Information Statement pursuant to article 13 of the General Data Protection Regulation EU 679/2016 (GDPR)
1. Purpose and legal basis of data processing.
We hereby inform you that Antico Molino Rosso Srl processes your personal data for the following purposes:
Allow and manage the registration process to this website.
Manage and process purchase orders made through the e-shop function of the website www.molinorosso.com, if used.
Deal with any information requests received through the special channels of the website.
The legal basis of data processing for the above purposes is to fulfil contract obligations and the provision of data required to regulate the performance of the services requested and described above (registration to the website, use of the e-shop function and other information requests) that would otherwise not be possible. Furthermore, with the specific consent of the data subject, to be expressed by affixing a flag (ticking or turning on the switch) in the provided boxes, the data can be processed, even for the following purposes:
SEND PROMOTIONAL MATERIALS, namely send our deals and information on sales promotions, advertising materials or sweepstakes through our newsletter or notices. Information may be sent by mail, by text message or by telephone. The consent is free and optional and failure to give consent will not jeopardise the processing of data for other purposes (the legal basis of the processing is the consent of the data subject).
The newsletter of the website molinorosso.com is an automated service that regularly sends information to the email given by the users on products, services and initiatives regarding topics that are normally dealt with in the website.
This service is provided free of charge to whoever makes a request to receive the newsletter by entering their email address in the provided space mentioned above.
The service is available only to users that have never entered their email address in the website to receive information/deals and promotions and it will be the website’s duty to check whether it is the same email.
If a user enters the same email address at a later time to active other services available in the website that require sending the user information by email, said data (email address) will be processed for purposes related to said services and the processing for purposes of sending the newsletter will stop.
Providing personal data for said purposes is optional and failure to do so will not result in any consequences to the user other than not receiving the newsletter. Users may withdraw their consent (and therefore object to the processing) at any time, simply by clicking on the provided link indicated in the email or by writing an email to email@example.com
TRACKING PURCHASING BEHAVIOUR, namely analyse consumer habits and trends, among which the type and frequency of purchases. Emails, text messages or telephone contacts will be sent based on the information received, as well as customised sale offers (e.g. discount vouchers, deals, anonymous feedback questionnaires), based on the expressed preferences. The consent is free and optional and failure to give consent will not jeopardise the processing of data for other purposes (the legal basis of the processing is the consent of the data subject).
MARKET RESEARCH, namely receiving surveys or interviews with the purpose of determining the level of satisfaction of customers based on the quality of the services provided and conduct market research, even by telephone. The consent is free and optional and failure to give consent will not jeopardise the processing of data for other purposes (the legal basis of the processing is the consent of the data subject).
2. Data Controller and DPO (Data Protection Officer).
The Data Controller is Antico Molino Rosso Srl – Via Bovolino, 1 – 37060 Buttapietra (VR), certified email address firstname.lastname@example.org
The Data Controller may be contacted by email to the following email address: email@example.com
3. Data Processors.
As part of its activities and for the above purposes, Antico Molino Rosso Srl may rely on services rendered by third parties operating of behalf of Antico Molino Rosso Srl and according to its instructions, acting as Data Processors. These are entities that provide Antico Molino Rosso Srl processing and instrumental services (e.g. technical management and CRM management, IT services to run the website, etc.). In any case, the processing is conducted in such a manner as to guarantee the confidentiality of the data by adopting the measures envisaged in article 32 of the General Data Protection Regulation with the purpose of preserving the integrity of the processed data and prevent access by unauthorised persons.
4. Type of processed data.
The data collected and processed by the Data Controller are of personal nature pertaining to registered users, namely information through which a person can be identified as natural person (i.e., name, surname, date of birth, address, residence, email address, telephone number, etc.) and with prior consent it may include other information such as, spending habits.
5. Analysing purchasing behaviour for profiling purposes.
Whenever the data subject gives consent to the data processing for TRACKING PURCHASING BEHAVIOUR, the data regarding its purchases, including detailed data on the frequency and quantity and type of purchased products, will be analysed in an automated manner, using special CRM (Customer Relationship Management) software in order to define the buying trends of the data subject. Data is analysed by creating homogeneous groups of individuals (clusters) that have a similar consumer profile, namely that have expressed an interest for similar products or that have similar buying trends. The availability and use of consumer data of users and those of other customers that have given their consent, allow Antico Molino Rosso Srl to get a more in-depth analysis of the demand dynamics and hence allowing the preparation of promotional offer plans. This allows us to send the user sale offers that are dedicated to customer clusters that have similar spending habits. In this way, users can benefit from dedicated offers.
6. Processing methods and duration.
Data will be processed in full compliance of principles of confidentiality, correctness, need, pertinence, lawfulness and transparency as set out by the GDPR for the necessary time to pursue the purposes for which the data was gathered or in case of purchase of goods, for the time required to complete the contract conditions and fulfil the preservation obligations set out by applicable tax and administrative laws. Data processing for purposes of SENDING PROMOTIONAL MATERIALS, possible with the consent of the data subject, will take place for a maximum period of 24 months. Data processing for purposes of READING PURCHASING PREFERENCES, possible with the consent of the data subject, will take place solely for purchase data with a historical depth of no more than 12 months and through decisional automated processes (CRM software).
7. Transferring personal data outside the EU.
The data of the data subject may also be processed by providers of IT services in their capacity as Data Processors outside the EU. In compliance with regulations on data transfer to countries outside the EU, if necessary, Antico Molino Rosso Srl undertakes to draw-up agreements that can guarantee a proper level of protection and sign the “standard contractual clauses” adopted by the European Commission.
8. Rights of the data subject.
The data subject has the rights envisaged in article 15 and subsequent articles of the GDPR. The Data Subject may exercise its rights at any time by sending an email to firstname.lastname@example.org or by writing to “Antico Molino Rosso Srl – Via Bovolino, 1 – 37060 Buttapietra (VR)” and may request Antico Molino Rosso Srl the following:
- Receive confirmation on the existence of your personal data, know the processing purposes and their scope of circulation and access to their content
- Update, modify or rectify your personal data
- Request their erasure, transformation in anonymous form, the blocking of data processed in breach of law or limit their processing
- Object to the processing for legitimate reasons, including profiling
- Object to the processing of data for the purpose of sending advertising or direct sales materials or to conduct market research or business communications
- Withdraw your consent, where given, without prejudice to the lawfulness of the data processing based on your consent given before the withdrawal
- Receive copy of the data provided and request for said data to be transferred to another data controller
In the event of a breach of your rights, contact the competent control authorities pursuant to article 77 of the GDPR, notwithstanding your right to contact legal authorities directly (article 79 of the GDPR).