INFORMATION NOTE ON PRIVACY
The data controller is La Sanfermese S.p.A. (hereinafter, “La Sanfermese Spa” or “Owner”), with registered office in Strada Tadesa 1, Piubega, 46040-MN with the following contact details: info@pec.lasanfermese.it La Sanfermese Spa will process your Personal Data in compliance with EU Regulation no. 2016/679 and the national legislation on personal data protection (hereinafter, “Privacy Law”).
What Personal Data we process and how we collect it
To allow you to browse the Site and/or access some of its sections, La Sanfermese s.p.a. may have to collect and process your Personal Data. When connecting to the Site, the IT systems and software procedures administer and acquire information automatically and indirectly (for example, the so-called cookies as specified in the “Information Note on Privacy – Cookies” following this information; IP addresses; domain names of computers used by users who connect to the Site; addresses in URL notation of the requested resources; time of the request to the server).
Purposes of the Data processing and its legal bases
Below, we indicate the purposes of your Personal Data processing and the related legal bases according to the needs expressed from time to time by accessing the various sections of the Site (except for individual initiatives that involve the provision of precise Personal Data, for which please refer to specific information published from time to time on the Site).
The processing of your Personal Data will only take place with your prior consent. You have the right to withdraw this consent at any time in the following ways: by accessing your profile page (and unchecking the relevant box); deleting your profile; using the link at the bottom of each promotional e-mail (regarding marketing activities and the newsletter) or according to the methods indicated from time to time by the Data Controller when obtaining consent.
Methods of processing your Personal Data
The processing of your Personal Data may include any operation, such as collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation, and destruction.
Depending on the purposes, the processing of your Personal Data may take place in electronic form (the prevailing one) or on paper. To this end, we use databases and electronic platforms managed by La Sanfermese S.p.a. or by external third parties designated as data processors and/or integrated IT systems owned by La Sanfermese S.p.a. and the aforementioned third parties and/or websites and/or APPs of which La Sanfermese S.p.a. holds the ownership or usage rights.
The Data Controller has assessed that the level of security guaranteed to your Personal Data is adequate to protect them from possible risks deriving from loss, destruction, modification, unauthorized disclosure, accidental or illegal access, abuse, or alteration.
In particular:
– The Data Controller has adopted security measures commensurate with the risks;
– The Data Controller has stored your data on servers located mainly in the European territory (for more information on this, consult the “Transfer of Personal Data outside the European Economic Area” section). In any case, all our servers use an advanced and daily backup system..
Where we process your Personal Data
Your Personal Data are mainly processed at the offices of the Data Controller and in the places where the data processors are located. For further information, contact the Data Controller at the addresses indicated in the section “Identity and contact details of the Data Controller”.
How long do we keep your Personal Data
In compliance with the principles of necessity and proportionality of the processing, the Data Controller has identified different retention times for Personal Data. These may vary concerning the individual purposes pursued, namely:
(i) we will keep your Data for the time strictly necessary to manage your interactions with the Site and its sections, such as registration, activation, and use of the services there offered (and in any case, at the latest until your profile is active). For security reasons, we will use the log data to confirm the use of the account. In the event of inactivity exceeding 24 months, we will contact you to verify your interest in keeping the account active, indicating how to express this interest. If there is no activity within 30 days after the contact attempt, we will delete your account;
(ii)we will keep your data for the time strictly necessary to manage and respond to your requests relating to products and initiatives of the various brands of the La Sanfermese Spa group, advertisements, or the Site (“Contact Us” section);
(iii) your Personal Data, excluding contact details, will be kept for a maximum of 36 months for marketing activities. These may include commercial communications via e-mail, SMS, and push notifications for sending promotional and advertising material, group or market research relating to any brand of La Sanfermese S.p.a ;
(iv) We will keep your profile data for a maximum of 36 months for profiling activities. These may include analysis of consumption habits and/or choices as well as a comparison of your Data present in the various databases owned or used by La Sanfermese S.p.a. (for instance, to send personalized promotional communications, personalization of the content displayed on the Site, banners, and statistical surveys);
(v) we will keep your data, excluding contact data, for a maximum of 36 months for sending newsletters;
(vi) in the case of prize events, we will keep your data for the duration of each event and for the time strictly necessary to manage your possible participation in competitions with the related regulatory, administrative, and accounting requirements;
(vii) we will keep your data for the time strictly necessary for the management and execution of the obligations established by law (accounting, administrative, tax, etc.);
(viii) we will keep your data for the time strictly necessary to manage any disputes and, in any case, no later than the applicable limitation periods.
Recipients of your Personal Data
Your Personal Data may be disclosed to and processed by:
(i) legal or natural persons who carry out outsourcing activities of assistance, communication, marketing, advertising, promotions, and product sales. La Sanfermese S.p.a. or its external trust processors may delegate activities and/or services to external parties, such as advertisers, advertising agencies, IT service providers, managers of the Site and electronic platforms, partners, credit institutions, professional firms;
(ii) employees and/or collaborators of the Data Controller (including system administrators) authorized to process your data under its direct authority;
(iii) employees and/or collaborators of external data processors (including system administrators) authorized to process your data under the direct authority of external data processors.
La Sanfermese S.p.a. will not communicate or disclose your data to third parties unless necessary to protect their rights. However, if you have entered Personal Data in your nickname and/or associated your image with it, they may appear on the Site or Social Networks.
Minors
Minors under the age of 16 must not give information or Personal Data to La Sanfermese S.p.a. without the consent of those who exercise parental responsibility. In the absence of such consent, the minor will not be able to register on the Site. La Sanfermese S.p.a. invites all those who exercise parental responsibility for minors to inform them about the safe and responsible use of the Internet and the Web. When registering on the Site, we also invite you to implement the registration procedures indicated for individuals under 16.
Your rights concerning the processing of your Personal Data
The Privacy Law recognizes numerous rights to interested parties. In particular:
1. You have the right to obtain from the Data Controller confirmation of the existence or not of your Personal Data, even if not yet registered, and their communication in an intelligible form. You also have the right to access your Personal Data (of which you can obtain a copy) and related information, including the purpose of the processing, the categories and origin of the Personal Data, the categories of recipients to whom they have been or could be communicated, the retention period (where possible), and the exercisable rights;
2. you have the right to obtain from the Data Controller the rectification of your Personal Data and the integration of incomplete ones;
3. you have the right to delete your profile on the Site. In any case, you can obtain the deletion of your Data without undue delay, among other things, when they are no longer necessary, or the legal basis for their processing no longer exists;
4. you have the right to obtain the transformation into an anonymous form or the blocking of your Personal Data when processed in violation of the law. This right extends to those whose conservation is not necessary for the purposes for which they were collected or processed;
5. you have the right to limit the processing of your Personal Data. This right also applies to cases in which you dispute the accuracy or object to the processing of data, and extends to the entire period necessary to carry out the related checks;
6. you have the right to receive your data in a structured, commonly used, and electronically readable format. You also have the right to transmit or obtain the direct transmission of your Data to another data controller without hindrance, when this is technically feasible, if the automated processing is based on your consent or is necessary to execute a contract of which you are part of;
7. you have the right to withdraw consent to the processing of your Personal Data for any of the purposes for which you granted it.
To exercise your rights towards La Sanfermese S.p.a., access the “Contact Us” section of the Site or write to the following e-mail address: info@pec.lasanfermese.it. Alternatively, you can send La Sanfermese s.p.a. a letter by ordinary mail to the address indicated in the section “Identity and contact details of the Data Controller”.
Furthermore, if you believe that the processing of your Personal Data violates the Privacy Law, you can lodge a complaint with the Privacy Authority of the State in which you reside, where you work or where the alleged violation has occurred. Alternatively, you can contact the same Authority to request information regarding the exercise of your rights under the Privacy Law.
Right to object to the processing of your Personal Data
At any time and for reasons related to your particular situation, you have the right to object to the processing of your Personal Data (including profiling) for the pursuit of a legitimate interest of the Data Controller or third parties. In this case, the Data Controller refrains from further processing your Personal Data. Situations in which legitimate binding reasons prevail over your interests, rights, or freedoms, and those in which the processing of your data is necessary to ascertain, exercise, or defend a right in court make exception.
Furthermore, you have the right to withdraw consent to the processing of your data for marketing purposes (direct and otherwise) and for profiling connected to it. To withdraw your consent to data processing, access the “Contact Us” section of the Site or send an email to the following email address: info@pec.lasanfermese.it.
In case of opposition to the processing of your Personal Data for direct marketing purposes, the Data Controller will no longer be able to process them for this purpose.
INFORMATION NOTE ON PRIVACY – COOKIES
Cookies are text strings that act as computer markers sent by a server (in this case, that of the Site) to a user’s device (generally, the Internet browser) at every access of a specific webpage. The user’s browser automatically stores cookies, including those set by other websites (“third-party cookies”). Each time the user accesses the same Internet page, they are sent back to the server that generated them.
Among the various functions performed by cookies, the improvement of the user’s browsing experience: for example, cookies enable and/or facilitate access to some Internet pages allowing the storage of visited pages and other information (such as frequently consulted pages, connection errors, etc.) or allow profiling activities. Therefore, to facilitate the full use of a website, it is advisable to configure the browser to accept cookies.
Typically, standard browser configuration automatically accepts cookies. Users can disable or delete them (from time to time or once and for all), but doing so could prevent optimal use of some site areas. To check the methods and types of cookies stored on your browser, you can change the default cookie settings of your browser.
Characteristics and purpose of cookies
Our Site uses the following categories of cookies, owned by La Sanfermese s.p.a. or third parties.
I. Technical and functional cookies:
a) Technical cookies: They facilitate navigation on the Site and the use of its features. Among technical cookies, strictly necessary cookies enable functions essential for full use of the Site. Performance cookies allow you to improve the functionality of the Site.
b) Functionality cookies: They allow the Site to provide better and personalized services (for example, propose content similar to those previously requested) by remembering your choices (such as your language or geographical area) and suggesting them at subsequent accesses.
II. Profiling cookies:
They allow us to send you advertising messages and services in line with the preferences you have expressed. In detail, they permit individual profiling based on your tastes, preferences, and consumption choices. They also enable the offer of advertising and services potentially close to your interests as detected while browsing the Site or comparing the activities through your browser.
Profiling cookies are used, for example, to limit the administration of a given ad (we deduce the effectiveness of a campaign from the frequency of viewing of the related commercial).
Description of the methods of consent to the installation of cookies
At the first access to the Site, you will find a banner with a brief note about cookies linked to this complete information. Here, you will find more information on the cookies installed by the Data Controller and third parties.
The detailed information presents descriptions and characteristics of the different categories of cookies and allows you to decide which ones to authorize.
The use of technical and analytical cookies does not require your express consent. However, you can disable them by following the procedure described in the paragraph: “How to enable or disable cookies on your browsers.”
On the other hand, your consent is necessary for profiling cookies that allow us to send you advertising and services in line with your tastes, preferences, and consumption choices.
By browsing the Site or using the APP, you consent to cookies, including profiling cookies. In any case, you can change your cookie preferences at any time. You can also deny consent to the use of any cookies (including cookies installed by third parties) in the table below.
The following table (updated on 17/05/2018) describes the cookies sent to your browser when you access the Site. Any updates will be available on this page.
Third-party technical cookies
• OVH technical cookies with storage time extended until the manual deletion of the cookie.
Analytical cookies
• Google Analytics
Cookie of La Sanfermese s.p.a.
Below are the links to the information and consent forms of third parties, independent data controllers. Through these links, you can collect more information, as well as manage and disable cookies.
How to enable or disable cookies on your browsers:
You can block the acceptance of cookies by your browser. However, this operation could make it less efficient or prevent access to some functions or pages of the Site.
Below are the methods offered by the main browsers to block the acceptance of cookies:
Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Chrome: https://support.google.com/chrome/answer/95647?hl=en
Safari: https://support.apple.com/en-gb/HT201265
Further ways to disable analytical and profiling cookies:
In addition to disabling and/or deleting cookies through the relative settings of your browser, you can disable and/or delete single analytical and profiling cookies by accessing the following sites:
Google Analytics cookie, web analysis service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files stored on computers, to analyze how visitors use a specific website. The information generated by the cookies on the use of the website is then transmitted and stored on Google’s servers. Google uses this information to evaluate your use of the website, compiling reports for operators and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google.
The User can refuse cookies by choosing the corresponding setting in their web browser, but this could prevent or reduce the Site’s features customization according to the User’s preferences. For more information, please consult the Google privacy policy available at the following address: https://policies.google.com/privacy.
To receive information on the processing of personal data by Google Analytics, please see the following address: https://support.google.com/analytics/answer/6004245.
To prevent Google from recording and processing the cookies data relating to the Site use (including your IP address), the User can download and install the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=it.
Using the Site, the User consents to Google processing their data in the manner and for the purposes indicated in the Google privacy policy concerning the use of Google Analytics, accessible at the following link: https://www. google.com/intl/it/policies/privacy/partners/. To disable these cookies, please visit https://tools.google.com/dlpage/gaoptout?hl=.
• Doubleclick cookies: to delete the cookies provided by the Doubleclick platform, please visit https://adssettings.google.com/authenticated.
• Neodata cookies: to delete the cookies provided by Neodata, please visit http://www.neodatagroup.com/it/data-security/neodata-services-privacy-policy/.
- Facebook cookies: to delete the cookies provided by Facebook, please visit https://www.facebook.com/policies/cookies/.
In addition, for the cancellation of other cookies:
- Users based in the European Union can see http://www.youronlinechoices.eu, a website managed by the European Interactive Digital Advertising Alliance (EDAA),
- Users residing in the United States of America can refer to http://www.aboutads.info/choises/.