- Data processing
Pursuant to Art. 13 of EU Regulation 679/2016 (“Regulation”), we hereby inform you that your personal data will be processed by Sperlari S.r.l., Via Milano 16 – 26100 Cremona – VAT no. 01350470199 (hereinafter the “Company”) as Data Controller, in manual, paper, computerized or telematic form. In its capacity as Data Controller, the Company stores Users’ personal data in a special server located in Europe and carries out all other processing operations through the staff in charge of this task, or through any external parties responsible for maintenance operations. The database can only be accessed by authorized parties by means of methods that guarantee its protection and confidentiality, thanks to the adoption of security measures designed to prevent data loss, illegal or improper use and unauthorized access. The data storage period is based on the purposes of the processing operations conducted, taking into account the type of data related to each User, their choices, preferences and instructions. Under no circumstances will the duration of storage exceed the time strictly necessary to carry out the planned processing operations and will in any event comply with applicable laws that take precedence over the individual purpose of the processing itself.
- Data Controller
The Data Controller responsible for personal data processing is Sperlari S.r.l., Via Milano 16 – 26100 Cremona – VAT no. 01350470199
- Data Protection Officer – DPO
The External Data Protection Officer – DPO of Sperlari S.p.A. is the lawyer Francesco Polimei, email address: firstname.lastname@example.org
- Data subject to processing
The type of data that is collected and processed varies depending on how the User interacts with the Company (at a point of sale, by telephone, online, etc.).
In particular, the Company may collect and use the following data:
I) Data provided and/or acquired when the User interacts with the Company:
- Personal contact details (name, surname, address, tax and bank details, telephone number, email address and any information the User provides regarding third-parties);
- User profile data (name, IP address, login ID, username, password and/or security question and answer and other registration information);
- Employment information (data provided when applying for a job online or during the recruitment process, curriculum vitae, letter of motivation and/or presentation, vocational training, professional qualifications and any other information provided for the purposes of the recruitment process);
- Order and product information (details of the products that the User searches for and orders online or at points of sale, the date and time of searches, etc.);
- Information describing the User’s characteristics and preferences (age or age group, gender, preferences, date of birth, geographical location, favourite products, hobbies and interests, lifestyle information, etc.);
- Information relating to the User’s feedback (information, comments, suggestions and reviews that the User voluntarily shares with the Company based on their experience with the Company’s products or services);
- Information relating to content and posts produced by the User (photos, videos, personal stories or similar content that the User creates or shares with the Company through websites, applications, fan pages, etc.);
- Information on allergic reactions and/or other health incidents that occur in relation to use of the Company’s products.
- c) Data received and collected from other sources: the Company may obtain information, including personal information, from third parties and sources other than the Company’s website, such as business partners or advertisers. The Company will combine and process the collected information and data in accordance with this Policy and the provisions of the Regulations.
d) Data received from social media and/or advertising partners: the Company may work with social media and digital advertising platforms to simplify account access (e.g. using the User’s Facebook account) and/or to display product advertising on other websites and social media platforms.
In any event, the Company will undertake to only collect and use data strictly necessary for the purposes of the processing.
- Purposes and methods of data processing
Users’ personal data are collected and processed by the Company for the following purposes:
- management of any participation in prize events, loyalty programmes or other forms of incentives, including in order to fulfil contractual obligations;
- sending information, commercial, advertising and/or promotional material relating to the Company’s products using “automated” contact systems (for example, SMS and/or email and/or Whatsapp) and/or by telephone calls with an operator or traditional mail;
- collection of data and information in general and in particular on consumer behaviour and preferences, in order to carry out market research and/or obtain a detailed consumer profile, in order to offer an increasingly efficient and personalised promotional and/or advertising information service; the activities referred to above may be carried out by automated means;
- administrative and/or accounting purposes;
- handling of the request(s) made by the User to Customer Service.
The Company uses Users’ data in accordance with the choices that the User has freely exercised with their consent at the time of their collection or subsequently. In some cases, the data may also be processed without the User’s express consent – in accordance with Article 6 of the Regulations – for example, to fulfil contractual obligations or to fulfil a legal obligation to which the Company is subject, or in cases where the Company has a legitimate interest.
- Provision of data and granting of consent
Provision of data:
- for the purpose referred to in Art. 5 point (i) of this policy, it is necessary in order to participate in any prize events, loyalty programs or other forms of incentive and failure to do so will make it impossible to participate in the above and/or to follow up any winnings;
- for the purpose referred to in Art. 5 point (ii), it is optional. Failure to provide data does not compromise correct use of the website;
- for the purpose referred to in Art. 5 point (iii), it is optional. Failure to provide data does not compromise correct use of the website;
- for the purpose referred to in Art. 5 point (iv), it is mandatory. Failure to provide data makes it impossible to take part in any prize events, loyalty programs or other forms of incentive and/or follow up any winnings;
- for the purpose referred to in Art. 5 point (v), it is necessary in order to allow Customer Service to correctly follow up the request made by the User. Failure to provide data makes it impossible for Customer Service to handle the User’s request, but does not compromise correct use of the site.
Granting of consent to the processing:
- for the purposes referred to in Art. 5 points (i), (iv) and (v), it is not required. The relative use of the services will therefore take place following the simple provision of the data.
- for the purposes referred to in Art. 5 points (ii) and (iii), it is optional and the User is given the possibility to exercise their choice during registration. Failure to give consent does not compromise, in any case, participation in any prize events, loyalty programmes or other forms of incentive.
- Communication and dissemination of data
The User’s data may be communicated to suppliers, collaborators and/or third-party consultants of the Company, which are entrusted with carrying out certain processing operations, within the scope of the purposes set out in point 5, and to this end are appointed as external data processing managers. The data will also be communicated to INTHERA S.p.A., a company managed and coordinated by HCI srl, with registered office in Corso Giulio Cesare 268, 10154 – Turin, enrolled in the Turin Company Register, Tax Code and VAT no. 04742700018. INTHERA S.p.A., the company appointed as data processor, shall process the User’s data for purposes relating to consumer service management, to the extent necessary to respond to the User’s request, deleting the data once it has been processed, as well as for the purposes referred to in point 5 ii), iii) in full compliance with the instructions provided by the Company. The User’s data, provided as part of a promotional activity for one of the Company’s brands, may also be communicated to the Group’s other brands operating in the same product categories to promote their respective products and services. Communication of the data will be limited to Europe and in compliance with current legislation.
The User’s data shall not be disclosed.
For the complete list of Data Processors for the purposes referred to in point 5, the User may send a request to the following email address: email@example.com.
The User’s data may also be shared for legal purposes in order to cooperate with law enforcement agencies and for other legal purposes. Data sharing, in particular, could occur in connection with a legal proceeding, a claim for compensation, in the case of investigations, orders and injunctions, to exercise rights, for security reasons or similar.
In accordance with the law, the Company may share (or receive) Users’ data in the event of an acquisition, merger, sale, reorganization proceedings, insolvency proceedings, including bankruptcy proceedings, or other similar events involving Sperlari S.r.l. The Company shall take the necessary measures to ensure that the data is managed and processed in accordance with this Policy and the Regulations.
- Rights of the data subject
The User, as an interested party in the processing of personal data, may exercise the rights under Articles 15 et seq. of EU Regulation 679/2016, by making an informal request to the Data Controller by writing to the email address firstname.lastname@example.org. This request will be duly answered without delay.
In particular, the User has the right to:
- access personal data relating to them and to obtain all the information concerning the processing of this data and listed in the Regulations, as well as to obtain a copy of this data;
- obtain rectification and integration of, respectively, inaccurate or incomplete data;
- obtain deletion of their data, in the cases provided for in Article 17 of the Regulation;
- obtain limitation of processing in the cases provided for in Article 18 of the Regulation;
- to receive from the Data Controller their personal data in a structured format, in common use and readable by an automatic device and to transmit them to another data controller (so-called portability);
- oppose the processing of personal data concerning them carried out by automated means, including profiling;
- withdraw consent to the processing of data concerning them at any time;
- lodge a complaint to the supervisory authority about the processing of data concerning them, pursuant to Article 77 of the Regulation,
Furthermore, for information and clarifications regarding the processing, the User may contact the Data Protection Manager indicated in point 7 above.
- Minor users
The Company is aware that this website and the services it offers may also be of interest to minors.
Registration is only permitted to Users who are over 16 years of age or a different minimum age established by subsequent amendments and/or additions made to the Regulations under Italian law. If the minor is younger than the age specified by the applicable regulatory sources, registration shall be allowed only if and insofar as consent is given or authorised by the holder of parental responsibility.
Moreover, the Company also encourages parents of minor registered users to register: this allows parents to use the same services and to always be informed about the initiatives that the Company makes available to their children, and thereby verify that they meet their expectations and their educational models and paths. In any case, for services for which consent is obligatory, minors are forbidden to give their consent and the Company will not proceed with any service.
- Liability regime for third-party sites and/or features
Through the Company’s website, links to, or features of, third-party websites (e.g. social networks) that are not owned or controlled by the Company may be provided.
If the User decides to click on these links or to use the above-mentioned features, they must be aware that the Company will not be responsible for the contents or characteristics of third-party sites, applications or features.