Cookie and Personal Data Policy

COOKIE POLICY

Notice on the use of Cookies and similar tracking technologies

1. Introduction and regulatory references
This notice sets out the main information relating to the processing of personal data and the use of cookies within this site.
This notice is addressed to anyone who accesses or uses this site, describing how the user’s personal data may be collected, used and protected through cookies and similar technologies, as well as the rights granted by law.
These provisions do not concern other websites, pages or online services accessible through external links that may be present on the site, in respect of which you are invited to consult the relevant privacy notices.
This notice is provided in compliance with the principal national and international regulations on the protection of personal data, including:

• Regulation (EU) 2016/679 (GDPR) and Directive 2002/58/EC, known as the ePrivacy Directive
• Other regulations that may be applicable.

2. Who manages your data and how can you contact us?
Your personal data is processed by:
A New Tomorrow
London UK
contact@anewtomorrowband.com

For any information concerning the processing of personal data or to exercise the rights granted by law, data subjects may contact the Data Controller.

3. What data do we collect when you visit the site?
When you browse this site, we may collect certain information through cookies, related tools and tracking technologies. The main types of data that may be recorded include:

• Technical and navigation information: IP address, identifiers of the device in use, information about the browser and operating system, date and time of accesses, pages visited, technical commands necessary for the correct display of content, system errors.
• User preferences: choices made in relation to cookies and privacy settings, collected through panels, banners or similar tools.
• Statistical and usage data: information used to assess and improve the functioning of the site, for example the frequency of visits or the most consulted areas. This data may be processed in aggregated or anonymized form where the tool used allows it; in other cases the related processing takes place according to the preferences expressed by the user and as indicated in the detailed list of cookies.
• Interactions with integrated external services: technical data shared when the site integrates third-party services (e.g. fonts, maps, image display), always in accordance with the rules of the operators involved.

For details on the processing of data provided through contact forms, service requests or other features, we invite you to consult our Personal Data Policy.

4. What types of cookies (and similar) exist?
In general, there are several categories of cookies and similar technologies (web beacons, local storage and equivalent technologies). Below is a description of the categories that can generally be used; the list of those actually present on this site is set out in the following section “Detailed list of cookies”.

• Strictly necessary cookies: essential for the technical functioning of the site, they allow, for example, access to protected areas, session management or remembering essential preferences.
• Cookies for preferences and personalization: they serve to store display choices, such as language, text size or viewing mode, in order to offer you an interaction closer to your preferences.
• Analytics and performance cookies: they help us understand how the site is used. They can be treated as technical cookies only when they are configured so as to reduce their identifying power and are used exclusively for aggregated statistics; in other cases they are activated only with the user’s prior consent.
• Cookies for promotional or advertising activities: used to offer personalized commercial content and to monitor the effectiveness of advertising campaigns.
• External components and services: by interacting with social plugins, analytics tools or third-party platforms, cookies or comparable systems managed directly by external parties may be installed.

5. How can you give or refuse consent to the use of cookies?
Jurisdictions EU, or in any case in countries with legislation similar to the GDPR:

• The use of cookies and similar technologies that are not strictly necessary is subject, where required by the applicable legislation, to the prior consent of the user, freely given, specific, informed and unambiguous; in other cases, it takes place in compliance with the conditions of lawfulness and, where applicable, on the basis of an appropriate legal basis, following transparent information and in compliance with the rights of refusal, objection or withdrawal provided for by the applicable legislation. As a precautionary choice, the consent management system My Agile Privacy® adopted on this site activates such tools only after the user has expressed their preferences through the dedicated cookie banner.
• The user can manage and modify their preferences at any time, withdraw the consent granted and access the “Manage cookie preferences” function.

Operational details:
On first access to the site, a banner is displayed that allows you to manage preferences relating to cookies and tracking tools.
Through the banner, the user can choose whether to:

• Accept all cookies: by clicking the dedicated button, all non-essential cookies will be activated.
• Customize the settings: you can select in detail which cookies to authorize and which to keep disabled.
• Reject optional cookies: by pressing the reject button or closing the banner via the dedicated close command (X), the default settings remain unchanged and browsing continues with only the technical cookies necessary for the functioning of the site; closing the banner therefore amounts to a refusal of consent.

The preferences expressed through the banner are retained for a period of 180 days by means of a technical cookie. If you access from a different device or browser, you will need to reconfigure your preferences.
The user may, in any case, at any time modify the choices made by accessing the dedicated functionality, identifiable by the icon or the link dedicated to consent management.

The preferences on the use of cookies and tracking tools are collected and managed through the consent management system (Consent Management Platform) My Agile Privacy®, a Google-certified partner for integration with Google Consent Mode v2.

6. On what legal bases do we process the data collected through cookies and related technologies?
The installation of cookies and the use of tracking tools are based on different legal bases depending on the category of the tool and the applicable legislation. In general:

1. Technical cookies and strictly necessary tools: they are used without the user’s consent, as they are necessary to carry out the transmission of a communication over an electronic communications network or to provide an information society service expressly requested by the user. This category includes, for example, cookies necessary for the functioning of the site, session management, security, the storage of consent preferences and, where the conditions are met, certain analytics cookies configured so as to reduce their identifying power.

Where cookies or other tools involve the processing of personal data, the storage of information on the device or access to it is subject to consent only where this is required by the applicable legislation, save for the exemptions indicated above for strictly necessary tools; the subsequent processing operations on the data collected are based on a legal basis under the applicable data protection legislation. Any legitimate interest of the Data Controller may concern such subsequent processing, where necessary and proportionate (for example specific security activities), and cannot replace the consent required for tools that are not strictly necessary.

Refusing or withdrawing consent to the use of certain cookies may limit access to some personalized features of the site.

7. How is your data protected?
The personal data collected through this site by means of cookies and tracking tools is processed by electronic means in accordance with the principles of lawfulness, fairness, minimization, integrity and confidentiality.

The Data Controller also adopts further technical and organizational measures appropriate to ensure a level of security suited to the risk. For details of such measures, please refer to the Personal Data Policy on this site.

8. Where can your data be processed and transferred?
Some of the cookies and third-party tools listed in the following section “Detailed list of cookies” are provided by parties that may process the data in countries other than the one in which you reside, including foreign countries.

The data collected through cookies and tracking tools is processed, as a rule, in the country where the Data Controller is established and at the service providers used. Where data is transferred or made accessible outside the relevant territory under the applicable legislation, the transfer takes place by means of one of the mechanisms it permits, including adequacy decisions, appropriate or suitable safeguards and, where applicable, derogations or other conditions provided for by the applicable legislation. For transfers subject to the GDPR, the relevant territory is the European Union / European Economic Area and, in particular, the EU-U.S. Data Privacy Framework, limited to organizations included in the relevant list and within the scope of the certification, and the Standard Contractual Clauses adopted by the European Commission are relevant. The destination countries and the mechanism actually applied are indicated in the detailed list of cookies, together with the methods for obtaining a copy of any safeguards.

9. Who can receive your data?
The personal data collected through cookies and tracking tools may be processed by the Data Controller, by authorized persons and by technical service providers or third parties involved in the provision of the services on the site.

Such parties may, depending on the activities actually carried out and the applicable legislation, process the data on behalf of the Data Controller or determine the purposes and means of the processing, independently or jointly with other parties. The identities or categories of such parties, their respective roles and, where relevant, the purposes are indicated in the detailed list of cookies; the privacy notices of the individual suppliers provide supplementary information.

The updated list of suppliers can be consulted in the table in section 10 and is also available on request at the Data Controller’s contact details.

10. Detailed list of cookies

This site does not use any third-party cookies or tracking tools.

11. How long do we keep your data and preferences?

The preferences expressed on the use of cookies and tracking technologies through the banner or the consent management platform are retained for a period of 180 days.

For the retention, duration and methods of deletion of data other than those mentioned, you can consult the specific provisions set out in the Personal Data Policy on this site.

12. What are your rights regarding the data collected?
In relation to the data collected through cookies and tracking tools, the user can exercise at any time the rights granted by the applicable legislation.

In particular, the right most directly connected to cookies is the right to withdraw the consent previously given to the use of non-essential cookies and to modify one’s preferences at any time, through the dedicated consent management function identifiable by the icon or the dedicated link, without retroactive effect on the lawfulness of processing already carried out on the basis of consent, without prejudice to the further rights provided for by the applicable legislation, including, where applicable, the right to erasure or deletion of the data.

The user also has, under the applicable legislation, the further rights granted to data subjects - including access, rectification, erasure, restriction, objection to processing, data portability and lodging a complaint with the competent authority, pursuant to Article 77 of the GDPR. For a full description of these rights and the methods of exercising them, please refer to the Personal Data Policy on this site.

13. How to delete cookies

Each browser provides different procedures to prevent the use of cookies or to remove them. You can act from the settings of your browser to block and/or delete them. Below you will find references to the official guides of the main browsers on how to manage and delete cookies:

• instructions for Google Chrome
• instructions for Safari
• instructions for Mozilla Firefox
• instructions for Microsoft Edge

If you use a browser other than those indicated, consult the support section of the official website of the relevant manufacturer.

14. How do we inform you of changes to this notice?
This notice is subject to periodic revision to reflect regulatory changes or modifications to the services offered through the site. Any significant change will be communicated through this page.

This notice is made available by My Agile Privacy®.

PERSONAL DATA POLICY

Notice on the Processing of Personal Data collected through this website

1. Introduction and regulatory references
This notice describes the processing of personal data collected through this website, including data acquired by means of cookies, tracking technologies and - where present - contact forms and any other features that may be active on the site.
This notice is addressed to anyone who accesses or uses this website, describing how the user’s personal data is collected, used and protected, as well as the rights granted by law.
These provisions do not concern other websites, pages or online services accessible through external links that may be present on the site, in respect of which you are invited to consult the relevant privacy notices.
This notice is provided in compliance with the principal national and international regulations on the protection of personal data, including:

• Regulation (EU) 2016/679 (GDPR) and Directive 2002/58/EC, known as the ePrivacy Directive
• Other regulations that may be applicable.

2. Who manages your data and how can you contact us?
Your personal data is processed by:
A New Tomorrow
London UK
contact@anewtomorrowband.com

For any information concerning the processing of personal data or to exercise the rights granted by law, data subjects may contact the Data Controller.

3. On what legal bases do we process your data?
The processing of personal data collected through this site (including data collected by means of cookies, similar technologies, contact forms and any other features that may be active on the site) is based on one or more of the following legal bases:

1. Performance of pre-contractual or contractual measures: where processing is necessary to respond to user requests, provide requested services and, where the site so provides, manage orders, accounts or contractual relationships.
2. Compliance with legal obligations: where processing is necessary to comply with tax, accounting, administrative or security obligations or with requests from the authorities.

The Data Controller may also process the necessary data on the basis of its own legitimate interest, pursuing interests consisting in the security of the site, the prevention of abuse and fraud and the protection of its rights in legal proceedings. The user may in any case object to the processing in accordance with the applicable legislation, in the cases provided for by Article 21 GDPR.

Failure to accept or the withdrawal of consent may limit certain features or services of the site.

The site does not require the active provision of personal data: technical navigation data is collected automatically and is necessary to enable the functioning and use of the site; in the absence of its automatic transmission it is not technically possible to establish the connection or provide the requested functionality.

4. What data do we collect when you visit the site?
While browsing this site, the following data may be collected, including by means of cookies and similar technologies such as pixel tags, web beacons, local storage and equivalent technologies, namely:

• Navigation and technical data: information such as IP address, device identifiers, data relating to the operating system and browser, requested URLs, connection times, technical logs, technical preferences, and usage data collected through cookies and tracking technologies (pixel tags, web beacons, local storage and equivalent tools).

5. How do we process your data, how do we protect it and how long do we keep it?
The personal data collected through this site is processed mainly by electronic and digital means in accordance with the principles of lawfulness, fairness, data minimization, integrity and confidentiality.

Data is retained according to the following timeframes:

• Cookie preferences and consents: retained for 180 days, as set out in the Cookie Policy on this site.
• Navigation and technical data: retained for the time strictly necessary for security purposes and, as a rule, no longer than 12 months, after which it is deleted or anonymized, save for longer periods imposed by legal obligations or by the need to establish, exercise or defend a right in legal proceedings.
• Data connected to any contractual relationships established with the Data Controller: where they exist, it is retained for the duration of the relationship and, thereafter, for the time required by the applicable legal obligations (for example in accounting and tax matters).
• Data entered through forms or specific requests: retained for the time necessary to respond to the request and to fulfill the related purpose, and thereafter for any period required by legal obligations.

6. Who can receive your data?
The following may access the personal data collected through this site, within the limits of their respective responsibilities and purposes:

• Authorized internal persons designated by the Data Controller, duly instructed on privacy and security matters;
• Suppliers and third parties appointed as Data Processors (for example: technical providers and IT services, site maintenance, e-mail providers, consultants, where applicable);
• Third parties that provide services integrated into the site (e.g. fonts, maps, image display), which may process technical data as independent controllers in accordance with their own notices (in which case please also consult the individual notices of such third parties);
• Competent public authorities and supervisory bodies, within the limits imposed by law or in order to comply with requests from the judicial authority;

The updated list of external recipients can be made available on request by writing to the Data Controller’s contact details.

7. Where can your data be transferred?
The personal data collected through this site is processed, as a rule, in the country where the Data Controller is established and at the service providers it uses. Where data is transferred or made accessible outside the relevant territory under the applicable legislation, the transfer takes place by means of one of the mechanisms it permits, including adequacy decisions, appropriate or suitable safeguards and, where applicable, derogations or other conditions provided for by the applicable legislation. For transfers subject to the GDPR, the relevant territory is the European Union / European Economic Area and, in particular, the EU-U.S. Data Privacy Framework, limited to certified organizations, and the Standard Contractual Clauses adopted by the European Commission are relevant. Information on the applicable mechanism and, where provided for, a copy of the relevant safeguards, possibly redacted in the confidential parts, may be requested at the Data Controller’s contact details.

8. What are your rights regarding the data collected?
The user, under the applicable legislation, has the right to:

• Obtain confirmation as to whether or not personal data concerning them is being processed and, if so, obtain access to that data and the related information (right of access).
• Request the rectification, updating or erasure of data that is inaccurate or no longer necessary (right to rectification and erasure).
• Request the restriction of processing or object, for reasons connected with your particular situation, to processing based on the Data Controller’s legitimate interest, subject to the existence of the conditions provided for by Article 21 GDPR.
• Receive, in the cases and under the conditions provided for by the applicable legislation, the personal data concerning you in the format required by it and obtain its transmission to another controller or provider; for the EU/EEA and the UK, the right concerns the data you have provided, the format is structured, commonly used and machine-readable and direct transmission is carried out where technically feasible (right to data portability).
• Withdraw at any time any consent given, without affecting the lawfulness of processing based on consent carried out before the withdrawal (for example for the sending of commercial communications or newsletters, where active).
• Withdraw the consent given to the use of non-essential cookies and to the processing of data collected through tracking tools.
• Report any irregularities or abuses to the competent supervisory authorities.

To exercise these rights, it is sufficient to send a request to the Data Controller’s contact details. The Data Controller will respond without undue delay and within the time limits provided for by the applicable legislation. For requests subject to the GDPR or the UK GDPR, a response is provided within the ordinary period of one month, calculated in accordance with the applicable legislation; that period may be extended by a further two months, taking into account the complexity and number of the requests, and the data subject is informed of the extension and the related reasons within the ordinary period.

9. How is minors’ data processed?
The protection of minors is a fundamental priority.

This site is not directed at minors and does not intentionally collect their data through its forms. Where, in the context of a request or query, the user provides personal data relating to third parties - including any minors - they must ensure that they are authorized to do so; such data will be processed within the limits and for the purposes of the request, in compliance with the applicable legislation. For requests for rectification, restriction or erasure, you may write to the Data Controller’s contact details.

10. How can you make reports or complaints to the authorities?
If you believe that the processing of your personal data through this site does not comply with the applicable legislation, you may lodge a complaint free of charge, pursuant to Article 77 of the GDPR, with the competent authorities indicated below, in accordance with the applicable legislation:

• the competent supervisory authority for the protection of personal data;

11. How do we inform you of changes to this notice?
This notice is subject to periodic revision to reflect regulatory changes or modifications to the services offered through the site. Any significant change will be communicated through this page.

This notice is made available by My Agile Privacy®.