Introduction
This notice is provided pursuant to Article 13 of the European Regulation 2016/679 (GDPR), as well as Article 122 of Legislative Decree 196/2003 (Privacy Code) and the Provision of 17 April 2026 issued by the Italian Data Protection Authority regarding the use of ‘tracking pixels’ in email communications.
It also supplements the other notices available on the website; together with these, it provides all the elements required by Article 13 of the GDPR, as well as by further provisions issued by the Italian Data Protection Authority.

Subject matter of this notice
Our company uses tracking technologies in its email communications that make use of so-called ‘tracking pixels’ to collect certain information about recipients, which may include personal data. Consequently, the purpose of this notice is to explain to the user, in a clear and precise manner, the purposes and methods of their use.

Definition of tracking pixels
Tracking pixels are very small images embedded within emails as hypertext links. When the recipient opens the email, a code embedded in the message can automatically trigger a request to the server to download the image. This mechanism enables the sender to collect information, for example, on message-opening events and any deletion, forwarding or archiving thereof, as well as data on the recipient, such as their IP address and the type of device used.

Tracking pixels used and their purposes
The purposes for which our company may use tracking pixels are set out below:

1. Anonymous and aggregated statistics: tracking pixels are used to obtain overall statistics on message open rates, in order to improve email deliverability and combat spam, which also benefits the user. The recipient’s consent is not required for this purpose.
2. Security: tracking pixels are necessary to implement specific security measures, for example in connection with the authentication process for the provision of services requested by the user, for which it is necessary to collect information on whether messages have been opened. The recipient’s consent is not required for this purpose.
3. Institutional or service-related communications: pixels are used for particularly important communications, for which it is necessary to verify actual receipt and acknowledgement by reference to message-opening data (e.g. communications relating to contractual changes, security incidents, deadlines and compliance obligations, etc.). The recipient’s consent is not required for this purpose.
4. Promotional purposes/activities: message-opening data collected via tracking pixels is used to evaluate and improve our company’s promotional campaigns, for example by adjusting their frequency in accordance with the level of interest shown by recipients.

Such use may only take place with the prior consent of the email recipient. Consent, as expressly provided by applicable legislation, may be included within the more general consent to receive promotional communications, obtained prior to the inclusion of the address in the ‘mailing lists’, subject to the exceptions provided in relation to ‘soft spam’. As specified in more detail below, consent may be withdrawn at any time, and the recipient may choose either to stop receiving promotional communications altogether, or to continue receiving them without tracking pixels.

Data collected via tracking pixels
Tracking pixels may enable our company to collect certain personal data from recipients, strictly related to information on the opening of messages, such as the IP address, the type of device used, the time spent viewing the messages and similar data.

Such data will be processed in full compliance with current legislation, limiting processing to what is strictly necessary to achieve the intended purposes, in accordance with the data minimisation principle laid down in the GDPR.

Computer settings to prevent tracking
Recipients are reminded that tracking, regardless of the purpose of the communications, can only take place if image downloading is enabled. If the user reads the email exclusively in text format, the tracking pixel, like other images, is not downloaded and cannot perform its tracking function.

Withdrawal or ‘granular’ modification of consent
The user/recipient of the emails may at any time withdraw or amend their consent on a ‘granular’ basis, choosing in particular whether to stop receiving communications altogether or to continue receiving them without tracking pixels.

Specifically, the user can easily manage their preferences by accessing the dedicated links and buttons included in every email message they receive.

Legal basis for processing
For the use of tracking pixels for statistical or security purposes and/or for sending institutional or service-related communications, the processing is necessary to optimise the services provided to users; the legal basis may be, depending on the circumstances, the legitimate interests of the data controller and the recipients, the performance of contractual or pre-contractual measures at the data subject’s request and/or compliance with legal obligations by the data controller.

Where tracking pixels are used for promotional purposes, the legal basis is the freely given consent of the user, which may be withdrawn and/or amended at any time.

Recipients or categories of recipients of personal data
Data may be disclosed to third parties only to fulfil legal or contractual obligations, as well as to honour the user’s choices and/or requests. Under no circumstances will the data be disseminated.

Persons authorised to process the data
The data will be processed exclusively by duly authorised personnel.

Rights of the data subject
You are entitled to all the rights enshrined in the European General Data Protection Regulation (GDPR), such as the right to request access to and rectification of your personal data, the right to erasure, the right to restriction of processing, the right to object to processing, and the right to data portability. You also have the right to lodge a complaint or submit a notification to the supervisory authority, namely the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), or to bring proceedings before the competent courts.

Transfers to third countries
Any transfers of personal data to a third country outside the European Union or to an international organisation will take place on the basis of an adequacy decision of the European Commission or, in the case of transfers referred to in Articles 46, 47 or 49(2) of the European General Data Protection Regulation, on the basis of appropriate safeguards.

Data controller
The data controller is Reggio Children S.r.l., with its registered office at Via Bligny No. 1/A, Reggio Emilia (RE).

Data Protection Officer
The Data Protection Officer is Dr Juri Torreggiani, whose practice is situated at Via Piccard 16/G, Reggio Emilia: any requests for clarification or information may be addressed to this officer.

This privacy notice may be supplemented, either orally or in writing, with further details and guidance, in order to best meet any informational needs in relation to privacy matters and to keep pace with regulatory developments.