Data Controller

PERRERO CAFFÈ SRL – Strada dei Fornero, 4 – 10070 San Carlo Canavese (TO)

Owner’s email address: info@caffeperrero.it

Types of Data collected

The Owner does not provide a list of types of Personal Data collected.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Application.

Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.

Users who have doubts about which Data are mandatory are encouraged to contact the Owner.

Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to further purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability towards third parties

Method and place of processing of the collected Data

Methods of treatment

The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller

Legal basis of the treatment

The Data Controller processes Personal Data relating to the User in the event that one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
• the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• the treatment is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller;
• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the Owner.

The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

The User can check whether one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the beginning

Storage period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the treatment is based on the User’s consent, the Owner can keep the Personal Data for longer until said consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

User rights

Users can exercise certain rights with reference to the Data processed by the Owner.

In particular, the User has the right to:

• withdraw consent at any time. The User can revoke the previously expressed consent to the processing of his Personal Data.
• oppose the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are set out in the section below.
• access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• check and ask for rectification. The User can verify the correctness of his Data and request its updating or correction.
• obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any other purpose other than their conservation.
• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
• receive their data or have them transferred to another owner. The User has the right to receive their Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User’s consent, on a contract of which the User is a party or on contractual measures connected to it.
• propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons connected with their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document

How to exercise your rights

To exercise the User’s rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.

Learn more about treatment

Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Application or related Services by the User.

The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Application could provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System and maintenance logs

For needs related to operation and maintenance, this Application and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Application does not support “Do Not Track” requests.

To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users via one of the contact you have. Therefore, please consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary

Information for California Consumers

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the company that manages this Application and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we” , “our” or “our”).

The provisions contained in this section apply to all Users who are considered consumers who are residents of the state of California, United States of America, pursuant to the “California Consumer Privacy Act of 2018” (such Users are referred to below simply as “you ”, “your”, “you” or “your”), and, for them, these provisions prevail over any other possibly divergent or conflicting provision contained in this privacy policy.

The term “personal information” as defined by the California Consumer Privacy Act (CCPA) is used in this part of the document.

Categorie di informazioni personali raccolte, divulgate o vendute

This section summarizes the categories of personal information we have collected, disclosed or “sold” under the CCPA and the related purposes of the processing. You can find detailed information on these activities in the section entitled “Details on the processing of Personal Data” in this document.

Information We Collect: The categories of personal information we collect

We have collected the following categories of personal information about you: .

We will not collect additional categories of personal information without first notifying you of a new policy

How we collect information: What are the sources of the personal information we collect?

We collect the above categories of personal information, directly or indirectly, from you when you use this Application.

For example, you provide us with your personal information directly when you submit requests through any form on this Application.
In addition, you indirectly provide us with personal information when you browse this Application, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties who work with us in connection with the provision of the Service or the operation of this Application and its features.

How we use the information collected: sharing and communicating your personal information with third parties for operational purposes.

We may disclose your personal information to third parties for operational and service purposes.
In this case, we enter into a written contract with that third party which obliges the recipient of your personal information to keep that information confidential and not to use it for any purpose other than what is necessary for the performance of the contract.

We may also disclose your personal information to third parties when you ask us to or authorize us to do so in order to provide you with our Service.

For further information on the purposes of the processing, please consult the relevant section of this document.

No sale of your personal information

We have not sold any of your personal information in the last 12 months.

What are the purposes for which we use your personal information?

We may use your personal information to allow the proper functioning of this Application and its features (“operational purposes”). In such cases, your personal information will be treated appropriately and proportionate to the purposes for which it was originally collected and strictly within the limits of compatible purposes.

We may also use your personal information for other reasons, such as for commercial purposes (as indicated in the “Details on the processing of Personal Data” section herein), as well as to comply with the law and defend our rights before the competent authorities when our rights or interests are threatened or when we suffer damage.

We will not use your personal information for different, unrelated or incompatible purposes, without first communicating to you a new information.

Your California privacy rights and how to exercise them

Right to knowledge and portability

You have the right to know the following:

• the categories of personal information we collect about you and the sources of that information, the purposes for which we use your personal information and with whom we share it;
• in case of sale or communication of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will communicate:
  • for sale, the categories of personal information disclosed to each category of recipients; end
  • for communication to third parties for operational purposes, the categories of personal information obtained from each category of recipients;

The above information will be limited to personal information collected or used in the last 12 months.

In the event that our response is provided electronically, the information contained therein will be “portable”, i.e. delivered in a compatible format so as to allow you to transmit the information to other entities without impediments – provided this is technically feasible.

Right to request deletion of your personal information

You have the right to request the deletion of any of your personal information, subject to the exceptions provided by law (such as, but not limited to, where the information is used to identify and repair errors on this Application, to detect accidents of security, for purposes of protection from fraudulent or illegal activities, to exercise certain rights, etc.).

If no exceptions provided by law apply, following the exercise of your right, we will delete your personal information and ask our suppliers to do the same.

How to exercise your rights

To exercise the rights described above, you must submit a verifiable request by contacting us using the contact details provided herein.

In order to be able to respond to your request, it is necessary for us to be able to identify you. For this you can only exercise the above rights by submitting a verifiable request that must:

• provide sufficient information to enable us to reasonably verify that you are the individual to whom the personal information we have collected relates or an authorized representative;
• describe your request with a degree of detail that is sufficient for us to understand, evaluate and respond correctly to what you ask us.

We will not respond to any request if we are unable to verify your identity and, therefore, confirm that the information in our possession actually refers to you.

If you cannot make a verifiable request yourself, you can designate a person registered with the California Secretary of State to do it on your behalf.

If you are an adult, you can make a verifiable request on behalf of someone under your parental authority.

It is possible to submit a maximum number of 2 requests within 12 months.

How and in what time we will handle your request

We will confirm that we have received your request within 10 days and provide you with information on how we will process it.

We will respond to the merits of the request within 45 days of receiving it. If we need more time, we’ll explain why and let you know how much time we need. In this regard, please note that it may take up to 90 days to fulfill your request.

Our communications will cover the period of the previous 12 months.

If we deny your request, we will explain the reason for the refusal.

We will not charge any fees for processing or responding to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or deny your request. In both cases, we will notify you of our decisions and explain the reasons.

Information for Users residing in Brazil

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this Application and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we “, “our” or “our”).
The provisions contained in this section apply to all Users who are residents of Brazil, pursuant to the “Lei Geral de Proteção de Dados” (such Users are referred to below simply as “you”, “your”, “you” or “your”). For these Users, these provisions prevail over any other possibly divergent or conflicting provision contained in this privacy policy.
This part of the document uses the term “personal information” as defined by the Lei Geral de Proteção de Dados (LGPD).

Legal bases under which we process your personal information

We only process your personal information if one of the legal grounds for such processing exists. The legal bases are as follows:

• your consent to the processing activities in question;
• compliance with legal obligations that we are required to comply with;
• the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
• studies conducted by research institutions, preferably carried out on anonymised personal information;
• the execution of a contract and the related pre-contractual obligations, if you are a party to this contract;
• the exercise of our rights in court, administrative proceedings or arbitration;
• your defense or physical safety or that of a third party;
• health protection – in the context of procedures implemented by entities or professionals in the health sector;
• our legitimate interest, provided that your fundamental rights and freedoms do not override those interests; and
• credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out which categories of personal information are processed, you can refer to the “Details on the processing of Personal Data” section in this document.

Why we treat your personal informationi

To find out why we process your personal information, please refer to the “Details on the processing of personal data” and “Purpose of processing the collected data” sections in this document.

Your privacy rights in Brazil, how to make a request and how it will be handled by us

Your privacy rights in Brazil

You have the right to:

• obtain confirmation of the existence of processing activities concerning your personal information;
• access your personal information;
• obtain the rectification of your personal information that is incomplete, inaccurate or out of date;
• obtain anonymization, blocking or deletion of unnecessary or excessive personal information, or of that information that is processed contrary to the provisions of the LGPD;
• obtain information regarding the possibility of giving or refusing your consent and the related consequences;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your explicit request, the portability of your personal information (with the exception of anonymised information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;
• obtain the cancellation of the personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions provided for in article 16 of the LGPD apply;
• withdraw your consent at any time;
• lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;
• oppose processing activities in cases where such processing is not carried out in accordance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used in the context of automated decision-making processes; and
• request the review of decisions that harm your interests, made exclusively on the basis of automated decision-making processes of your personal information. These include decisions to shape your personal, professional, consumer or creditor profile, or other aspects of your personality.

You will never be discriminated against, nor will you suffer any treatment that is unfavorable to you in any way, following the exercise of your rights.

How to submit a request

You can submit an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.

How and in what time we will handle your request

We will do our best to answer your request as soon as possible.

In any case, if it is impossible for us to do so, we will make sure to inform you of the factual or legal reasons which prevent us from immediately complying or following up on your request. If your personal information is not processed by us, if we are able to do so, we will indicate the natural or legal person to whom to address your requests.

In the event that you decide to submit an access request or a request for confirmation of the existence of the processing of personal information, please make sure to specify whether you prefer to receive your personal information in electronic or paper format.

You will also need to let us know if you want an immediate response, in which case you will receive a simplified response, or if you require complete disclosure.

In the latter case, we will respond within 15 days from the moment of your request, providing you with all the information regarding the origin of your personal information, confirmation or not of the existence of personal information concerning you, all the criteria used for the treatment and the purposes of such processing, while safeguarding our commercial and industrial secrets.

In the event that you decide to submit a request for rectification, deletion, anonymization or blocking of personal information, we will make sure to immediately inform the other parties with whom we have shared your personal information of your request so that they can in turn satisfy your request – except in cases where such communication is impossible or excessively burdensome for us.

Transfer of personal information outside Brazil in cases permitted by law

We may transfer your personal information outside the Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedure bodies, as required by the tools made available by international law;
• when the transfer is necessary to defend the life or physical integrity of you or of third parties;
• when the transfer is authorized by the ANPD;
• when the transfer derives from an obligation assumed in the context of an international cooperation agreement;
• when the transfer is necessary for the exercise of a public order or for the performance of a public service;
• when the transfer is necessary for the fulfillment of a legal obligation, the execution of a contract and the related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.