PRIVACY POLICY
Information on Personal Data Protection.
Art. 13 Reg. EU 679 of 27 April 2016
In accordance with 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”), FLAVOMEL.COM, as the Controller, is obliged to provide users who
connect to the www.flavomel.com domain (regardless of their purpose in
connecting) with information relating to the personal data processing carried
out therein.
This document represents the “Privacy Policy” (subject to appropriate future
updates) of this website. For the purposes of this statement, without affecting
any of the definitions covered by article 4 of the GDPR, the term:
FLAVOMEL.COM Domain: refers to the domain at the address https://www.FLAVOMEL.COM, which can be accessed via the Internet’s world wide web service, made up of the data, applications, technological resources, human resources, organisational regulations and procedures in place for the purpose of acquiring, saving, processing, exchanging, recovering and transmitting information.
Data collection points: areas within the flavomel.com domain used for the collection of personal data.
I. Notices 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 to what is necessary in relation to the purposes for which
they are processed (data minimisation). They shall always be kept up to date
and accurate and kept for no longer than is necessary for the purposes of
implementing the Contract, subject to compliance with legal and fiscal
requirements which may call for longer storage periods (storage limitation). The
personal data shall be processed using all appropriate security measures to
ensure their integrity, confidentiality, and prevention of access by
non-authorised third parties (integrity and confidentiality). Where not
expressly stated otherwise, the provision of personal data through the data
collection points present on the website WW.FLAVOMEL.COM is reserved exclusively for persons of
legal age.
II. Reference standards and legal grounds for
processing.
Processing operations, which we shall describe in detail below, have their
legal basis in the rules which govern your right to the protection of your
personal data, in those which govern your right to confidentiality, and finally
in those which allow you to grant or withdraw your consent to processing
operations at any moment, namely:
- General Regulation EU 679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data;
- Your informed consent, expressed in compliance with the existing legal provisions regarding the protection of personal data (Art. 6 GDPR).
- Fulfilment of the obligations or orders which the Data Controller is obliged to observe by law or by an order of the Authority (Art. 6 GDPR).
III. – Nature of the data subject to processing.
III.1. – The optional, explicit and voluntary sending of an
e-mail to the addresses provided on this site will lead to the subsequent
acquisition of the sender’s address, which is necessary to allow a response to
requests, as well as any other personal information contained in the message.
Specific brief notices shall be shown or displayed from time to time on the
pages of the site set up for special services by request. In any case, where
required by law, you will on each occasion be required to consent to the
processing of your personal data.
III.2. – Only after your consent, and where necessary, the
following categories of personal data pertaining to you can and shall be
processed for the purposed indicated:
(a). – General personal data, identifying data.
Such as, for example, Name and Surname, Birth year, Gender, Address, City,
Province, Email address, Telephone number, Post code, Links to profiles on the
following social networks: Facebook, Instagram and Twitter.
(b). – Technical processing.
Your IP number and the type of browser that you use to connect to the flavomel.com
domain (non-identifying data) are also processed, being automatically recorded
by the logical protection and security devices for domain access (LOG FILES).
Such personal data shall be used exclusively for the purposes of controlling
network traffic to the flavomel.com domain.
This is information that is not collected to be associated to the identified
data subject but, due to its nature, could be used to identify users through
processing and associating it with information held by third parties. Such data
is used solely to formulate anonymous statistical information concerning the
use of the site and to ensure that the site is functioning properly and is
deleted immediately after it has been processed. The data in question may be
used to investigate the parties responsible for any cybercrimes committed
against the site; apart from in this circumstance, online contact data is not retained
for more than seven days.
(c). – Cookies.
In addition, FLAVOMEL.COM anonymously processes and analyses data about the
pages of the FLAVOMEL.COM domain that you visit, detected through files called
cookies. By using this technology, (which allows your navigating
preferences to be learned by monitoring the areas of the FLAVOMEL.COM domain
already visited on previous occasions) FLAVOMEL.COM can customise its
services to suit your needs without going through unnecessary
registrations. (A cookie consists of a series of data sent by a Website to
a browser. This data may also be stored on the computer through an anonymous
tag which identifies the computer but not the user. Some FLAVOMEL.COM pages use
cookies sent by FLAVOMEL.COM or by third parties, and other technologies, to
offer a better navigation service on the Website. You can set your browser to
receive a warning before a cookie is transmitted, thus offering you the chance
to accept or reject it. It is also possible to completely disable cookies. Some
Websites may not work correctly with cookies disabled). For more detailed
information on the use of cookies on the flavomel.com website, you can consult
our Cookie Policy available here.
(d). – Special categories of personal data.
In the case that special categories of personal data as per art. 9 Reg. EU
679/2016 are collected through the FLAVOMEL.COM domain, you will be given prior
notice of this and given the opportunity to grant the necessary consent in
accordance with the law.
IV. – Nature of data provision, data sources.
It is not generally obligatory to provide your personal data, however, in some
cases, it is necessary in order to allow you to make use of the services and
functions on the site and is therefore obligatory.
IV.1. – Data which it is necessary to provide.
IV.1.1. – Certain personal data is necessary to carry out your
specific requests, and it is therefore obligatory to provide them. You are
always free to refrain from providing your personal data, but in such a case it
may be impossible for the Controller to fulfil your requests, respond to your
needs, or allow all the functions available on the flavomel.com website to be
used fully.
IV.1.2. – It is necessary to provide identifying personal data
to:
- (a). – be able to register on the website and receive, as well as the other advantages, the desired information on FLAVOMEL.COM products, services and initiatives.
IV.1.3. – Such data shall be processed both
in paper and electronic format and shall be kept by FLAVOMEL.COM solely for
such time as the data subject maintains their membership of the Website, or for
a maximum term of three years after the last action performed on the Website.
After those storage times have passed, the identifying personal data shall be
automatically deleted.
IV.2. – Data used for authentication.
Once you have completed registration, during which you can choose your access
credentials – including your password, known only to you – you may access the FLAVOMEL.COM
website from a mobile device or a desktop, using the fields provided to insert
your chosen, personal authentication credentials, which you should guard with
the greatest care.
We recommend that you choose a password with the following minimum
characteristics: a length of no less than eight characters, including at least
one special character. If you forget your password, the recovery process
consists of a link allowing you to reset it autonomously. Authentication data
will be encrypted from the first time they are used and FLAVOMEL.COM will not
be able to learn them in any way.
IV.3. – Data Sources.
We collect your data directly from you, through your interactions with the
website www.FLAVOMEL.com.
V. Purposes for the Processing.
In addition to the processing which is necessary under the obligations of the
law, the regulation, or which come from an order of the Authority, FLAVOMEL.COM
will carry out, if necessary and exclusively with your consent, the operations
necessary to allow you to take advantage of the services and functions of the
www.FLAVOMEL.com website, namely:
- managing your relationship with FLAVOMEL.COM;
- purposes strictly connected and instrumental to the management of the above-mentioned relationship (such as the acquisition of pre-contractual information and to provide services as contractually agreed);
- purposes related to the analysis of information obtained in order to propose, through newsletters and/or promotional or advertising-related information sent by FLAVOMEL.COM, products and/or services from FLAVOMEL.COM or third parties which FLAVOMEL.COM believes may be of interest to you, as well as to allow FLAVOMEL.COM to carry out opinion surveys;
- purposes related to monitoring trends in customer relations and monitoring credit risks and fraud in relation to the services offered by FLAVOMEL;
- fulfilling specific requests by the data subject.
VI. Personal data processing methods.
With regard to all the purposes outlined in the above paragraphs, your personal
data will be subject to computerised and on-paper processing, conducted through
specific computer procedures in order to personalise the services which FLAVOMEL
can offer you. The data will be processed in a way that ensures their physical
and logical security and confidentiality, and this may be carried out using
manual, computerised and remote tools suitable for storing, transmitting and
sharing the data. Processing logics are strictly linked to the purposes to be
achieved.
VI.1. – Data Retention Policy.
In relation to the purposes referred to in letter (V.3), namely the proposal of
commercial or promotional information, such processing – which, in accordance
with the provisions of web Document 1103045 of the Italian Authority for the
Protection of Personal Data, shall not make use of sensitive data – shall be
carried out by the data controller, with the subject’s prior consent, for no
more than 24 months after data collection exclusively on aggregate data.
VI.2. – Data security and storage.
VI.2.1. – Your personal data will be stored within the
European Union, and security policies in this regard have been revised in
accordance with the sector’s Best Practices.
VI.2.2. – Access and Operations Traceability. Audit Log.
Each instance of access to the data is stored in specific Log tables. This
information contained in this record will include the access timestamp, the
identification of the user who accessed the data, the type of data which was
accessed, the user who owns the data, the operation carried out, and the
application from which access was made.
(E.6). – Profiling, automated decision-making;
Beyond what is necessary to allow us to enact the functions allowing you to
take advantages of the services offered on the website, with the exception of
the provisions set out in our cookie policy, we will not carry out profiling
operations in relation to the data collected through this website.
(E.7). – Data Protection Impact Assessment.
In relation to the personal data processing operations linked to its website’s
operation, and with the aid of the specific assessment tool made available by
the French Authority for the Protection of Personal Data (Commission Nationale
de l’informatique et des libertés), FLAVOMEL is preparing its own Data
Protection Impact Assessment (DPIA) the results of which will be available upon
request by the data subject.
VII. – Data recipients and transfer overseas.
VII.1. – Data processing managers and officers.
The following persons, in their roles as processing Managers or Officers, may
come to know of the personal data covered by this document:
- within FLAVOMEL, qualified personnel, each one in a limited way according to their own responsibilities and duties and on the basis of the tasks and instructions given to them.
- outside of FLAVOMEL, third parties, who have also been designated as processing Managers or Officers, used by FLAVOMEL for various services and exclusively to fulfil those services, each one in a limited way according to their own responsibilities and duties and on the basis of the tasks and instructions given to them.
VII.2. – Communication of the data (to specific
external parties).
For its ordinary activities of management, accounting and administration, FLAVOMEL
may communicate your personal data – subject to obtaining your prior consent,
where required, in accordance with law and in compliance with security measures
– to subcontractors for services for the sole purpose of performing the service
requested by you, such as: – postal service companies, – legal and notarial
offices, – consultants, including associates, – other service companies, as
well as other parties in compliance with any legal obligations (such as
insurance institutions, police forces, judicial authorities, etc.). The list of
parties to whom the data may be communicated is available at the headquarters
of the Data Controller.
VII.3. – Transfer of personal data overseas.
FLAVOMEL.COM does not transfer personal data overseas of its own initiative.
However, some third party service suppliers may have their servers physically
located overseas (such as, for example, email service providers). In such
cases, the transfer of data overseas shall take place exclusively under the
terms of and in compliance with Reg. EU 679/2016 Art. 44 et seq.
VII.4. – Dissemination of the data (to non-specific external parties).
In no case may personal data be disseminated.
VIII. – Rights of data subjects.
Articles 15 to 22 of the GDPR grant data subjects certain rights to be
exercised. Article 15 of the GDPR grants data subjects the right to access
their own personal data and to obtain a copy thereof. The right to obtain a
copy of the data shall not adversely affect the rights and freedoms of others.
By requesting access, the data subject has the right to obtain confirmation
from FLAVOMEL.COM as to whether or not personal data concerning him or her is
being processed and to know the purposes of the processing, the categories of
data concerned, third parties to whom the data has been communicated, and
whether the data has been transferred to a country outside of the EU with
suitable safeguards. The data subject also has the right to know the storage
times of their personal data, and has the right to ask for the rectification of
inaccurate data and the completion of incomplete data, for erasure (the right
to be forgotten) under the conditions outlined in art. 17 of the GDPR, for the
restriction of processing, for the withdrawal of consent, and for data
portability and has the right to object, at any moment and without the need to
provide a reason, to processing for the purposes of direct marketing.
These rights may be exercised via an email to the address of FLAVOMEL.COM’s
Data Protection Officer, or via ordinary post to the address given below. The
Data Protection Officer may need to ensure the identity of the data subject by
requiring him/her to provide a copy of his/her identification.
A data subject who believes the processing of his/her personal data is in
violation of the provisions of the GDPR or national legislation regarding the
protection of personal data has the right to lodge a complaint with the Italian
Authority for the Protection of Personal Data, which has its headquarters in
Rome, in accordance with art. 77 of the GDPR, and/or to appeal to the judicial
Authority.
To exercise these rights, or to obtain any further information regarding these
rights or, more generally, the processing of your personal data, requests can
be sent via email to the following address: executive@flavomel.com; IX.
Withdrawal of Consent, Privacy Enquiries, Access and Reply
You have the right, at all times, to withdraw your consent to the processing of
your personal data, communicating your decision to us. If you have questions or
wish to have more information regarding the processing of your personal data or
to exercise the rights described above in point no. VI, you can send an email
to the FLAVOMEL.COM Website administrator by writing to executive@flavomel.com.
You can contact us at the same address to receive replies regarding FLAVOMEL.COM’s
management of information. You may need to verify your identity and answer some
questions before FLAVOMEL.COM will be able to supply you with, or modify, any
information. We will respond as soon as possible.
X. – Data Controller
The Data Controller is FLAVOMEL.COM