Effective from: 16/05/2018

SCOPE OF THIS NOTICE

Please read this Privacy Policy (“Policy”) carefully to understand our policies and practices regarding your Personal Data and how we will treat it. This Policy applies to individuals who interact with AR TARTUFI SRL services as consumers (“you”). The Policy explains how your Personal Data is collected, used and disclosed by AR TARTUFI SRL. It also explains how you can access and update your Personal Data and how to make certain choices.

This Policy covers both online and offline data collection activities, and concerns Personal Data that we obtain from various channels, such as websites, apps, social networks and events. Please note that we may aggregate Personal Data collected from different sources (e.g. from a website or an offline event). With this same logic, we combine Personal Data that were originally collected by AR TARTUFI SRL. In point 9 you will find further information on how to object to what has just been described.

If you do not provide us with the necessary Personal Data (for example, by entering a message in our registration forms), we may not be able to provide you with our products and/or services. This Policy may be subject to subsequent changes (see Point 11). This Policy provides important information relating to the following areas:

  1. DATA SOURCES
  2. WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
  3. PERSONAL DATA OF MINORS
  4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
  5. USES OF YOUR PERSONAL DATA
  6. DISCLOSURE OF YOUR PERSONAL DATA
  7. STORAGE OF YOUR PERSONAL DATA
  8. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
  9. ACCESS TO YOUR PERSONAL DATA
  10. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
  11. CHANGES TO THIS NOTICE
  12. DATA CONTROLLERS AND RESPONSIBLE FOR DATA PROCESSING & CONTACTS

1. SOURCES OF PERSONAL DATA

This Policy applies to Personal Data that we collect from or about you, using the methods described below (see Section 2), from the following sources:

AR TARTUFI SRL websites.
Consumer-directed websites operated by or for AR TARTUFI SRL, including sites we operate under our own domains/URLs and mini-sites we operate on social networks such as Facebook (“Websites”).

AR TARTUFI SRL mobile sites/apps.
Consumer-facing mobile sites or applications operated by or for AR TARTUFI SRL, such as smartphone apps.

Emails, texts, and other electronic messages.
Electronic communications between you and AR TARTUFI SRL

Offline registration forms.
Paper or digital registration forms and the like that we collect in various ways, such as by mail, during in-store demonstrations, contests or other promotions or events.

Advertising interactions.
Interactions with our advertising activities (for example, we may receive information about your possible interaction with one of our advertisements on a third-party website).

Data created by us.
In the context of our relationships, we may create some Personal Data relating to you (for example, data relating to your purchases from our websites).

Data obtained from other sources.
Social networks (e.g. Facebook, Google) or market research (if the feedback is not collected anonymously), data aggregators, AR TARTUFI SRL partners in promotions, public sources and data received following the acquisition of other Companies.

2. WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

Depending on how you interact with AR TARTUFI SRL (online, offline, by telephone, etc.), we collect different types of data about you, as described below.

Personal data.
This is the data you provide to us to allow us to contact you, such as your name, postal address, email address, social network registration data, or telephone number.

Demographics and interests.
This is data that describes your demographic characteristics or habits, such as your date of birth, age or age range, gender, geographic location (postal code/zip code), favorite products, hobbies and interests, and information about your family or lifestyle.

Technical data relating to your computer / mobile device.
Any information about the computer system or other technological device you use to access one of our websites or apps, such as the Internet Protocol (IP) address used to connect your computer or device to the Internet, operating system type, and browser type and version. If you access a website with a mobile device, such as a smartphone, the information collected will include, where permitted, your unique device ID, advertising ID, geolocation, and other similar mobile device data.

Information about your use of websites/communications.
As you navigate and interact with our websites or newsletters, we use automatic data collection technologies to collect certain information about your behavior. This information includes the links you click on, the pages you visit, and for how long, and other similar information and statistics about your interactions, such as content response times, download errors, and length of time spent on certain pages. This data is captured using automated technologies such as cookies and web beacons, and is also collected with third-party tracking systems for analytics and advertising purposes. You have the right to object to the use of these technologies: for more information, please read Section 4.

Market research & consumer feedback.
This is the data that you spontaneously communicate to us regarding your experience in using our products and services.

Consumer generated content.
This is any content you create and share with us on social networks, or by uploading it to one of our websites or apps, including social networking apps like Facebook. This includes photos, videos, personal stories, or other similar media. Where permitted, we collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, interactive sites, customer loyalty, and social networking.

Data present on social networks.
This is information that you share publicly on a social network, or information that is part of your profile on a social network (such as Facebook) and that you have allowed others to share with Us. This includes, for example, your basic account information (e.g., name, email address, gender, date of birth, city where you are located, profile photo, user ID, list of friends, etc.) and any other information or activity that you have allowed the social network to share. We receive information (even partial) from your profile published on a social network whenever you download or interact on a social network (such as Facebook), whenever you use a feature of a social network that is integrated into an AR TARTUFI SRL site (such as Facebook Connect), or whenever you interact with Us via a social network. To learn more about how your information on a social network is transmitted or to opt-out of sharing such information on social networks, you can visit the website of the relevant social network.

Financial and payment data.
This is all the data we need to process an order, or that you use to make a purchase, such as your credit or debit card details (holder name, card number, expiration date, etc.) or other forms of payment (if available). In any case, we will manage such financial and payment data in compliance with the laws and regulations in force and with Security standards such as PCI DSS.

Special Categories of Personal Data (Sensitive Personal Data).
In the normal course of our business we do not seek to collect or otherwise process any so-called “sensitive” personal data. Where for any reason it is necessary to process your sensitive personal data, we rely on your prior consent for any processing that is voluntary (for example, for marketing purposes). Where we process your sensitive personal data for other purposes, we do so on the following legal bases: (i) detection and prevention of crime (including fraud prevention); and (ii) compliance with applicable law (for example, to implement our diversity reporting).

3. PERSONAL DATA OF MINORS

We do not knowingly request or collect personal data from minors under the age of 18. If we become aware that we have accidentally received personal data from a minor under the age of 18, we will promptly delete this data from our records. AR TARTUFI SRL may, however, collect personal data from minors under the age of 18 directly from parents or guardians, and with their explicit consent.

4. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS

Cookies/Similar Technologies.
We invite you to read our Cookie Policy to learn how you can set your cookie preferences and to have precise information on the cookies we use and the reasons why we use them.

Log File.
We collect data in the form of log files that record website activity and gather statistics on your browsing habits. The data is generated automatically and helps us resolve errors, improve performance and maintain the security of our websites.

Web Beacons.
Web beacons (also known as “web bugs”) are small strings of code that deliver a graphic image on a web page or in an email for the purpose of sending data back to us. The data collected through web beacons may include IP addresses and information about how you respond to an email campaign (e.g., what time you opened the email, which links in the email you clicked, etc.). We use web beacons on our websites or include them in emails we send to you. We use the data we obtain from web beacons for a variety of purposes, including site traffic reporting, visitor counting, advertising, email auditing and reporting, and personalization.

Heat mapping.
Heat mapping services are used to identify which areas of a page are subject to cursor movement or mouse clicks in order to detect which of them attract the most interest. These services allow you to monitor and analyze traffic data and are used to track user behavior anonymously.

5. USES OF YOUR PERSONAL DATA

The following paragraphs describe the various purposes for which we collect and use your Personal Data and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses described below are relevant to every individual.

What we use your Personal Data for

Our reasons

Our legitimate interests

Customer Service: We use your Personal Data for Quality Office (Consumer Service) activities, including responding to your requests. These activities usually require the use of some personal contact information and information regarding the reason for the request (for example: order status, technical problems, product questions/complaints, general questions, etc.).

  • Fulfill contractual obligations
  • Legal obligations
  • Our legitimate interests
  • Improve and develop new products and services
  • Be more efficient

Contests, Marketing and Other Promotions. With your consent (where required), we use your Personal Data to provide you with information about products or services (e.g. marketing communications or campaigns or promotions). Such communications may be made via email, announcements, SMS, telephone calls or postal services, as permitted by applicable law. Some of our campaigns and promotions are run by third party websites and/or social networks. This use of your Personal Data is voluntary, so you can object (or withdraw your consent, in some countries) to the processing of your Personal Data for these purposes. For detailed information on how to change your preferences in relation to marketing communications, please see Sections 9 and 10 below. For more information about our contests and other promotions, please refer to the official rules or details published with each contest/promotion.

  • With your consent (where necessary)
  • To fulfill contractual obligations
  • Our legitimate interests
  • Understand which of our products and Services may be of interest to you and provide you with information about them
  • Define customer types for new products or services

Social Networks: We use your Personal Data when you interact with certain social network features, such as the “Like” option, to present you with advertising and attract your attention. You can learn more about how these options work, how we obtain your profile data, and understand how to exercise the opt-out option, by reading the Privacy policies of the social networks in question.

Personalization (offline and online). With your consent (where required), we use your Personal Data (i) to analyze your preferences and habits, (ii) to predict your needs based on the analysis of your profile, (iii) to improve and personalize your experience on our websites and apps; (iv) to ensure that the content of our websites/apps is optimized for you and your computer or device; (v) to provide you with targeted advertising and content, and (vi) to allow you to use interactive features, when you choose to do so. For example, we remember your login ID/email or user name so that you can quickly log in each time you visit the site, or easily retrieve items you have previously placed in your shopping cart. Based on this type of information and with your consent (where required), we also present you with specific AR TARTUFI SRL content or promotions that are tailored to your interests. The use of your Personal Data is voluntary, which means that you can object to the processing of your Personal Data. For more information on how to opt-out, see Section 10 below.

  • With your consent (where necessary)
  • Our legitimate interests
  • Understand which of our products and Services may be of interest to you and provide you with information about them
  • Define customer types for new products or services

Order Fulfillment. We use your Personal Data to process and ship your orders, inform you of the status of your orders, correct addresses, and perform identity verification and other fraud detection activities. This requires the use of certain Personal Data and payment information.

Other general purposes (e.g. internal or market research, analytics, security). In accordance with applicable laws, we use your Personal Data for other general business purposes, such as conducting internal or market research and measuring the effectiveness of advertising campaigns. We reserve the right, if you have multiple accounts, to merge them all into one account. We also use your Personal Data to manage our communications and operate IT and security systems.

  • Fulfill contractual obligations
  • With your consent (where necessary)
  • Legal obligations Our legitimate interests
  • Improve and develop new products and services
  • Be more efficient
  • Protecting our systems, our networks and our employees
  • Comply with legal obligations

Legal reasons or mergers/acquisitions. In the event that AR TARTUFI SRL, or its assets, are acquired by, or merged with, another company, including as a result of bankruptcy, we will disclose your Personal Data to our legal successors. We will also disclose your Personal Data (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreements or the terms of our website.

  • Legal obligations
  • Our legitimate interests
  • Comply with legal obligations
  • Protecting our property and employees

6. DISCLOSURE OF YOUR PERSONAL DATA

In addition to the AR TARTUFI SRL entities indicated in the chapter on Data Processors & Contacts (see Point 12), we share your Personal Data with these types of external organizations:

Service providers.
These are external companies that we use to help us run our business (e.g. order fulfillment such as logistics and transportation, payment processing, website operations, market research, support services, promotions, website development, data analysis, customer service, etc.). Service providers, and their selected staff, are only allowed to access your Personal Data on our behalf, for the specific tasks they have been asked to perform, based on our instructions, and are required to keep the Personal Data confidential and secure. Where required by applicable law, you can obtain a list of our service providers who process your Personal Data (see Section 12 to contact us about this).

Commercial-financial data provision / debt collection agencies.
To the extent permitted by applicable law, credit reporting and debt collection agencies are external companies that we use to verify your creditworthiness (particularly for orders with invoice) or to collect outstanding invoices.

Third party companies that use Personal Data for their marketing purposes.
Except where you have given your consent, we do not license or sell your Personal Data to third-party companies for their own commercial purposes. Their identity will be disclosed when your consent is requested.

Third party recipients who use Personal Data for legal reasons or for Merger/Acquisition operations.
We will transfer your Personal Data to third parties for legal reasons or in the context of an acquisition or merger (see Section 5 for more information).

7. STORAGE OF YOUR PERSONAL DATA

AR TARTUFI SRL takes every reasonable step to ensure that your personal data is processed only for the period necessary for the purposes set out in this Privacy Policy. The criteria for determining the retention period of your personal data are:

(a) AR TARTUFI SRL will retain copies of your personal data in a form that permits identification only for as long as: (i) We maintain an ongoing relationship with you (for example, if you are included in our mailing list and have not unsubscribed) and for 2 years following your last contact or expression of interest in our services (newsletter, websites, etc.). (ii) Your personal data is necessary in connection with the purposes set out in this Privacy Policy and we have a valid legal basis, (b) The duration of: (i) any applicable limitation period (i.e. any period during which a person could bring a legal claim against us) and (ii) an additional 2 months following the end of the applicable limitation period (in order to be able to identify the personal data of a person who may bring a claim at the end of the applicable period), (c) Additionally, in the event of relevant legal claims, we may continue to process the Personal Data for such additional time as is necessary in connection with such claim. During the periods set out in paragraphs b (i) and b (ii) above, we will limit the Processing of Personal Data to storing or maintaining the security of such data, except to the extent that the data needs to be reviewed in connection with any complaint, or any obligation under applicable law. After the periods set out in paragraphs (a), (b) and (c) have concluded, to the extent applicable, we will either permanently delete or destroy the relevant Personal Data or (ii) anonymize the relevant Personal Data.

8. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA

We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas, such as social networks.

People who can access your Personal Data.
Your Personal Data will be processed by our staff or our authorized partners, as necessary, for the specific purposes for which such Personal Data was collected (for example, our authorized staff will have access to your data as customers).

Measures taken in operating environments.
We store your Personal Data in operating environments that use security measures, among those reasonably available, to prevent unauthorized access. We follow appropriate standard measures, among those available, to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although we will do our best to protect your Personal Data, we cannot guarantee the security of data during transmission through websites/apps.

Precautions you should take.
It is important that you also do your part to protect the Security of your Personal Data. When you open an online account, make sure to choose a password that is difficult to guess and never share it with anyone. You are responsible for keeping this password confidential and for the use of your account. If you use a shared or public computer, never choose to remember your login ID/email address or password and log out of your account every time you leave the computer. You should also use any privacy settings or controls we provide on our websites/apps.

Transfer of your Personal Data.
Your data will not be transferred abroad or to other companies. If necessary, the company will inform you with a written request that must be accepted and signed.

9. YOUR RIGHTS

Access to Personal Data.
You have the right to access, verify and request a paper or electronic copy of the data we hold about you. You also have the right to request information about the sources of your Personal Data.

These rights can be exercised by contacting us at the following address: https://www.valnerinatartufi.com/contatti/ or at the following email: info@valnerinatartufi.com or by calling the Quality Office number 0744 62412, active from Monday to Friday, from 9 am to 16 pm, or by writing to us at the email address, attaching a copy of your ID or equivalent details (when requested by Us and permitted by law). If the request is made by a person other than you, who does not provide evidence that such request is legitimately made on your behalf, the request itself will be rejected. Please note that any identifying data provided to Us will only be processed in accordance with, and to the extent permitted by, the laws in force.

Other rights (e.g. modification or deletion of Personal Data).
When required by law, you may (i) request deletion, portability, correction or revision of your Personal Data; (iii) limit the use and disclosure of your Personal Data; and (iv) withdraw consent to any of our data processing activities.

Under applicable law, you also have these other rights in relation to the use of your Personal Data:

  • the right to object, on grounds relating to your particular situation, to the use of your Personal Data by us, or on our behalf;
  • the right to object to the Processing of your Personal Data by us, or on our behalf, for direct marketing purposes.

Please note that, in some circumstances, we will not be able to delete your Personal Data without also deleting your user account. We may need to retain some of your Personal Data, after you have requested deletion, to comply with our legal or contractual obligations. Applicable laws may also allow us to retain some of your Personal Data to meet our business needs.

In some cases, our websites have a dedicated function, through which you can verify and modify the Personal Data you have provided. Please note that we ask our registered consumers to verify their identity (e.g. via login ID/email address, password) before accessing their account and modifying their data. This is to prevent unauthorized access to your account.

We hope that we can always accommodate your requests regarding how we process your Personal Data. However, if any of your concerns remain unresolved, you have the right to lodge a complaint with the competent data protection authorities.

10. YOUR CHOICES ABOUT HOW WE MAY USE AND DISCLOSE YOUR PERSONAL DATA

We strive to provide you with choices regarding the Personal Data you provide to us. The following mechanisms will give you the control described below over your Personal Data:

Cookies/Similar Technologies.
You can communicate your consent via (i) our consent management solution or (ii) your browser, so as to refuse all or some cookies/similar technologies, or to be notified when they are being used. See Section 4 above.

Advertising, marketing and promotions.
If you wish for your Personal Data to be used by AR TARTUFI SRL to promote its products or services, you can indicate this by clicking on the appropriate boxes in the registration form, or by answering the questions asked by our Office staff. If you decide that you no longer wish to receive such communications, you can subsequently cancel your consent to receive commercial information, at any time, by following the instructions contained in these communications. You can opt-out of marketing communications sent by any means, including social networks, at any time by clicking on the links in our communications, or by logging in to the websites/apps or social networks, where you can change your preferences in your profile by unchecking the relevant boxes, or by calling our Office. Please remember that even if you opt-out of marketing communications, you will still receive administrative communications from us, such as order or other transaction confirmations, notifications about your account activity (e.g., account confirmations, password changes, etc.), and other important non-marketing communications.

Personalization (offline and online):
When required by law, if you wish for your Personal Data to be used by AR TARTUFI SRL to provide you with personalized experiences/targeted advertising and communications, you may indicate so by clicking on the appropriate boxes in the registration form or by answering the questions posed by our Quality Office staff. If you decide that you no longer wish to receive this service, you may opt out at any time by logging into the website/app, where you can change your preferences in your account profile by unchecking the relevant boxes, or by calling our Office.

Interest-based advertising
We work with advertising networks and other advertising service providers (“Advertising Providers”) that serve ads on behalf of Us and other unaffiliated companies across the Internet. Some of these ads are based on your interests based on information collected over time on AR TARTUFI SRL websites or on the websites of unaffiliated companies. You can visit www.aboutads.info/choices to learn more about this type of advertising, including how to opt out of interest-based advertising from companies that participate in the Digital Advertising Alliance (“DAA”) self-regulatory program. You can also opt out of this type of advertising in mobile applications from companies that participate in the DAA’s AppChoices program by downloading the app from the iOS or Android app store. You can also prevent location data from being collected from a mobile device by accessing your device’s location settings.

11. CHANGES TO THIS NOTICE

If we change the way we process your Personal Data, we will update this Policy. We reserve the right to make changes to our practices and this Policy at any time, so we recommend that you check this document frequently for updates or changes.

12. DATA CONTROLLER AND DATA PROCESSORS & CONTACTS

To ask questions or make comments about this Policy and our privacy practices, or to make a complaint about our compliance with applicable privacy laws, please contact us as follows: by contacting us via this link https://www.valnerinatartufi.com/contatti/, active from Monday to Friday, or by calling +39 0744 62412 from 9 am to 16 pm. We will respond to and investigate any complaint about how we handle your Personal Data (including any complaints about our violation of your rights under applicable Privacy laws).

Data controllers

AR TARTUFI Srl
Fraz. Palombare 5, 05031 Arrone (TR)

Responsible for all activities