art. 13 del Regolamento UE 679/2016
Revision March 2021
The processing of your Personal Data will be based on the principles of correctness, lawfulness, transparency, purpose limitation and storage, minimization and accuracy, integrity and confidentiality, in accordance with the provisions of the Regulation.
1. DATA CONTROLLER
The Data Controller is MANOVALE S.R.L (hereinafter “Il Manovale” and/or “Data Controller”) with registered office in Bari – VIA ROBERT SCHUMANN 14 A/4, in the person of the legal representative pro tempore.
2. DATA PROTECTION OFFICER – DPO
In compliance with the provisions of the Regulation, the Data Controller has identified and appointed the Data Protection Officer (DPO), with the task of supervising compliance with the Regulation and acting as a point of contact with data subjects and with the Guarantor for the protection of personal data. The DPO can be contacted at the email address: email@example.com
3. PERSONAL DATA PROCESSED
- Personal data (such as name, surname, date of birth, age, gender, etc.)
- Contact details (e-mail, address, telephone number)
- Bank data useful for the management of the commercial relationship, photographic images and/ or video shooting, collected on the occasion of participation in promotions, contests and institutional events, events, exhibitions, exhibitions, museum contexts and installations in general.
- Data related to your interactions with our websites, apps and/or smart coffee machines such as, but not limited to, i) data related to your device following the download of our app and the use of notifications on the publication of new content, initiatives and updates; ii) participation in questionnaires, initiatives, contests, promotions, events (also through our social channels); iii) registration of the coffee machine and/or the free coupons; iv) data of use of the smart coffee machine.
If a request is sent through the “Contact Us” section of the Site, the provision of some Personal Data is necessary for the Manovale to meet the requests, so the relevant fields of the registration form are marked as mandatory.
In addition to the aforementioned categories of Personal Data, further data may be processed by you directly conferred (the so-called “Contributions”) and shared on the Social Network pages dedicated to Il Manovale (Facebook, Twitter, Instagram, etc.), for which management refers to third parties providing such services. Among the data collected through social media there are, for example, likes, comments, images and in general any content and information that you may have published on the Social Network pages dedicated to Il Manovale products.
4. PURPOSE AND LEGAL BASIS OF THE PROCESSING
According to the needs related to access to the various sections of the Sites Il Manovale (and subject to individual initiatives that involve the provision of specific Personal Data, for which specific information will be published from time to time), the purposes of the processing of Personal Data and its legal bases are indicated below:
· Registration via website/APP: the registration procedure, through the creation of an account or the use of an existing social network account, is aimed at allowing the use of the portal Il Manovale as “Registered User” and to access a series of exclusive services offered through the same applications. The provision of data is optional. The legal basis for processing is the execution of pre-contractual measures to which the data subject is a party..
In case of registration through the APP, permission will be requested to receive notifications regarding the publication of new content, initiatives, events, promotions, etc. The legal basis for processing is the consent of the data subject. You can always change your mind and change the settings for receiving such notifications directly from your device in the “Settings” and “Notifications” section.
In case of registration or access through your social account, we may have access to some additional personal data compared to those provided when registering to the portal, on the basis of the permissions you provide to the social network itself and to which you refer for the policies on the management of your privacy.
· Purchase of products: through our Website/APP you can purchase Il Manovale products both as a Registered User (and in this case you do not have to re-enter all your Personal Data at the time of each purchase) and as a Unregistered User (by re-entering from time to time all the data needed to perfect the purchase). Both cases will involve the processing of your Personal Data.
Your Personal Data will be processed in order to manage orders and payments and to carry out the consequent administrative and accounting tasks as well as to contact you for any communications relating to the purchases themselves (e.g. information on the status of your orders). The provision of data is necessary to complete the purchase order. The legal basis for such processing is the execution of the Contract to which the interested party is a party.
· Request management: Personal Data will be collected in order to respond to requests that are sent to us by email, via website and/or social ovia such as, by way of example but not exhaustive, those related to maintenance/repair/replacement of coffee machines and requests related to products and initiatives of Il Manovale. The legal basis for such processing is the legitimate interest of the controller.
These services may also be provided through the activity of video chat/call. In this case, the support via video chat/ call will be activated at the discretion of the user, will be carried out exclusively in live mode and there will be no recording of their content.
· Marketing: with your express consent, we may process your Personal Data in order to send you commercial communications as well as to invite you to take part in our promotional initiatives, participate in our events, subscribe to the newsletter. The legal basis for such processing is the consent of the interested party, revocable at any time.
· Participation in competitions, prize events, loyalty programs to our brands: we may process your Personal Data in order to allow you to participate in competitions and prize operations, including the loyalty program to our brands. The legal basis for the processing of data for the purpose of participation in competitions and prize-winning operations is the execution of pre-contractual measures of which the data subject is a part, while for loyalty programs to our brands the legal basis for processing is the legitimate interest of the holder.
· Profiling: with your express consent, we may process your Personal Data for profiling purposes, that is to analyze or predict your tastes, potential habits and consumer choices in order to offer you products, personalised services, promotions and commercial communications. The legal basis for such processing is the consent of the data subject, revocable at any time.
Outside of the above assumptions:
· Analysis purposes: the Personal Data you provide in the interaction with the world The Manovale and the information related to the interaction will flow into our database and will be used anonymously to analyze and improve the services offered, evaluate the effectiveness of the activities and initiatives promoted by Il Manovale and conduct statistical analyses on the composition of the database. The legal basis for processing is the legitimate interest of the controller.
· Any further purposes in relation to which you have expressly given your consent, revocable at any time.
5. NATURE OF THE CONTRIBUTION
The provision of your Personal Data is optional. However, their failure to communicate may affect the possibility of using certain services (e.g. to place orders and acquisitions, to participate in competitions and prize-winning operations; sending newsletters, etc.).
The mandatory or optional nature of the contribution will be indicated from time to time by the use of symbols (e.g. “*”) placed alongside the information whose provision is mandatory to pursue the respective purpose.
6. METHOD OF TREATMENT
Your Personal Data will be processed in accordance with the requirements of the current Privacy Law, both with the help of electronic and automated means and with manual methods, with logic strictly related to the purposes of the processing, through the data bases, the electronic platforms operated by Il Manovale or by third parties (appointed Data Processors), the integrated computer systems of Il Manovale and the aforementioned third parties, and/or websites owned or used by Il Manovale.
Your data will be processed in a manner that ensures maximum security and confidentiality and only by persons instructed and authorized to process them. The Data Controller shall take appropriate technical and organisational measures to ensure a level of safety appropriate to the risk of processing..
Personal Data are mainly processed at the offices of the Data Controller and in the places where the Data Processors are located.
7. RECIPIENTS OF THE DATA
I Suoi Dati Personali potranno essere resi accessibili, per le finalità di cui sopra, a dipendenti e collaboratori di Il Manovale.
Il Titolare adotta garanzie idonee a fornire un livello adeguato di protezione pari a quello utilizzato in UE/SEE ed ha stilato un elenco dei Responsabili del Trattamento, costantemente aggiornato, che mette a Sua disposizione contattandolo agli indirizzi riportati al punto 11 della presente Informativa.
I Suoi Dati, infine, potranno essere trasmessi all’autorità giudiziaria ove necessario e nei casi previsti dalla legge.
8. PERIOD OF RETENTION OF DATA
In order to ensure compliance with the principles of necessity and proportionality of processing, several retention periods of Personal Data have been identified in relation to the individual purposes pursued:
– Registration to the website/APP: The Personal Data you provide to register to the website/APP will be kept for the duration of your registration to the portal. In case of inactivity for 24 months your Account will be deleted.
Per i possessori di macchine da caffè intelligenti l’account sarà attivo per la durata dell’utilizzo della macchina. Nel caso di inutilizzo della stessa per 24 mesi il Suo Account verrà cancellato ed i dati raccolti dalla macchina saranno anonimizzati.
– The billing data
– The data collected for profiling and marketing purposes, for which you have given your consent to the processing, will be stored for a period of time not exceeding 12 (profiling) and 24 months respectively (marketing) or the different period, if any, indicated by the supervisory authorities. If you have not given your consent, your personal data will be anonymized and used for statistical analysis activities.
– I dati raccolti per finalità di profilazione e per finalità marketing, per i quali ha fornito il consenso al trattamento, saranno conservati per un periodo di tempo rispettivamente non superiore ai 12 (profilazione) e 24 mesi (marketing) o al diverso periodo eventualmente indicato dalle autorità di controllo. Laddove non abbia fornito i suddetti consensi, i Suoi dati personali saranno anonimizzati ed utilizzati per attività di analisi statistiche.
– The data collected for the purpose of managing and responding to requests in relation to products and initiatives of Il Manovale and data provided in interaction with the world Il Manovale will be kept for the period necessary to process requests and subsequently deleted unless no further contact shall be made, without prejudice to any administrative obligations (for example, the request for a complaint must be kept beyond the management period of the complaint for administrative purposes).
9. DATA OF MINORS
However, in the event that we contact a child under the age of 16, the consent of the parents or parents will be required, except in the case of answering a question from the latter or of resolving a request from him.
10. RIGHTS OF THE PERSON CONCERNED
You may at any time exercise against the Owner the rights provided for by art. 15 and following of the Regulations, including:
a) the right to obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet recorded, and their communication in intelligible form;
b) the right to revoke at any time the consent you have given in relation to the purposes of the processing;
c) the right to obtain access, rectification, erasure, restriction of processing and portability of personal data;
d) the right to object to the processing at any time you wish;
e) the right to appeal to the competent Supervisory Authority, if it considers that the processing of your data is contrary to the legislation in force.
11. ARRANGEMENTS FOR THE EXERCISE OF RIGHTS
In the event that you wish to exercise these rights, or to receive further clarification regarding the processing of your personal data, you can write to the e-mail address: the firstname.lastname@example.org or the address of the registered office of the Data Controller, located in Bari – VIA ROBERT SCHUMAN 14 A/4 70126