Information on the protection of personal data.
Art. 13 eu reg. 679 of 27 april 2016
Pursuant to Article 13 of the “European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data” (hereinafter “GDPR”), Newlat Food S.p.A. (VAT No. 00183410653), with registered office in Reggio Emilia, Via J.F. Kennedy No. 16, as Data Controller, is required to provide users who connect to the domain: www.gudofree.it (regardless of the purpose of the connection) with certain information regarding the processing of personal data carried out therein.
For the purposes of this policy, and without prejudice to the definitions alluded to in Article 4 of the GDPR, the following definitions shall apply:
Domain “www.gudofree.it”: the domain, reachable through the world wide web service of the internet network, at the address https://www.gudofree.it, consisting of the data, applications, technological resources, human resources, organisational rules and procedures assigned to the acquisition, storage, processing, exchange, retrieval and transmission of information.
Collection points: areas within the domain www.gudofree.it intended for the collection of personal data.
- Warnings and Protection of Minors
The processing of personal data shall apply the principles of lawfulness, fairness and transparency. Personal data shall be collected for specified, explicit, legitimate purposes (purpose limitation) and shall be adequate, relevant and limited in relation to the purposes for which they are processed (data minimisation). They will always be up-to-date and accurate, and will be kept for a period of time not exceeding what is necessary for the purpose of executing the Contract, without prejudice to the fulfilment of legal and tax obligations that establish longer retention periods (retention limitation). Personal data shall be processed by adopting all appropriate security measures to guarantee its integrity, confidentiality and unavailability to unauthorised third parties (integrity and confidentiality). Unless expressly stated otherwise, the provision of personal data via the collection points on www.gudofree.it is reserved for persons over the age of 18.
- Reference standards and legal bases for processing
The processing operations, which we will explain in detail below, have their legal basis in the rules governing the right to protection of personal data, the right to confidentiality, and finally in those that allow the informed consent to processing operations to be expressed or revoked at any time, namely:
▪ EU General Regulation 679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data;
▪ The informed consent, given in accordance with the applicable legal provisions on the protection of personal data (Art. 6 GDPR).
▪ Fulfilment of contractual obligations undertaken by Newlat Food S.p.A. in favour of the user when subscribing to the Service (Art. 6 GDPR);
▪ Fulfilment of obligations or orders to which the Data Controller is bound by law or by order of the Authority (Art. 6 GDPR).
III. – Nature of the data being processed
III.1. – The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other personal data included in the message. Specific summary information will be progressively reported or displayed on the pages of the site set up for particular services on request. In any case – where required by law – your consent to the processing of your personal data will be requested from time to time.
III.2. – Exclusively after your consent, where necessary, the following categories of personal data concerning the person giving such consent will or may be processed for the purposes indicated.
(a). Common personal data, identification data such as e.g. Name and Surname, Year of birth, Gender, Address, City, Province, E-mail address, Telephone number, Post code, Links to the profiles of the following social networks: Facebook, Instagram and Twitter.
(b). Technical processing The IP number and type of browser used to connect to the domain www.gudofree.it (non-identifying data), automatically recorded by the logical devices for protecting and controlling access to the domain (LOG FILES), shall also be processed. This personal data will be used solely for the purpose of controlling network traffic to the www.gudofree.it domain.
This information is not collected in order to be associated with identified subjects, but by its very nature could allow users to be identified, through processing and association with data held by third parties. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation and is deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the site: except for this possibility, at present, data on web contacts do not persist for more than seven days.
(d). Special categories of personal data In the event that the collection of special categories of personal data ex art. 9 EU Reg. 679/2016 is carried out through the domain www.gudofree.it, the user will be informed in advance and put in a position to express – in the manner required by law – the relevant consent.
- Nature of conferment, sources of data
The provision of personal data is not normally compulsory but, in some cases, it is necessary, and therefore mandatory, in order to benefit from the services and functionalities of the site.
IV.1. Data whose provision is necessary
IV.1.1. The provision of certain personal data is necessary, and therefore compulsory, in order to fulfil specific requests; the user is always free not to provide his or her personal data, but in this case it may be impossible for the Data Controller to fulfil requests, meet requirements or make use, in their entirety, of all the functions available on the site www.gudofree.it.
IV.1.2. The provision of personal identification data is necessary in order to possibly register on the site and receive, along with other benefits, the desired information on Newlat Food S.p.A.’s services.
IV.1.3. This identification data will be processed both on paper and electronically, and will be retained by Newlat Food S.p.A. exclusively for as long as the interested parties maintain their registration on the Site, or for a maximum of 5 years from the last action taken on the Site. After these retention periods, personal identification data will be automatically deleted.
IV.3. Sources of Data
We collect data from you directly, through your interactions with www.gudofree.it.
- Purposes of Processing
Newlat Food S.p.A., in addition to the processing required by law, regulation, or by order of the Authority, will carry out, exclusively with the user’s consent, if necessary, the operations necessary to allow the user to benefit from the services and functionalities of the site www.gudofree.it; specifically
- management of the relationship with Newlat Food S.p.A;
- purposes strictly connected and instrumental to the management of the aforementioned relationship (e.g. for the acquisition of pre-contractual information and to execute services and operations, as contractually agreed)
- purposes relating to the monitoring of the progress of customer relations and the control of credit and fraud risks associated with the services provided by Newlat Food S.p.A;
- to fulfil specific requests made by the data subject.
- Method of processing your personal data
In relation to all the purposes indicated in the preceding paragraphs, personal data will be processed by computer and on paper and processed using pseudonymization and anonymization techniques in order to customize the services that Newlat Food S.p.A. is able to offer. Data processing will be carried out in such a way as to guarantee logical and physical security and confidentiality, and may be carried out by means of manual, computerised and telematic tools for storing, transmitting and sharing data. The logic of the processing will be strictly related to the purposes pursued.
VI.1. Data Retention Policy
In relation to the purposes referred to in point (V.2), i.e. the provision of commercial or promotional information, the related processing, which, in compliance with the provisions of Provv. Doc. web 1103045, of the Italian Data Protection Authority, will not concern sensitive data, will be carried out, by the data controller, subject to prior consent, for no more than 24 months from the collection exclusively on aggregate data.
VI.2. Data security and storage
VI.2.1. Personal data will be stored within the European Union, its security policies are reviewed in accordance with relevant Best Practices. It may happen that data are transferred outside the EU.
VI.2.2. Traceability of Access and Operations. Audit Log
Each access to data will be stored in special Log tables. The relevant information will contain the timestamp of the access, the identifier of the user who accessed the data; the type of data accessed, the user who owns the data, the operation performed, the application from which the access was made.
(E.6). Profiling, automated decision-making
VII. Data recipients and transfers abroad
VII.1. Data Processors and Persons in Charge of the Processing of Data
The following may become aware of your personal data, as referred to in this notice, in their capacity as Data Processors or Persons in charge of processing:
▪ inside Newlat Food S.p.A., the qualified personnel, each within the limits of their skills and duties and on the basis of the tasks assigned and instructions given;
▪ outside Newlat Food S.p.A., third parties, also specifically designated as data processors or persons in charge of data processing – which Newlat Food S.p.A. uses for various services and exclusively to perform such services – each within the limits of their skills and duties and on the basis of the tasks assigned and instructions given.
VII.2. Communication (to specific external parties) of data
Newlat Food S.p.A., for ordinary management, accounting and administrative activities, may communicate your personal data, after obtaining your consent in accordance with the law, where required, in compliance with security measures, to third party service providers for the sole purpose of providing the requested service, such as: postal service companies, legal and notary firms, consultants, also in associated form, other service companies, as well as to other subjects in compliance with any legal obligations (such as insurance companies, police forces, judicial authorities, etc.). The list of such parties to whom the data may be communicated is available at the Data Controller’s offices.
VII.3. Transfer of personal data abroad
Newlat Food S.p.A. does not transfer personal data outside the EU on its own initiative. However, some third parties, service providers, may have their servers physically located in territories outside the EU (such as email providers). In such cases, the transfer of data abroad will take place exclusively within the scope of and in compliance with EU Reg. 679/2016 Art. 44 ff.
VII.4. Disclosure of data (to unspecified external parties)
Under no circumstances may personal data be disseminated.
VIII. – Rights of the data subject
Articles 15 to 22, GDPR grant data subjects the exercise of specific rights. Article 15 GDPR grants data subjects the right to access and obtain a copy of their personal data. The right to obtain a copy of the data must not infringe the rights and freedoms of others.
With the request for access, the data subject has the right to obtain from Newlat Food S.p.A. confirmation as to whether or not personal data concerning him/her are being processed and to know the purposes and categories of data processed, the third parties to whom the data are communicated and whether the data are transferred to a non-EU country with adequate safeguards. The data subject also has the right to know the storage time of his or her personal data and has the right to request the rectification of inaccurate data and the integration of incomplete data, the deletion (right to be forgotten) under the conditions indicated in Article 17, GDPR, the restriction of processing, the revocation of consent, the portability of data and the right to object, at any time and without having to provide justification, to processing for direct marketing purposes.
The rights may be exercised by e-mail to the address of the Data Protection Officer of Newlat Food S.p.A., or by regular mail to the address below. The Data Protection Officer may need to identify the data subject by asking him/her to provide a copy of his/her identity document.
A data subject who considers that the processing of his or her personal data violates the provisions of the GDPR or internal data protection regulations has the right to lodge a complaint with the Data Protection Authority based in Rome, pursuant to Art. 77 GDPR and/or to take legal action.
To exercise these rights, or to obtain any other information about them and, more generally, about the processing of your personal data, requests may be made by e-mail to the following address: firstname.lastname@example.org ; – by ordinary mail to Newlat Food S.p.A. (P. IVA 00183410653), with registered office in Reggio Emilia, Via J.F. Kennedy n. 16.
- Withdrawal of Consent Privacy Questions Access and Acknowledgement
You may revoke your consent to the processing of your personal data at any time by notifying us of your intention. If you have any questions or would like more information on the processing of your personal data or would like to exercise the rights set out in No. VI above, you can send an e-mail to the administrator of the www.gudofree.it website by writing to email@example.com. You can also contact us at the same address for answers regarding the management of information by Newlat Food S.p.A.. Before Newlat Food S.p.A. can provide or modify any information, we may need to verify your identity and answer some questions. An answer from us will be provided as soon as possible.
- Data controller
The data controller is Newlat Food S.p.A. (VAT no. 00183410653), with registered office in Reggio Emilia, Via J.F. Kennedy no. 16.
XI.1. Data Processors
The complete list of Data Processors is available at the Head Office.
This mandatory information is subject to updating, depending on any changes in the applicable legal provisions.