La Gritta s.a.s., a company incorporated under the laws of Italy, having its registered office at Calata Marconi, 20 16034 Portofino, GE, Italy. (the “Company”), as data controller, pursuant to Article 13 of the EU Reg. no. 2016/679 (“GDPR”), is committed to protecting and respecting the privacy of the Website users.
• DATA PROCESSING
This policy (together with other documents referred to herein) describes what personal data (“Personal Data”) the Company collects from the Website user and how it processes such personal data.
• The Company may collect information on visits to the Website including, but not limited to, traffic data, location data, weblogs, contact forms and other communication data and the resources that the user may access.
This information will make the users’ visit to the Website easier in the future since the Company might suggest Content or Services depending on the location the user accesses the Website from.
• The Company may collect all the information the user provides by submitting the contact forms (for example, “Send us an Email” or “Quick Contact”), in particular name, surname, e-mail address, Tax Identification/Social Security Number, telephone number, Region, VAT Number, business name.
The provision of the personal information by means of contact forms is not a legal or contractual requirement; however, please note that all the data requests marked with an asterisk (*) are mandatory, since the Company requires this information in order to fulfil and reply to the user’s request. Additional information or personal information can be discretionally provided by the user by filling the contact form. If the user contacts the Company, the Company may keep a record of that correspondence.
• The Company may use personal information for direct marketing via e-mail, if this option has been accepted by the user in the relating contact form. The user may at any time opt-out of receiving future marketing communication.
• The Company may collect personal data when receiving an email by a user.
• When fulfilling the online forms, the user is also requested to give his consent to the data process.
• SCOPE OF THE DATA PROCESSING
The personal data are collected and managed by the Company in order:
• to customize Content or Services according to the user’s preferences;
• to provide customized products;
• to reply to the user’s request and questions and to keep the user informed by e-mail or telephone;
• to send by e-mail further information or communication the user may be interested into;
• to help the Company create, publish and improve the Content and Services in the most appropriate manner for the user;
• to ensure that the Content and Services provided through the Website are delivered in the most effective manner according to the user’s devices;
• to allow the user to interact with the Website, if the user wishes to;
• to further develop and improve the Website, the Company’s Services and systems for a better customer satisfaction.
The use of the information above-mentioned is allowed by legal provisions on the protection of personal data, since it is necessary:
• for the legitimate interests of the Company to pursue the above mentioned scope of the data processing; such interests, in any case, do not result in a conflict with the privacy rights of the users;
• in some cases, to comply with legal and regulatory liabilities of the Company, for example in relation to communication obligation to the authorities, government and regulatory bodies;
• in some cases, to fulfill of actions of public interest and, when the Company uses particular categories of personal data, or to engage, carry out and defend itself in legal actions, or when the data processing regards personal information manifestly of public domain;
• in limited circumstances on the basis of a case by case user’s consent such as, for example, when the user accepts to receive marketing news and communication by e-mail.
The Company does not take decisions only based on automated decision-making, including profiling, which may produce legal effects on the user or similar consequences.
The Company stores the personal data for a period of time necessary for the fulfillment of its legal obligations. The storage period of the personal data depends on the scope according to which the personal data are processed and on the instruments by means of which the data are treated.
However, it is not possible to indicate in this policy the estimate of the storage period of the personal data. The criteria used to determine the applicable period are strictly connected to the time (i) necessary for the accomplishment of the related scope, (ii) necessary for the completion of the business relationship with the user, (iii) accepted by the user and/or (iv) required by the applicable legal provisions.
• DISCLOSURE OF INFORMATION WITH THIRD PARTIES
To ease an efficient use of the user’s data, and to provide the user with the best service and/or opportunities, it may sometimes be necessary for the Company to share information with third parties. However, the disclosure will only occur in the following circumstances:
• to suppliers, contractors and agents: the Company may engage or employ other companies and individuals to perform functions on its behalf. Examples may include hosting and/or maintenance of the Website content or supply of specific functions contained in the Website, supply of marketing services or economic updating required by the user. Such recipients will only have access to data required by them to perform their functions and are not permitted to use such data for any other purposes. These recipients will be subject to contractual confidentiality obligations;
• to judicial or governmental authorities, if and to the extent that the Company believes that they are legally entitled to request them.
• IP ADDRESS AND COOKIES
The Company may collect information about the user’s computer or other electronic devices. This information may include (when available) IP address, operating system and browser type, for system administration. This is statistical data about the Company’s user’s browsing actions and patterns and does not identify the users or any individual.
• DATA TRANSFER ABROAD
Personal data may be transferred and processed in one or more States within the European Union or outside the European Union. A transfer of personal data to a third country outside the EU may take place where the European Commission has decided that the third country ensures an adequate level of protection or where the Company has provided adequate safeguards to preserve the confidentiality of this information.
• DATA SECURITY
Although the Company endeavours to take all steps reasonably necessary to safeguard the personal data, please note that the transmission of information via internet is not totally safe and it is not possible to ensure a complete security of the personal data transmitted to the Website or to third parties; for this reason, any transmission of data occurs at the user’s own risk.
However, the Company applies strict operating procedures and adequate technical and organizational security measures in order to prevent any access, modification, erasure or unauthorized transmission of personal data.
• RIGHTS OF THE USER
Articles from 15 to 22 of the GDPR grant the user, as data subject, certain specific rights, as indicated herein-below:
• right to access and obtain a copy of the user’s personal data:
the user has the right to claim confirmation of the fact that the Company is processing any his/her personal data. In this case, the user can have access to his/her personal data and to some information regarding the processing. In some cases, the user can require to the Company an electronic copy of his/her personal data;
• right to rectification:
in case the user is able to demonstrate that his/her personal data concerning are not correct, the user has the right to ask the updating or the rectification of the data;
• right to be forgotten/ to erasure of the data:
in specific circumstances, the user has the right to obtain the erasure of his/her personal data. The request can be filed at any time and the Company will assess the possibility to accept the request. However, this right is subject to legal duties and obligations that may impose the conservation to the Company. In the event that, pursuant to the legal provisions, the request of erasure of the personal data may be accepted, the Company will proceed to erase the date without undue delay;
• right to object:
although the user’s data processing by the Company is based on the legitimate interest of the Company (without any other reason for the processing), the user has the right to object to the processing modality of his/her personal data implemented by the Company in relation to the user’s specific situation;
• right to withdraw the consent:
since the data processing is based on the user’s consent, the user is entitled to withdraw the consent at any time. The consent withdrawal does not affect the lawfulness of processing based on a consent formerly granted.
• MODALITY OF THE EXERCISE OF THE USER’S RIGHTS
In order to exercise his/her rights, the user can submit an e-mail to the following e-mail address: email@example.com.
It is also possible to lodge a complaint regarding the data processing to the competent supervisory authority.
• MARKETING COMMUNICATIONS
The Company delivers marketing communications by e-mail only if the user has given his consent for this operation.
Usually, the forms used by the Company to collect personal data contain a checkable box to select when the user is willing to receive marketing communication. When marketing communications are sent by e-mail, the user can decide to not receive further communications by clicking on “Unsubscribe” or on the e-mail function to renounce to it. Moreover, it is possible to exercise the withdrawal right at any time by contacting the Company at the following e-mail address: firstname.lastname@example.org and providing the following information: name, e-mail address, telephone number and the marketing communications the user is not willing to receive anymore.
The Company informs that questions, comments and requests regarding this Policy must be submitted to the following e-mail address: email@example.com
It is possible to request a copy of the mechanism regarding a specific transmission of personal data by contacting:
La Gritta s.a.s
Calata Marconi, 20
16034 Portofino GE, Italy
Tel. +39 0185 269126
Last update: 23.05.2019
La Gritta s.a.s. (“La Gritta” or “we”), provide(s) the following information regarding cookies installed on lagrittaportofino.com (“Website”).
WHAT ARE "COOKIES"?
Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. Every time you revisit our website, your web browser sends these cookies back to us so that we can customize your experience to reflect your interests and preferences, or to simply facilitate your signing in to use our services.
WHAT COOKIES DO WE USE?
The cookies we use allow us to recognize each returning consumer and their relevant information so that you do not need to input the same information more than once. They also help us to understand visitor traffic patterns through our website, so that we can enhance its usability.
We may use technical cookies in order to enable you to receive the services that you request via our website. Without these cookies, services that you have asked for cannot be provided.
For example, these cookies may be used to:
- Allow you to access secure areas of our website without having to continually log in to the service;
- Remember previous actions you have taken (such as completing an online form) when navigating back to a page in the same session.
We may use analytical cookies to collect information about how our website, advertisements and email communications are used and to flag to us if an error occurs. These cookies may be used to collect quite detailed technical information such as the last visited Page, the number of pages visited, whether or not email communications are opened, which parts of our website or email communication are clicked on and the period of time elapsed between clicks. While this information may be associated with details such as your IP address, domain or browser information, it is analyzed only in aggregate with information from other users and not in a way that would directly identify you.
For example, these cookies may be used on our website to:
- Analyze and improve the performance and design of our website, advertisements and email communications;
- Calculate the number of responses to our advertisements to improve the effectiveness of our advertising;
- Measure errors presented on our website to improve our service and management complaints.
We may use functional cookies that are not essential but enable various helpful features on our website.
For example, these cookies may be used on our website to:
- Memorize the preferences that you selected on a previous visit to our website, such as, country/language, your interests and the presentation of our website (for instance, layout, font size, colors, etc.), so you do not have to tell us again;
- Memorize answers to questions our website has asked you, such as, not wishing to take part in a customer satisfaction questionnaire, so that you are not asked again;
- Detect if a service has already been offered to you;
- Provide information to allow an optional service to function.
TARGETING OR ADVERTISING COOKIES
Targeting or advertising cookies may be used on our website to deliver advertisements that are more relevant to you and your interests. These cookies may collect quite detailed information about your browsing habits across our website (such as which products and services you have clicked on). They may also be used to recognize when you re-visit our website and/or visit a website that is part of one of our advertising partner’s network.
For example, these cookies may be used to collect information about products or services you have browsed across our website so that:
- Our advertising partners can provide you with adverts on other websites in their advertising network for products and services of your interest;
- We can limit the number of times you see an advert, as well as measuring the effectiveness of an advertising campaign;
- These cookies may be stored and accessed by us and/or our advertising partners.
THIRD PARTY COOKIES
Your use of our website may result in some cookies being stored that are not controlled by us. This may occur when the Page you are visiting includes content displayed by a third party website, and will result in you receiving cookies from these third party services. However, no personal information will be stored in these cookies, unless you are logged into your account.
For example, these cookies may come from:
- Google Analytics;
- other Social Network;
- Reliable operators.
HOW TO ADJUST YOUR COOKIE SETTINGS
Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored.
WHAT HAPPENS IF COOKIES ARE DISABLED?
If you block or erase cookies, we may not be able to restore any preferences or customization settings you have previously specified, and our ability to personalize your online experience would be limited.
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