Privacy Informative according to Italian D. Lgs. 30.06.2003, n. 196 (privacy Code) and EU Regulation 2016/679
Document updated May 25th 2018
Inovafood SRL, located in 33170 Pordenone (PN), VAT number and Fiscal Code 03762010266 (hereinafter referred to, for the sake of simplicity, as “Inovafood” or “the Controller”) is committed to safeguarding your personal data to the greatest possible extent.
Here below you can find our Privacy Informative, which describes the manner in which we collect and process your personal data. This policy conforms to Legislative Decree of 30th June 2003, n° 196 (Privacy Code) and to the New EU Regulation 2016/679 (GDPR).
We have made our best effort in order to write this document in the easiest, schematic and comprehensive possible manner. However, considering the legal and technical issues involved, please do not hesitate to contact us at the details provided below in case further information and / or clarifications are needed.
- What is a personal Data
We would like to inform you as to the meaning of personal data, WHICH REFERS TO ANY INFORMATION BY MEANS OF WHICH IT IS POSSIBLE TO IDENTIFY, OR TO RENDER IDENTIFIABLE WITH REASONABLE EASE, a physical person (hereinafter referred to, for the sake of simplicity, as “Data”).
- What is a processing of Data
The processing of Data means any processing which might be made on Data, since their collection to their cancellation. In particular, according to the New Regulation, said processing includes the following operations: collection, registration, organisation, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of Data.
- Who are the Data Controller, the Data Processors and the Persons tasked with your data processing
The Controller of your Data is InovaFood srl – Via Interporto Centro Ingrosso,151 – 33170 Pordenone, Italy, Vat Code and Fiscal Code 03762010266, Tel. +39 0434 598109 – Fax. +39 0434 572373 and e-mail firstname.lastname@example.org.
Please note that Inovafood IS NOT requested to appoint a DPO (Data Protection Officer) according to art. 37 of the new Regulation.
An updated list of the internal/external Data processors and of the Persons tasked with the processing, including nominated professionals, is held at the legal premises of the Controller. You can receive information regarding said list by sending us an e-mail or fax.
- What Data do we process
Inovafood processes the Data that:
- You communicate to us in relation to the execution of a contract regarding to our / your services and products;
- You communicate to us in relation to pre-contractual activities;
- Are collected by us in case of elective, explicit and voluntary sending of e-mail to the address indicated on the Web Site. In said circumstance, your e-mail address will be collected in order to answer your e-mail, as well as the Data contained in said communication;
- Are written in the curricula which will be sent to us;
- Are collected through cookies. For further information, please see our Cookies Policy below.
Should you provide us with the Data of third parties, you will be required to take all necessary steps to ensure that the communication of the Data to the Controller and our consequent processing of the same comply with the applicable provision. Therefore, for example, before providing us with the Data of third parties, you should duly inform such parties and obtain their consent to processing, if required by the aforementioned provision.
- How do we process Data
Inovafood processes Data in both printed and electronic form (saving them on PCs and servers), for the time strictly necessary for the scope for which Data are collected. In such context, Inovafood will guarantee the logistic and physical security of the Data and, in general, the confidentiality of the Data processed, by taking all necessary technical and organisational measures.
The Controller DOES NOT collect and store data of individuals of less than 14 (fourteen) years of age: individuals of less that 14 (fourteen) year of age are therefore asked NOT to communicate any personal data to us.
- Why do we process Data
Inovafood COLLECTS AND PROCESSES DATA TO THE EXTENT STRICTLY NECESSARY FOR A NUMBER OF PURPOSES, such as:
- To complete necessary precontractual activities (e.g. sending of quotations, precontractual agreements, verification of credit rating and solvency);
- To carry out contractual and taxation obligations towards yourself;
- To protect our assets and/or defend our rights on the basis of our legitimate interests (e.g. collecting pictures through video surveillance system, for which a specific policy has been prepared);
- To fulfil legal requirements and comply with requests of authorities, as well as to comply with fraud and money laundering prevention provisions, etc.;
- To reply your requests sent us by e-mails or by the form on our Web Site;
- To evaluate and select CVs, in case of voluntary sending of them;
- To send information regarding services and product already purchased by you in the past, for instance by sending you newsletter (i.e. soft spamming).However, you may unsubscribe from said service at any time.
Furthermore, should you provide us with your express consent, we will process your Data in order to:
- Carry out direct marketing through both traditional and automated processes (e.g. newsletter),
- Disclose your data through our Web Site and / or through our Social networks;
- Analyse your behaviours and preferences, but for a marketin purpose only. Indeed, Inovafood shall not take decisions which produces legal effects on an individual based solely on automated processing.
PLEASE NOTE THAT YOU CAN REVOKE, AT ANY TIME, ANY POSSIBLY CONSENT ALREADY GIVEN, by contacting us in the manner reported below.
Should the above purpose be changed, Inovafood shall promptly modify / integrate the present informative.
- Obligation to provide Data or consent, if required
THE PROVISION OF DATA FOR THE PURPOSES SET OUT IN CLAUSE 7 LETTERS A) – D) IS OBLIGATORY. Should it not be provided then contract execution cannot be guaranteed.
THE PROVISION OF DATA FOR THE PURPOSES SET OUT IN CLAUSE 7 LETTERS E) – J) IS INSTEAD OPTIONAL. Therefore, you may decide not to provide Data or to successively deny the possibility to process previously-supplied Data. In case of failure to provide your consent, we will not be able to reply your requests and / or take in consideration your application.
In relation to the purposes for which explicit consent is requested from yourself, failure to provide consent DOES NOT constitute a valid reason for the Controller to withdraw from a contract or to not fulfil your requests in relation to other purposes.
- Who is your Data communicated to
Without having to obtain your express consent, Inovafood may communicate your Data, for the above referred to purposes, to prefectures, insurance supervision institutes (such as IVASS), judicial authorities, insurance companies (for the provision of insurance-related services), as well as to parties to which such communication is required by law for the fulfilment of the afore-mentioned purposes.
Said parties will process the Data as autonomous controllers.
Your Data WILL NOT be disclosed without previous and explicit consent.
- Who can access your Data
Your Data may be made accessible for the purposes stated above:
- To employees and collaborators of the Controller, in their role as persons responsible for processing and/or internal processors and/or system administrators;
- To third parties or other parties (such as, for example, credit institutes, professional offices, consultants, insurance companies for the provision of insurance services, etc.) that carry out activities which have been outsourced by Inovafood, in their role as external processors or as autonomous controllers.
- Where is your Data stored and where is it transferred to
The Data is processed at the operative premises of the Controller, and in particular:
- At Inovafood’s (legal and manufacturing) premises, located in 33170 Pordenone (PN) – Italy – Via Venezia, 11;
- At Inovafood’s (Administrative and warehouse) Premises, located in 33170 Pordenone (PN) – Italy – Via Interporto, Centro Ingrosso 151; and
- In any other place where the parties involved in the processing are located.
THE DATA IS HELD IN ELECTRONIC FORM ON SERVERS LOCATED WITHIN THE EUROPEAN UNION. In all cases, it should be understood that Inovafood, should it prove necessary, will have the faculty to move the server to non-EU countries. In such case, Inovafood guarantees from hereon in that the transfer of Data outside of the EU will take place in accordance with applicable legal provisions following on from the stipulation of standard contractual clauses provided for by the European Commission or in conformity with the Privacy Shield, in relation to those countries that do not, according to the European Commission, offer adequate provisions.
- How long do we hold your data for
Your Data will be held in accordance with the principles of proportionality and necessity, and until the purposes for which it was collected have been fulfilled or until your consent is denied.
In particular, RBH process Data for the entire duration of its services contracts and for as long as there will be obligations or fulfilment related to the latter.
After the end of the contractual relationship your Data will be held for a period of 11 (eleven) years, in order to fulfil specific legal obligations or our legitimate interest, such as Data managing in hypothesis of any contestations or claims.
Your Data will be cancelled automatically 11 (eleven) years after the end of the contractual relationship.
- What are your rights
As the interested party, you have the right to:
- Know if the Controller holds and/or processes your Data, obtaining information relative to the: origin, category, purposes and method of processing, the recipients to whom such data can be communicated, the logic applied in the case of processing carried out by electronic means, the period for which data is held; as well as the right to access the same in its entirety and obtain a copy (art. 15 Right of access);
- Have rectified Data that relates to yourself and to complete Data which is incomplete (Art. 16 Right to rectification);
- Obtain the cancellation of Data in possession of the Controller where such cancellation is provided for by the New Regulation (art. 17 Right to erasure – Right “to be forgotten”)
- Request the Controller to limit the processing to only certain Data, where this is provided for by the New Regulation (Art. 18 Right to restrict processing);
- Be informed as to who the recipients to whom any rectifications, cancellations or processing restrictions have been communicated are (art. 19 Obligation of notification);
- Request and receive all your Data, in a format that is structured, commonly used and readable on an automatic device or to request its transmission to another controller without impediment (Art. 20 Right to portability);
- Oppose entirely or in part, the processing of Data for the purposes of marketing (sending of advertising material, direct sales, market research and commercial communications) and for the purposes of profiling connected to such marketing (art. 21 Right of opposition).
Finally, you have the right to present a claim/petition directly to the Italian Personal Data Protection Authority, located at Piazza di Montecitorio n°. 121 – 00186 ROME, Italy tel. (+39) 06.696771 and Fax: (+39) 06.69677.3785.
The exercise of the rights set forth in this paragraph is completely free of charge.
- How can you exercise your rights
At any time, you may exercise your rights by sending a registered letter with return receipt to Inovafood SRL,located in 33170 Pordenone (PN), Italy, or an e-mail to email@example.com.