Fondazione Capellino and the other subsidiaries directly or indirectly controlled by the latter, as detailed at the end of this policy (under XI), as Joint Data Controller (hereinafter referred as, “Joint Controllers”), inform that, in accordance with Article 13 of EU Regulation 2016/679 (“GDPR”) and with the Legislative Decree No. 196/2003, as subsequently amended (“Italian Privacy Code”), they will process the data of data subject (the “Data Subjects”) collected through the website www.almonature.com (the “Site”) or during participation in projects organised by the Joint Controller, in the manner and for the purposes set out below.
I. TYPE OF DATA PROCESSED BY THE CONTROLLER
The Joint Controllers process the following types of personal data (the “Data”) provided by Dara Subjects, as detailed below:
1. Data obtained while a User is browsing the Site
The computer systems, cookie technology and software procedures used to operate the Website www.almonature.com obtain certain data, during their normal use, the transmission of which is implicit in the use of the Internet. This information is not collected to be linked with identified data subjects, but by its very nature could, through processing and linkage with data held by third parties, allow the identification of browsing Users. This category of data includes, for example, the pages visited by Users within the Site, domain names and addresses of websites which the User has used to access (through referral) the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response from the web server, and other information regarding the type of browser (e.g. Internet Explorer, Firefox), operating system (e.g. Macintosh, Windows) and the User’s computer system.
The data are collected through technical cookies and analytical cookies. For more information on browsing data, please refer to the Site’s Cookie Notice.
2. Personal data provided by Users
Most of the pages and contents of the Site are accessible by the User (“Unregistered User”) without the need to identify the User for consultation purposes. Therefore, access to and consultation of the Site does not require registration, except in relation to subscribing to the newsletter.
In this case, the User provides the Joint Controllers with the following personal data: name, surname, e-mail, city of residence, telephone number.
3. Personal data provided by Professional Users
A User who falls into particular professional categories has the right to register in the “Reserved Area” of the Site, where he or she confirms, under his or her own exclusive responsibility, to meet the requirements to access it (the “Professional User” and/or “Professional Users”). In this case, he or she will provide the Joint Controllers, when registering for the “Reserved Area”, with his or her personal data, including name, surname and e-mail, and will receive a personalised password for access to the “Reserved Area” from the system.
4. Personal data provided in relation to Projects organised by the Joint Controllers
A User may register in the appropriate area dedicated to the Projects. In this case, it will provide Almo Nature with its identification data during registration, including its name, e-mail address and copy of its identity document. Otherwise, a User will provide subjects appointed as Data Processors (for example, the non-profit association that manages the dogs/cats shelter within the project “CAFL / Adopt me”) with their identification data in order to be allowed to participate in the projects organised by the Joint Controllers and described in detail in the reserved area.
II. PURPOSES OF DATA PROCESSING
- The data provided by the registered and unregistered User will be processed without the prior consent of the User under Article 6(b) of the GDPR, for the following purposes of the Service:
- for the management and processing of statistical surveys on the use of the Site;
- to carry out the maintenance and technical assistance necessary to ensure the proper functioning of the Site and of the services connected to it;
- to improve the quality and structure of the Site, as well as to create new services, functions and/or features;
- to process any contact request made by the User by filling out the appropriate form or by email, for example to obtain clarification on the services offered by the Joint Controllers;
- to enable the Joint Controllers to exercise its rights in judicial proceedings and to punish unlawful conduct;
- to comply with legal or regulatory requirements.
- The data provided by the Data Subjects will be processed with their prior consent, which will be distinct, specific, and separate for each point of this paragraph, in accordance with Article 6(a) of the GDPR for the following purposes:
- to allow commercial, promotional and advertising communications to be sent to the registered User by means of automated systems, such as e-mail, about products, promotions and/or services offered by the Joint Controllers as well as newsletters containing further information on the main issues relating to the diet of cats and dogs, their welfare and their care.
- The data provided by a User in the area dedicated to the Projects or provided to the subjects appointed as Data Processor within projects organised by the Joint Controllers, will be processed:
- without the prior consent of the Data Subject under Article 6(b) GDPR, to allow the Joint Controllers’ and Data Processors’ participation in projects and allow them to manage the phases related to the organisation and carrying out of the Projects;
- with the prior consent of the Data Subject, which will be distinct, specific and separate for each point of this paragraph, under Article 6(a) GDPR, for the following purposes:
- to allow the sending to the Data Subject (for example, the adopting subject within the project) or to subjects appointed as Data Processor (for example, the non-profit association that manages the dogs and cats shelter within the project “CAFL / Adopt Me”) of commercial, promotional and advertising communications by means of automated systems, such as e-mails, on products, promotions and/or services offered by the Joint Controllers and newsletters containing further information on the main issues related to the diet of cats and dogs, their wellbeing and their care.
III. NATURE OF DATA PROVISION
The Data Subject must provide the data for the purposes of the service referred to in point 1 of the above paragraph. Any refusal to provide such data may make it impossible to provide the services.
The provision of data is, however, optional (and in any case revocable, even after the service has been provided, by simply sending an e-mail to firstname.lastname@example.org) for the purposes referred to in points 2 and 3 of the previous paragraph. The only consequence of the refusal to provide the data or its consent, where necessary, will be that the Data Subject will not be sent newsletter or commercial communications on products, promotions and/or services offered by the Joint Controllers or that it will not be able to participate in the Projects and/or to fulfil any requirements related to the Project. In any event, the Data Subject may still use the services referred to in point 1 of the previous paragraph.
IV. METHODS OF PROCESSING AND STORAGE
- The processing of Data Subjects’ data is carried out by means of the operations set out in Article 4(2) GDPR and in particular: collection, recording, organisation, storage, consultation, processing, alteration, selection, retrieval, alignment, access, use, combination, blocking, disclosure, erasure and destruction of data.
- The Data Subjects’ data are processed by non-automated and automated means, for the time period strictly necessary to achieve the purposes for which they were collected and, in any case, for no more than 10 years from its collection for the purposes of the service referred to in paragraph II, point 1 and no more than 10 years from their collection for the purposes referred to in paragraph II, paragraphs 2 and 3. Data relating to marketing will be verified every two years.
- The Data Subjects’ data will be processed by persons authorised to perform the tasks referred to in point I, who will always be identified, properly instructed and made aware of the security obligations under the GDPR as well as prepared by Almo Nature.
V. ACCESS TO DATA
The data may only be made accessible for the purposes mentioned above to the following recipients:
- employees and contractors of the Joint Controllers or its associated companies and/or of the parent company, in their capacity as persons authorised to carry out processing;
- third party companies or other persons or entities (for example, associations or professional firms that provide assistance and consultancy services and activities, such as management services for the information system, subjects that cooperate within the projects such as non-profit association (for example, dogs and cats shelters or other entities). An updated and complete list can be Fondazione Capellino at the addresses indicated above.
VI. DISCLOSURE OF DATA
Without the express consent of the User (under Article 6(b) GDPR), the Joint Controllers may disclose the Data Subjects’ data for the purposes of the Service referred to in Article II.1) to Supervisory Bodies, Judicial Authorities as well as to all other persons and entities to whom disclosure must be made by law to fulfil the said purposes, in their capacity as autonomous data controllers. The Data Subjects’ data will not be disseminated.
VII. DATA TRANSFER
The personal data provided by a Data Subject to enable the sending of commercial communications by e-mail on products, promotions and/or services offered by the Joint Controllers and/or newsletters containing insights into the main issues related to food, health and animal welfare are processed electronically, also by e-mail or cloud-systems, through the use of the providers appointed as Data Processors.
In this case, data will be transferred to the United States, in accordance with existing international agreements and Standard Terms and Conditions, which the European Commission considers to offer sufficient guarantees for the international transfer of data.
Apart from this case, the management and storage of data will take place on the Joint Controllers’ severs located in the European Union.
VIII. THIRD PARTY WEBSITES
Please note that, if the Site contains links to third party websites, the Joint Controllers has may not control over the content of those websites nor does it have access to the personal data of users who visit them.
The owners of these websites will remain, therefore, the only controllers and processors of the personal data of its users, while Joint Controllers will remain unconnected to this activity as well as to any liability, prejudice, cost, which may arise from its failure or incorrect performance.
IX. USERS’ RIGHTS
The Data Subject has the rights referred to in Article 15 GDPR.
More specifically, the Data Subject has the right, at any time, to obtain confirmation from the Joint Controllers as to whether or not personal data concerning him or her exists, even if not yet recorded, and their communication in intelligible form.
The Data Subject also has the right to obtain confirmation of:
- the source of the personal data;
- the purposes and methods of processing;
- the method applied in processing carried out using automated tools;
- the identity of the controller, the persons in charge and the designated representative;
- the recipients or categories of recipients to whom the personal data may be disclosed or who can become aware of it as designated representative in the country, processors or persons in charge of processing;
- the period for which the data will be stored.
The Data Subject is also entitled to obtain:
- the updating, rectification or, where he or she is a concerned party, the updating of the data;
- the erasure, anonymisation or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
- certification that the notice has been given of the operations set out in letters 1) and 2), including in relation to their contents, to the entities to whom or which the data were disclosed or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
The Data Subject has the right to object, in whole or in part: 1) for legitimate reasons, to the processing of personal data, even if relevant to the purpose for which it was collected; 2) to the processing of personal data for the purposes of sending advertising materials or direct selling or for carrying out market research or business communications (such as newsletters)
The User also has the right to
- restrict or object to processing;
- portability of the data, i.e. to receive the data from a controller, in a structured, commonly used and machine-readable format, and to transmit the data to another controller without hindrance;
- withdraw consent at any time without prejudice to the lawfulness of the processing based on consent given prior to the withdrawal;
Any rectification, erasure or restriction of the processing carried out at the request of the data subject, unless this proves impossible or involves a disproportionate effort, will be disclosed to each of the recipients to whom the personal data were transmitted. The requesting Data Subject can receive the list of such recipients.
The exercise of the rights is not subject to any form restriction and is free of charge and may be exercised by sending an e-mail to the following address email@example.com.
X. WITHDRAWAL OF CONSENT AND OBJECTION
If the Data Subject has given his or her consent to processing for the purposes mentioned in paragraphs 2 and 3 above, he or she can revoke it at any time, by simply sending a clear e-mail to that effect to: firstname.lastname@example.org or by clicking on the relevant link.
Following receipt of this opt-out request, the Joint Controllers will promptly remove and erase the data and inform any third parties to whom the data have been disclosed for the same purposes of erasure. The receipt of the erasure request will automatically be considered as confirmation of the erasure.
It is hereby specifically and separately noted, as required by Article 21 of the GDPR, that the data subject has the right to object at any time to the processing of personal data concerning him or her carried out for such purposes and that if the data subject objects to the processing for direct marketing purposes, personal data may no longer be processed for such purposes.
XI. DATA CONTROLLER AND PROCESSOR
Fondazione Capellino – Via de Marini 1 – 16149 Genova
Almo Nature Benefit Spa – Piazza dei Giustiniani 6 -16123 Genova
Almo Nature Uk LTD; 38 Craven Street I London WC2N 5NG I UNITED KINGDOM
Almo Nature Deutschland GmbH – Franz-Josef-Strauß-Straße 41 I 82041 Oberhaching I DEUTSCHLAND
Almo Nature Netherlands B.V.; Teelmanstraat 1-B I 1431 GL Aalsmeer I THE NETHERLANDS
Almo Nature France Sarl -153 boulevard Haussmann I 75008 Paris I FRANCE
Almo Nature Swiss GmbH – Lidenstraße 6 I 6340 Baar I SCHWEIZ
Villa Fortuna Società Agricola Sperimentale Srl – Via al Santuario, 23 I 15046 San Salvatore Monferrato
For any clarification or request concerning the processing of personal data, or to obtain the updated list of the Data Processors, you may contact Fondazione Capellino at any time, at the following email address: email@example.com.
Please note that this Policy will be subject to periodic updates which will be published on the Site.
XIII. DATE OF LAST UPDATE