- websites that use analytical cookies can consider them as necessary for their functioning only if created by the first-party;
- if the cookies are third-party’s cookies, the website owners are not subject to duties (e.g. notification to the DPA) if: (i) the cookie tracking capabilities are reduced (for example by blocking part of the IP); (ii) the third party agrees not to cross the information recorded through the cookie with others already in its possession;
- if the website contains links to other sites (e.g. commercial banner, social networks) that do not require cookies, there is no need to inform the data subject;
- the provisions apply to all websites that feed cookies to users, without regard to whether they have a place of business in Italy.
For more information, Francesca Giannoni-Crystal