Tracking Pixel policy
Tracking pixels in marketing communications
The marketing communications and newsletters that Jacob Cohën Company S.p.A. sends by email contain a tracking pixel—a small image embedded in the message that loads when the email is opened, generating a request that is sent to the systems of the hosting platform provider. Using this tool, and by tracking clicks on the links in the message, the following data are processed: IP address, information about the device and the email program used (user agent), date and time of opening and interaction, and links clicked.
Purpose. The purpose of the processing is to measure interaction with the communications received, in order to evaluate their effectiveness and improve the relevance of the content sent.
Legal basis. The processing is carried out based on the consent of the data subject, pursuant to Article 122 of Italian Legislative Decree 196/2003 and Articles 6( 1)( a) and 7 of Regulation (EU) 2016/679. Consent to tracking may be granted at the same time as consent to receive marketing communications, in accordance with the guidelines of the Italian Data Protection Authority (Order No 284 of April 17, 2026).
Right to object and withdraw consent. The data subject may object to tracking and withdraw their consent at any time, easily and without affecting the receipt of communications. If the data subject withdraws their consent, they will continue to receive the marketing communications for which they signed up, without their opening and clicks being tracked or recorded. You can withdraw your consent through the preferences center in your account or via the link at the bottom of each communication.
Data processors. The data is processed on behalf of the Controller by Klaviyo, Inc. (email marketing platform) and by Salesforce (CRM) in their capacity as data processors pursuant to Article 28 of Regulation (EU) 2016/679. The processing carried out by Klaviyo, Inc. involves transferring data to the United States, which is carried out on the basis of the EU-US Data Privacy Framework and, to a lesser extent, the Standard Contractual Clauses pursuant to Article 46 of the Regulation. The data managed by Salesforce is stored in data centers located in the European Union; any access from third countries is governed by the relevant data processing arrangement (Data Privacy Framework and/or Standard Contractual Clauses).
Storage. Data collected via pixels and click tracking is stored for 12 months from the date of collection, after which it is deleted or anonymized. Profile data is stored for as long as the data subject consents to receive to communications; proof of consent is stored for the duration of the same consent and for the subsequent statutory period, in order to demonstrate the lawfulness of the processing.
