Hi @bosendorfer,
This translation is done at cookiedatabase.org. I will ask them to look into it. Do you have documentation so we can double-check that technical and functional cookies are described differently or that technical is specifically preferred in Italy?
Because ‘technical’ could be broadly understood regarding website operations, as you would expect aggregating data would be technical as well, but it does not serve the functional operation of the website. The same reason we stay away from ‘essential cookies’ as there are alternatives without cookies for the same operation and ‘essential’ does not seem an appropriate label. That’s the reason, but we will look into it.
Regards Aert
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This reply was modified 3 years, 2 months ago by
Aert Hulsebos. Reason: used 'moderators' and got flagged
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This reply was modified 3 years, 2 months ago by Aert Hulsebos.
To make you better understand I am attaching an image and I specify that cookies are added manually and the cookie document is made manually (of course embedding [cmplz-cookies] )
https://servimg.com/view/19611707/257
Thanks in advance!
Francus`
Hi @aahulsebos,
Thanks for your reply.
The authority that deals with privacy in Italy is this
https://www.garanteprivacy.it/
The latest published directive is this:
https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/9677876
There is also a short video here:
The word Funzionali (functionals) is never used.
Only the word Tecnici (Technical) is used.
Tell me if there is any other element that may be useful for your investigation.
Thanks for your interest,
Francus
Hi @bosendorfer,
Thanks. The explanation of the category is taken into account with Complianz, and follows the (ePrivacy e.a.) guidelines;
The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
The name of the category is interchangeable. https://cookiedatabase.org/function-and-purpose-of-cookies/
Both are correct, it’s just a matter of preference. I referred this to cookiedatabase.org as well.
regards Aert
Thanks @aahulsebos ,
as always very clear.
I saw that the definition is interchangeable but I was wondering if to accurately follow the instructions of the Italian Guarantor it was possible to force the definition with some code in function.php in the child theme.
Naturally it would then be the same in both languages, but if in English a category is defined as Tecnici instead of Technical it would be a negligible mistake.
And in any case it would give the possibility in the sites in a single language to define that category in the most appropriate way according to the country of belonging.
As code ignorant I ask you if it is feasible.
As always a big thank you,
Francus
Hi @bosendorfer
Just wanted to let you know that our legal team always stays in contact with Data Protection Authorities around the world when it comes to the implementation or enforcement of new guidelines and laws.
We know that the Italian DPA uses the two categories “Technical” and “Profiling” as identifiers in their 2021 guideline. The description of what they consider to be technical is indeed the same as the description Complianz uses under “Functional” in the banner and the cookie policy. The way we implemented this is actually allowed by the Italian DPA because according to the DPA there is no universally accepted system for semantic coding of cookies and other tracking tools.
According to the Italian DPA you should therefore disclose the used criteria of the identifiers (Complianz does that in the banner), and you should consider placing those criteria in your cookie policy (Complianz already does that) or privacy statement. These criteria may also be communicated to the Authority upon request as a tool to support any investigative activities that will be undertaken with regard to the issues in question.
Hi @paapst,
thank you for your reply.
According to your answer I can leave everything as it is.
I just wonder why, since you are aware that in Italy the DPA defines this category as Tecnici, it is not convenient in the Italian translation of Functional to let the word Tecnici to be triggered.
However, if you are sure that for the Italian DPA there is no universally accepted system for semantic coding of cookies, Functional will also work.
Thank you, have a nice day!
Francus
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This reply was modified 3 years, 2 months ago by
bosendorfer.
