The purpose of the present document is to inform the natural person (hereinafter “Data Subject“) about the processing of his/her personal data (hereinafter “Personal Data“) collected by the data controller, Oxygenium s.r.l., with registered office in Via Farini no. 3 40124 Bologna, CF/VAT no. 03466981200 , e-mail address firstname.lastname@example.org, (hereinafter “Data Controller“), through the website https://www.scramblerducatifoodfactory.it/ (hereinafter “Application“).
- Categories of Personal Data processed
The Data Controller processes the following types of Personal Data voluntarily provided by the Data Subject:
- Contact data: name, surname, address, e-mail, telephone, pictures, authentication credentials, any further information sent by the data subject, etc.
The Controller processes the following types of Personal Data collected in an automated manner:
- Technical Data: Personal Data produced by the devices, applications, tools and protocols used, such as, for example, information about the device used, IP addresses, browser type, Internet Service Provider (ISP) type. Such Personal Data may leave traces that, in particular when combined with unique identifiers and other information received by servers, can be used to create profiles of individuals
- Application navigation and usage data: such as, for example, pages visited, number of clicks, actions taken, duration of sessions, etc.
- Data relating to the exact location of the Data Subject: for example, geolocation data that precisely identifies the location of the Data Subject, which may be collected via the satellite network (e.g. GPS) and other means, collected with the consent of the Data Subject. The Data Subject may withdraw consent at any time.
Failure on the part of the Data Subject to provide Personal Data for which there is a legal or contractual obligation, or if they are a necessary requirement for the conclusion of a contract with the Data Controller, will result in the Data Controller’s inability to establish or continue the relationship with the Data Subject.
The Data Subject who communicates Personal Data of third parties to the Controller is directly and exclusively responsible for their origin, collection, processing, communication or dissemination.
- Cookies and similar technologies
- Legal basis and purpose of processing
The processing of Personal Data is necessary:
- for the execution of the contract with the Data Subject, namely:
- fulfilment of any obligation arising from the pre-contractual or contractual relationship with the data subject
- by legal obligation, namely:
- the fulfilment of any obligations provided for by the applicable laws, regulations and legislation, in particular, in tax and fiscal matters
- on the basis of the legitimate interest of the Controller, for:
- marketing purposes via email of the Controller’s products and/or services in order to directly sell the Controller’s products or services using the email provided by the Data Subject in the context of the sale of a similar product or service
- management, optimisation and monitoring of the technical infrastructure: to identify and solve technical problems, to improve the performance of the application, to manage and organise information in a computer system (e.g. servers, databases, etc.)
- statistics with anonymous data: to perform statistical analysis on aggregated and anonymous data in order to analyse the behaviour of the Data Subject, to improve the products and/or services provided by the Controller and better meet the Data Subject’s expectations
- based on the consent of the data subject, for:
- profiling of the Data Subject for marketing purposes: to provide the Data Subject with information on the Controller’s products and/or services by means of automated processing aimed at collecting personal information for the purpose of predicting or assessing the Data Subject’s preferences or behaviour
- retargeting and remarketing: to reach with a personalised advertisement the Data Subject who has already visited or shown interest in the products and/or services offered by the Application using his/her Personal Data. The Data Subject may opt-out by visiting the Network Advertising Initiative page
- communication of Personal Data for third party marketing purposes: to communicate Personal Data to third parties operating in the marketing sector so that they can use it to send them information or commercial and/or promotional materials or to carry out direct sales activities of their products and/or services or to carry out market research by automated and traditional means
Based on the legitimate interest of the Data Controller, the Application allows interactions with external platforms or social networks whose processing of Personal Data is governed by their respective privacy policies to which please refer. The interactions and information acquired by this Application are in any case subject to the privacy settings that the Data Subject has chosen on such platforms or social networks. This information – in the absence of specific consent to processing for further purposes – is used solely for the purpose of enabling the use of the Application and providing the information and services requested.
The Data Subject’s Personal Data may also be used by the Data Controller to protect itself before the competent courts.
- Processing methods and recipients of Personal Data
The processing of Personal Data is carried out by means of paper-based and computer-based instruments with organisational methods and logics strictly related to the stated purposes and through the adoption of appropriate security measures.
Personal Data are processed exclusively by:
- persons authorised by the Data Controller to process Personal Data who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality;
- subjects operating autonomously as separate data controllers or by subjects designated as data processors by the Data Controller in order to carry out all the processing activities necessary to pursue the purposes set out in this policy (e.g. business partners, consultants, IT companies, service providers, hosting providers);
- parties or entities to whom Personal Data must be disclosed by law or by order of the authorities.
The persons listed above are required to use appropriate safeguards to protect Personal Data and may only have access to Personal Data necessary to perform the tasks assigned to them.
Personal Data will not be disseminated indiscriminately in any way.
If necessary, Personal Data may be transferred to entities located outside the European Economic Area (EEA). Whenever Personal Data is transferred outside the EEA, the Controller shall take all appropriate and necessary contractual measures to ensure an adequate level of protection of Personal Data, including, among others, agreements based on the standard contractual clauses for the transfer of data outside the EEA, approved by the European Commission. To request information on the specific guarantees adopted, the Data Subject may contact the Controller at the following e-mail address email@example.com.
- Period of retention of Personal Data
Personal Data will be kept for the period of time necessary to fulfil the purposes for which they were collected, in particular:
- for purposes relating to the performance of the contract between the Data Controller and the Data Subject, shall be retained for the entire duration of the contractual relationship and, after termination, for the ordinary limitation period of 10 years. In the event of litigation, for the entire duration of the same, until the time limit for appeals is exhausted
- for purposes relating to the legitimate interest of the Controller, will be retained until that interest is fulfilled
- for the fulfilment of a legal obligation, by order of an authority and for legal protection, shall be retained in accordance with the time limits provided for by those obligations, regulations and in any case until the expiry of the prescriptive period provided for by the applicable rules
- for purposes based on the consent of the data subject, will be retained until the consent is revoked. For marketing purposes for a period not exceeding 24 months.
At the end of the retention period, all Personal Data will be deleted or stored in a form that does not allow the identification of the Data Subject.
- Rights of the Data Subject
Data Subjects may exercise certain rights with regard to Personal Data processed by the Controller. In particular, the Data Subject has the right to:
- be informed about the processing of their Personal Data
- withdraw consent at any time
- limit the processing of one’s Personal Data
- object to the processing of your Personal Data
- access their Personal Data
- verify and request rectification of their Personal Data
- obtain the restriction of the processing of their Personal Data
- obtain the deletion of your Personal Data
- transfer their Personal Data to another controller
- file a complaint with the data protection supervisory authority and/or take legal action.
To exercise their rights, Data Subjects may address a request to the following e-mail address firstname.lastname@example.org. Requests will be taken up by the Controller immediately and processed as quickly as possible, in any case within 30 days.
Last updated: 26/10/2022