Directive 2009/136/EC, establishes in Article 5(3) that the storage of information or access to information already stored on the user's device is permitted only on condition that the user has given consent after being provided with clear and comprehensive information about the purposes of the processing. An exception is made for cookies strictly necessary to provide a service explicitly requested by the user.
• Regulation (EU) 2016/679 (GDPR) governs the processing of personal data in general, defining principles of lawfulness, fairness, transparency, data minimisation and purpose limitation. Where cookies involve the processing of personal data — a frequent occurrence — the information obligations under Articles 13 and 14 also apply, as does the principle of free, specific, informed and unambiguous consent under Article 7.
• Legislative Decree 196/2003 (Privacy Code), as amended by Legislative Decree 101/2018, transposes European provisions at national level.

Guidelines of the Italian Data Protection Authority

Guidelines of the Italian Data Protection Authority (Garante) of 10 June 2021 (Provision no. 231/2021) provide updated operational guidance on the use of cookies and other tracking tools, establishing that:

• consent must be expressed actively and cannot derive from simply scrolling the page
• the user must be able to accept, refuse or select individual categories of cookies with equal ease
• the repeated re-presentation of the banner to users who have already expressed a refusal constitutes an unlawful practice
• technical cookies do not require consent but must still be the subject of information
• profiling cookies and analytical cookies not comparable to technical ones always require prior consent

Guidelines of the European Data Protection Board (EDPB), in particular Guidelines 05/2020 on consent under Regulation 2016/679, complement the framework by providing harmonised criteria at European level.

Pulsar Real Estate SRL policy

Having stated the above, Pulsar Real Estate SRL has deliberately chosen to build its institutional website adopting a privacy by design approach and is pleased to declare the following:

The website www.pulsar-re.it does NOT use cookies of any kind

Specifically, the website:

• Does not install its own technical cookies beyond those strictly necessary for page loading, as it is a static website that does not require user sessions, authentication or personalisation
• Does not use analytical cookies, either first-party or third-party. No Google Analytics, Matomo, Plausible with cookies, or any other measurement tool that involves storing information on the user's device is installed
• Does not use profiling or marketing cookies of any kind
• Does not integrate third-party services that deposit cookies, such as advertising tracking pixels, social plugins with tracking, remarketing tools or A/B testing systems
• Does not load external resources subject to tracking: the fonts used on the website are hosted locally on the server, as are images and graphic assets. No calls are made to Google Fonts, third-party CDNs or other external services that could track the user's IP address
• Does not integrate embedded videos or content that would result in the installation of cookies by YouTube, Vimeo, Facebook, Instagram or similar platforms
• Does not use interactive Google Maps or similar services that deposit cookies; any references to our offices are provided as text, static images or external links opening in a new tab
• Does not use chat or customer support systems that install cookies or trackers on the user's device

Contact form protection without cookies

The contact form on the website is protected by anti-spam techniques that do not require cookies or tracking. Specifically, client-side and server-side validation techniques based on hidden fields (honeypot) and time-based controls (time-trap) are used, which do not involve any collection or storage of information on the user's device nor any identification of the user.

Hosting and content delivery network

The website is served through a content delivery network (CDN) configured in cookie-free mode. No analytics services from the hosting platform are used, nor bot detection tools that involve depositing cookies on the user's device.

Consequences for the user

As a result of the above, when browsing www.pulsar-re.it the user:

• Does not need to give any consent to the use of cookies, as no cookies are installed
• Is not tracked in their browsing either within the website or outside of it
• Is not subject to profiling of any kind
• Does not need to configure any preference in their browser to block third-party cookies, as none are proposed
• Can browse anonymously without any personal data being collected through tracking technologies

The only time the user's personal data is processed is when they voluntarily choose to fill in and submit the contact form on the website. For information on this processing, please refer to the Privacy Policy.

Voluntary disclosure

It should be noted that, although the website does not use cookies and is therefore not technically required to display an informative banner, Pulsar Real Estate SRL has chosen to make a brief message visible to the user on first access, reaffirming the absence of cookies. This choice responds to a logic of transparency and clear communication, allowing the user to receive immediate confirmation of the nature of the website without necessarily having to consult this Cookie Policy.

Data subject rights

Although the website does not collect personal data through cookies, users who voluntarily send a communication via the contact form have the right, pursuant to Articles 15-22 of Regulation (EU) 2016/679, to:

• access their personal data
• obtain rectification or erasure
• obtain restriction of processing
• object to processing
• receive data in a structured format (portability)
• lodge a complaint with the supervisory authority (Italian Data Protection Authority)

Changes to this Cookie Policy

This Cookie Policy may be amended over time, particularly should the website introduce features involving the use of cookies or tracking technologies in the future. In such cases, this policy will be promptly updated and, where necessary, a consent management system compliant with applicable regulations will be presented to the user. Users are therefore encouraged to consult this page periodically.

Data Controller

Pulsar Real Estate SRL
Via Flaminia 695 — 00191 Rome, Italy
VAT No.: 15862301007
REA: RM-1619009

Email: info@pulsar-re.it

PEC: pulsar_srl@pec.it

Tel: +39 06 855.21.11

For any request relating to this policy or the processing of personal data, you may contact the Data Controller at the above details.

This Cookie Policy is drafted in compliance with Directive 2002/58/EC, Regulation (EU) 2016/679, Legislative Decree 196/2003 and subsequent amendments, as well as the Guidelines of the Italian Data Protection Authority of 10 June 2021.