PRIVACY POLICY

1. HOLDER OF THE TREATMENT

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The Data Controller of Personal Data is the Vera Agricultural Cooperative Society (“Vera” and / or “Owner”) with a registered office in Genzano di L. - C.da Ripa D’api, in the person of its pro tempore legal representative.

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2. DATA PROTECTION MANAGER - DPO

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In compliance with the Regulation, the Data Controller has identified and appointed the Data Protection Officer (DPO), with supervising compliance with the Regulation and acting as a contact point with the subjects concerned by the treatment. as well as with the Guarantor for protecting personal data. You can contact the DPO at the e-mail address info@pastaraguso.it

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3. PERSONAL DATA PROCESSED

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• Personal data (such as name, surname, date of birth, age, sex, etc.)

• Contact details (e-mail, address, telephone number)

• Geo-localization and / or Internet browsing data (including “IP” addresses) collected through the cookies installed on your computer or mobile device (for more information, see the Cookie Policy)

• Bank data useful for managing the commercial relationship

• Photographic images and / or video footage, collected on the occasion of participation in promotions, contests and institutional events, events, exhibitions, exhibitions, museum contexts and installations.

•  Data relating to your interactions with our websites, apps and / or smart coffee machines such as, for example but not limited to, i) data relating to your device following the download of our App and use of notifications on the publication of new ones contents, initiatives and updates; ii) participation in questionnaires, initiatives, contests, promotions, events (also through our social channels); iii) registration of the coffee machine and / or free coupons; iv) usage data of the smart coffee machine.

If a request is sent through the “Contact Us” section of the Site or the Vera App, the provision of some Personal Data is necessary for Vera to meet the requests, so the relevant fields in the registration form are marked as mandatory.

Besides the aforementioned categories of Personal Data, further data directly provided by you (the so-called “Contributions”) and shared on the pages of the Social Networks dedicated to Vera’s brands (Facebook, Twitter, Instagram, etc.) may be processed, for the management of which we refer to the third parties that provide these services. Among the data collected through the Social networks there are, for example likes, comments, images and any content and information that you may have published on the pages of the Social Networks dedicated to products of the different Vera brands.

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4. PURPOSE AND LEGAL BASIS OF THE PROCESSING

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According to the needs related to access to the various sections of the Vera Sites (and without prejudice 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 the Personal data and related legal bases:

Registration via website / APP: the registration procedure, by creating an account or using an existing social network account, is aimed at allowing the use of the Vera portal as a “Registered User” and to access a series of exclusive services offered through the same applications. The provision of data is optional. The legal basis of the processing is the execution of pre-contractual measures of which the interested party is a party.

With registration through the APP, it will request authorization to receive notifications regarding the publication of new content, initiatives, events, promotions, etc. The legal basis of the processing is the consent of the interested party. You can always change your mind and change the settings regarding receiving such notifications directly from your device in the “Settings” and “Notifications” section.

In case of registration or access through your social network account, we may have access to some additional personal data regarding those provided when registering on the portal, based on the authorizations you have provided to the social network itself and to which reference should be made for the policies on the management of your privacy.

Purchase of products: through our Website / APP you can purchase Vera products both as a Registered User (and in this case you will not have to re-enter all your Personal Data at each purchase) and as an Unregistered User (re-entering from time to time all the data needed to complete the purchase). Both cases will involve the processing of your Personal Data.

It will process your Personal Data in order to manage orders and payments and to fulfill the consequent administrative-accounting obligations as well as to contact you for any communications relating to the purchases themselves (eg information on the progress of your orders). The provision of data is necessary to complete the purchase order. The legal basis of these treatments is the execution of the Contract to which the interested party is a party.

Management of requests: Personal Data will be collected in order to respond to requests sent to us via email, website and / or social media such as, for example but not limited to, those relating to maintenance / repair activities / replacement of coffee machines and requests relating to products and initiatives of the various Vera brands. The legal basis of these treatments is the legitimate interest of the owner.

It may also provide these services through the video chat / call activity. Here, the support via video chat / call will be activated at the user’s discretion, will take place only in live mode and there will be no recording of their content.

Additional purposes:

Marketing: subject to 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, subscribe to the newsletter. The legal basis of this processing is the consent of the interested party, which can be revoked.

· Participation in competitions, prize events: we may process your Personal Data in order to allow your participation in competitions and prize operations. The legal basis for the processing of data for participation in competitions and prize operations is the execution of pre-contractual measures of which the interested party is a party.

Profiling: subject to your express consent, we may process your Personal Data for profiling purposes, i.e. to analyze or predict your tastes, potential habits and consumption choices in order to offer you products, services, promotions and personalized commercial communications. The legal basis of this processing is the consent of the interested party, which can be revoked.

It could also carry the profiling activity out through the use of proprietary and third-party cookies. We therefore invite you to read our Cookie Policy. This treatment can be carried out on condition that you provide further specific and optional consent.

Outside of the previous hypotheses,

Purpose of analysis: the Personal Data provided by you in the interaction with the Vera world and the information relating 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 Vera and conducting statistical analyzes on the composition of the database itself. The legal basis of the processing is the legitimate interest of the data controller.

Any further purpose in relation to which you have expressly given your consent, which can be revoked at any time.

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5. NATURE OF THE ASSIGNMENT

The provision of your Personal Data is optional. However, their failure to communicate could affect the ability to use some services (eg. To place orders and purchases, to take part in competitions and prize operations; to send newsletters, etc.).

We will report the mandatory or optional nature of the provision from time to time through the use of symbols (eg “*”) placed alongside the information whose provision is mandatory to pursue the respective purpose.

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6. METHOD OF TREATMENT

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Your Personal Data will be processed under the current Privacy Law, both with the aid of electronic and automated means and with manual methods, with logic strictly related to the purposes of the processing, through the databases, the electronic platforms managed by Vera or by third parties (appointed as Data Processors), the integrated IT systems of Vera and the aforementioned third parties, and / or websites owned or used by Vera.

Your data will be processed in a manner designed to guarantee maximum security and confidentiality and only by persons trained and allowed to process them. The Data Controller adopts adequate technical and organizational measures to guarantee a level of security adequate 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.

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7. DATA ADDRESSES

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In order to ensure compliance with the principles of necessity and proportionality of the processing, we have identified different retention periods of Personal Data in relation to the individual purposes pursued:

- Registration on the website / APP: The Personal Data you provide to register on the website / APP will be kept for the entire duration of your registration on the portal itself. In case of inactivity for 24 months, your account will be deleted.

For owners of smart coffee machines, the account will be active for the duration of use of the machine. In the event of non-use of the same for 24 months, your account will be deleted and the data collected by the machine will be anonymized.

- We will keep the billing data for a period to ensure the correct execution of the contract and for a further 10 years to fulfil the related administrative and tax obligations.

- We will keep The data collected for the management of competitions and prize operations for the entire duration of the prize operation and for a period to ensure its correct execution. Without prejudice, to fulfill administrative and tax obligations in relation to which the data retention period is that required by law.

- The data collected for profiling and marketing purposes, for which you have given your consent to the processing, will be kept for a period not exceeding 12 (profiling) and 24 months (marketing), respectively, or any other period showed by the supervisory authorities. If you have not provided the aforementioned consents, your personal data will be anonymized and used for statistical analysis activities.

- The data collected to manage and responding to requests in relation to products and initiatives of the various Vera brands and the data provided in the interaction with the Vera world will be kept for the period necessary to process the requests and subsequently deleted if not there is no further contact, except for any administrative obligations (for example, the request concerning a complaint must be kept beyond the period of management of the same for administrative purposes).

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8. DATA RETENTION PERIOD

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Al fine di assicurare il rispetto dei principi di necessità e proporzionalità del trattamento, sono stati individuati diversi periodi di conservazione dei Dati Personali in relazione alle singole finalità perseguite:

-          Registrazione al sito web/APP: I Dati Personali da Lei forniti per effettuare la Registrazione al sito web/APP saranno conservati per tutta la durata della Sua registrazione al portale medesimo. In caso di inattività per 24 mesi il Suo Account verrà cancellato.

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.

-          I dati di fatturazione saranno conservati per un periodo di tempo atto a garantire la corretta esecuzione del contratto e comunque per ulteriori 10 anni ai fini dell’assolvimento dei connessi obblighi amministrativi e fiscali.

-          I dati raccolti per la gestione di concorsi ed operazioni a premio, saranno conservati per tutto il periodo della durata dell’operazione a premio e per un periodo di tempo atto a garantire la sua corretta esecuzione. E’ fatto salvo l’assolvimento degli obblighi amministrativi e fiscali in relazione al quale il periodo di conservazione dei dati è quello previsto per legge.

-          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.

-          I dati raccolti a fini di gestione di e risposta a richieste in relazione a prodotti e iniziative dei diversi marchi di Vera ed i dati forniti nell’interazione con il mondo Vera verranno conservati per il periodo necessario ad evadere le richieste e successivamente cancellati ove non intercorra alcun ulteriore contatto, salvo eventuali obblighi amministrativi (per esempio, la richiesta avente ad oggetto una lamentela dovrà essere conservata oltre il periodo di gestione della stessa a fini amministrativi).

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9. DATA OF MINORS

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Vera rarely intend to collect Personal Data from minors or deliberately establish communication with them. For this reason, we encourage parents to actively monitor the online activities of children under the age of sixteen.

However, if we have to contact a child under the age of 16, the consent of the parents or those exercising parental responsibility will be required, except by answering a question from the latter or resolving your request.

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10. RIGHTS OF THE INTERESTED PARTY

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You may exercise the rights provided for in Articles 15 and following of the Regulation, including:

a) the right to get confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

b) the right to withdraw the consent given by you in relation to the purposes of the processing;

c) the right to get access, rectification, cancellation, limitation of the processing and portability of personal data;

d) the right to object to the processing you want;

e) the right to appeal to the competent supervisory authority if you believe that the processing of your data is contrary to the legislation in force.

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11. METHOD OF EXERCISE OF RIGHTS

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If you wish to exercise the aforementioned rights, or wish to receive further clarifications regarding the processing of your personal data, you can write to the e-mail address: info@pastaraguso.it or to the address of the Data Controller’s registered office, located in C.da Ripa D’Api, 85013, Genzano di L. (PZ).