10ALPIATTO SRL, C.F. 02164470664, with registered office in Tagliacozzo (AQ), Via degli Ontani no. 11 (hereinafter the “Company”), as Data Controller (hereinafter the “Controller”) pursuant to EU Regulation 679/2016 (“Regulation”) as well as Legislative Decree 196/2003 and subsequent amendments and additions on the protection of personal data (“Code”), hereby informs you that it will process your personal data in accordance with the aforementioned legislation and in the manner and for the purposes set out below. This Privacy Policy concerns the data processing activities carried out by the Company in relation to the personal data of users who browse the mobile application for Android and iOS devices named “10ALPIATTO” (hereinafter the “App”).

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INDEX

Below we provide the index of this Privacy Policy so that you can easily find information regarding the processing of your personal data.

1. DATA CONTROLLER

2. PERSONAL DATA SUBJECT TO PROCESSING

3. PURPOSES OF THE PROCESSING

4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING

5. RECIPIENTS OF PERSONAL DATA

6. TRANSFERS OF PERSONAL DATA

7. RETENTION OF PERSONAL DATA

8. DELETION OF PERSONAL DATA

9. DATA SUBJECT RIGHTS

10. AMENDMENTS

11. CONTACTS

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1. DATA CONTROLLER

The Controller of your personal data is 10ALPIATTO SRL, Tax Code 02164470664, with registered office in Tagliacozzo (AQ), Via degli Ontani n. 11.

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2. PERSONAL DATA SUBJECT TO PROCESSING

Depending on the specific case and within the limits of the purposes set forth below, the Controller processes the following categories of personal data:

• personal data (e.g., name, surname, place and date of birth, tax code);

• contact data (e.g., address, telephone number, e-mail);

• contract data (e.g., services offered, execution methods);

• billing and payment data;

• IP address, cookies and similar online trackers.

For information regarding the cookies used by the App, the data subject is invited to consult the specific “cookie policy” section.

 

3. PURPOSES OF THE PROCESSING

Users’ personal data will be lawfully processed by the Controller for the following purposes:

3.1. to enable the performance of a contract to which you are a party or the implementation of pre-contractual measures taken at your request and, in any case, to allow navigation of the App and the provision of services; some of these services necessarily involve the processing of data for profiling purposes, as they are personalized services.

3.2. to comply with any obligations under current legislation and fulfill requests from authorities;

3.3. to carry out direct marketing activities for products/services similar to those you have purchased;

3.4. to carry out internal statistical surveys within the Controller’s commercial activities. Such surveys will be used solely for internal reporting purposes, in the Controller’s interest to improve its products and/or services and to implement more efficient management; these statistical surveys may involve the processing of data also in pseudonymized and/ or aggregated form and are, in any case, not aimed at carrying out direct operations or activities on service users (e.g., marketing campaigns, profiling and/or disclosure to third parties);

3.5. to send you informational and promotional material relating to the activities, services and products of the Company and its business partners, or surveys to improve the service (“customer satisfaction”). These communications may be made via email or SMS, paper mail and/or phone calls with operator and/or through the official pages of the Company on social networks, or even via push notifications through the App;

3.6. to analyze your interests, habits and consumption choices, also for the purpose of sending you personalized informational and promotional material on the services offered (“profiling”);

3.7. to transfer or share personal and profiling data with business partners, social media websites, advertising networks, data aggregators and other third parties operating in the food/wine/gastronomic sector, for marketing/promotional/ commercial purposes and in connection with possible corporate transactions.

Specific security measures are observed to prevent the loss of data, unlawful or improper use, and unauthorized access.

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4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING

The legal basis for the processing of personal data for the purposes set out in Section 3.1 is Article 6(1)(b) of the Regulation ([...]the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract), as the processing is necessary for the provision of the services. As for the processing of your data for profiling purposes related to the provision of the services, as described in Section 3.1, such processing is based on Article 22(2)(a), as it is necessary for the conclusion or performance of a contract between the data subject and the controller. The purpose referred to in Section 3.2 constitutes a legitimate processing of personal data under Article 6(1)(c) of the Regulation ([...]the processing is necessary for compliance with a legal obligation to which the controller is subject). Once the personal data has been provided, the processing becomes necessary to fulfill legal obligations to which the Company is subject. The provision of personal data for the processing purposes mentioned above is optional but necessary, as failure to provide such data will result in the user being unable to access the App and use the services. The processing for the purposes set out in Sections 3.3 and 3.4 is based on Article 6(1)(f) ([...]the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, in particular where the data subject is a child). The Company’s legitimate interest is based on the existence of a relevant and appropriate relationship between the Controller and the data subject and on the data subject’s reasonable expectation to receive information aimed at satisfying their needs (“It may constitute a legitimate interest to process personal data for direct marketing purposes” - see Recital 47 of the Regulation). It is understood that the user has the right to object at any time and free of charge to the processing of their personal data for the purposes described in this paragraph by contacting the Controller. The processing carried out for the purposes set out in Sections 3.5, 3.6 and 3.7 is based on your consent pursuant to Article 6(1)(a) ([...]the data subject has given consent to the processing of their personal data for one or more specific purposes) and Article 22(2)(c) of the Regulation. The provision of your personal data for the purposes of Sections 3.5, 3.6 and 3.7 is therefore entirely optional and does not affect your ability to use the services. Should you wish to object to the processing of your data for these purposes, you may do so at any time by contacting the Controller at the addresses provided in the “Contacts” section of this notice or, where available, through the App settings

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5. RECIPIENTS OF PERSONAL DATA

Your personal data may be shared, for the purposes referred to in Section 3 of this Privacy Policy, with:

• service providers for the management of the Controller’s IT systems and the App;

• legal, accounting and tax consulting service providers;

• companies engaged by the Controller to provide the services;

• users of the App for purposes related to service provision;

• banks and other financial institutions for payment management;

• entities, bodies or authorities to whom your personal data must be disclosed pursuant to legal obligations or orders from authorities;

• within the scope of their respective competences, employees, seconded or agency workers and collaborators of the Controller;

• persons authorized by the Company to process personal data as strictly necessary to perform activities connected to the provision of the services, who are committed to confidentiality or have an adequate legal obligation of confidentiality;

• business partners, social media websites, advertising networks, data aggregators and other third parties operating in the food/wine/culinary sector

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6. TRANSFERS OF PERSONAL DATA

Some of your personal data may be shared with recipients located outside the European Economic Area. The Controller ensures that the processing of your personal data by such recipients takes place in compliance with the Regulation. Indeed, transfers may be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission pursuant to Articles 45 and 46 of the Regulation. Further information may be requested from the Controller at the addresses provided in the “Contacts” section.

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7. RETENTION OF PERSONAL DATA

Your personal data, including any “special categories” of data, will be processed by automated and non-automated means and will be retained for the time necessary to properly fulfill the contract and, in any case, for 10 years from the collection of the data for the purpose of protecting the Company’s rights in judicial and extrajudicial proceedings. More information is available from the Controller under the “Contacts” section.

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8. DELETION OF PERSONAL DATA

Once your account has been deleted, all your personal data associated with the account will be permanently erased, except in cases where retention is required by law or for the protection of legitimate rights. Any residual data will be stored only within the limits and for the durations required by applicable privacy and data protection regulations (e.g. EU Regulation 2016/679 - GDPR).

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9. DATA SUBJECT RIGHTS

Pursuant to Articles 15 et seq. of the Regulation, you have the right to request from the Controller, at any time, access to your personal data, their rectification or deletion, or to object to their processing pursuant to Article 21 of the Regulation. You also have the right to request restriction of processing in the cases provided for by Article 18 of the Regulation, as well as the right to receive the data concerning you in a structured, commonly used and machinereadable format in the cases provided for by Article 20 of the Regulation. Where processing is based on Articles 6(1)(a) and 9(2)(a), you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Requests must be addressed in writing to the Controller using the contact details in the “Contacts” section of this notice. Where the communication of your personal data is a legal or contractual requirement or a requirement necessary to enter into a contract, you are obliged to provide your personal data. Failure to provide such data will make it impossible for the Controller to process your request and provide the services. The Company may use automated systems/processes and an automated decision-making procedure (such as profiling) to offer you the requested services. For example, the Company may promote a specific new product/service based on certain automated criteria taking into account specific needs, the type of activity carried out and previous purchasing behavior. This is done in order to meet the expectations of a group of customers potentially interested in the purchase.

In any case, you always have the right to lodge a complaint with the competent supervisory authority (Italian Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your data is in violation of the applicable law.

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10. AMENDMENTS

The Controller reserves the right to amend or simply update the content of this Privacy Policy, in whole or in part, also due to changes in applicable laws. The Company will inform you of such changes as soon as they are introduced and they will be binding as soon as they are published on the App. The Controller therefore invites you to regularly visit this section to be aware of the most recent and updated version of the Privacy Policy in order to stay informed about the data collected and how the Company uses it.

 

11. CONTACTS

To exercise the rights described in this notice, you may contact the Controller at:

10ALPIATTO SRL

Via degli Ontani n. 11

67069 - Tagliacozzo (AQ)

Italy