Almo Nature Netherlands BV with registered office in Teelmanstraat 1, 1431 GL Aalsmeer, Holland, as Controller of data processing (“Almo Nature”), gives notice that, in accordance with Article 13 of EU Regulation 2016/679 (the “GDPR”), it will process the data of users (the “User” and/or “Users”) collected through the website www.almonature.com (the “Site”) in the manner and for the purposes set out below.
I. Type of data processed by Almo Nature through the site
Almo Nature processes the following types of personal data (the “Data”) provided by Users of the Site when they read and/or register for the newsletters:
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.Thedata 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 ofthe Site does not require registration, except in relation to subscribing to the newsletter.In this case, the User provides Almo Nature 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 Almo Nature, when registering for the “Reserved Area”, with his or herpersonal data, including name, surname and e-mail, and will receive a personalised password for access to the “Reserved Area”from the system.
4. Personal dataprovided in relation to solidarity projects by accessing to the dedicated page “A companion Animal is for life”
A User who is a representative of an ONLUS [not for profit]association or a non-ONLUS association may register in the appropriate area “A companion Animal is for life”. 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 in order to be contacted to participate in the solidarity projects described in detail in the reserved area.
II. Purpose of data processin
- The data provided by the registered and unregistered User will be processed without the prior consent of the User under Article 6(b) of theGDPR, 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 Almo Nature;
- to enable Almo Nature to exercise its rights in judicial proceedings and to punish unlawful conduct;
- to comply with legal or regulatory requirements.
- The data provided by the registered User and by the Professional User will be processed with the prior consent of the User, 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 ase-mail, about products, promotions and/or services offered by Almo Natureas well as newsletters containing further information on the main issues relating to the diet of cats and dogs, their welfare and their care.
- to allow the transfer of data to Fondazione Capellino to receive promotional and advertising communications by means of automated means, such as e-mail, about initiatives, opportunities and services offered by Fondazione Capellino in relation to projects on the protection of dogs, cats and biodiversity.
- The data provided by a User in the “A companion Animal is for life”area will be processed:
- without the prior consent of the User under Article 6(b) GDPR, to allow the User’s participation in any solidarity projects described in the “A companion Animal is for life” area, and allow Almo Nature to manage the phases related to the organisation and carrying out of the project;
- with the prior consent of the User, 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 registered User of commercial, promotional and advertising communications by means of automated systems, such as e-mails, on products, promotions and/or services offered by Almo Nature and newsletters containing further information on the main issues related to the diet of cats and dogs, their wellbeing and their care.
- to allow the transfer of data to Fondazione Capellino to receive promotional and advertising communications by means of automated systems, such as e-mail, about initiatives, opportunities and services offered by Fondazione Capellino in relation to projects on the protection of dogs, cats and biodiversity.
III. Nature of data provision
The User 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 email@example.com) for the purposes referred to in points 2 and 3 of the previous paragraph. The only consequence of the refusal to provide the data:for point no. 2.1, will be that the User will not be sent commercial communications on products, promotions and/or services offered by Almo Nature and/or newsletters; for point no. 2.2, will be that the User and Professional User will not be sent commercial communications on events, promotions and/or services offered by Fondazione Capellino and/or newsletters; for point no. 3.A, will be that the User will not be able to participate in the solidarity projects in the “A companion Animal is for life”area and/or to fulfil any requirements related to the project; for point no. 3.1, will be that it will not be possible to send the User commercial communications on products, promotions and/or services offered by Almo Nature and/or newsletters; for point no. 3.2, will be that the User and the Professional User will not be sent commercial communications on events, promotions and/or services offered by Fondazione Capellino and/or newsletters.
IV. Methods of processing and storage
- The processing of Users’ 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 Users’dataare 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.
- The Users’ 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 Almo Nature 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 used by Almo Nature Benefit S.p.A. and the telecommunications networks, providers (managed by Amazon web Services), as well as management of e-mail services (entrusted to MailJet), in their capacity as processors.
VI. Disclosure of data
Without the express consent of the User (under Article 6(b) GDPR), Almo Nature may disclose the User’s 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 Users’ data will not be disseminated.
VII. Data transfer
The personal data provided by a registered User to enable the sending of commercial communications by e-mail on products, promotions and/or services offered by Almo Nature and/or newsletters containing insights into the main issues related to food, health and animal welfare are processed electronically through the use of the provider, Mailjet; the relevant information on Privacy can be found on the site. In this context, the data will be processed and stored within the European Union.
The data will be processed through the Oracle software; the relevant information on Privacy can be found here.
In this case, data will be transferred to the United States. Oracle is certified under the Privacy Shield and the transfer of data outside the territory of the European Union is authorised under Article 45 GDPR, on the basis of the Commission’s adequacy decision no. 2016/1250 of 12 July 2016.
The data will also be stored in the Amazon web services cloud; the relevant information on Privacy can be found here.
In this context, personal data will be transferred to the United States. As Amazon Web Services is certified in accordance with the “Privacy Shield”, the transfer outside the European Union is authorised, in accordance with Article 45 of EU Regulation No. 2016/679, on the basis of the adequacy decision of the European Commission 2016/1250 of 12 July 2016.
Apart from this case, the management and storage of data will take place on Almo Nature.
VIII. Third party websites
Please note that, if the Site contains links to third party websites, Almo Naturehas no 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 onlycontrollers and processors of the personal data of its users, while Almo Nature will remain unconnected to this activity as well as to any liability, prejudice, cost, which may arise from its failure or incorrect performance.
IX. User’s rights
The User has the rights referred to in Article 15 GDPR.
More specifically, the User has the right, at any time, to obtain confirmation from Almo Nature as to whether or not personal data concerning him or her exists, even if not yet recorded, and their communication in intelligible form.
The User 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 recipientsor 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 User 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 User 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;
- lodge a complaint to the relevant supervisory authority.
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 User 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 firstname.lastname@example.org.
X. Withdrawal of consent and objection
If the User has given his or her consent to processingfor 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 email@example.com or by clicking on the relevant link.
Following receipt of this opt-out request, Almo Nature 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. Controllerand processor
The Controller is Almo Nature Netherlands BV – firstname.lastname@example.org
The Processors are:
- Almo Nature Benefit S.p.A. with registered office in Genoa (Italy), Piazza Giustiniani 6, as Site email@example.com
- MailJet SAS with registered office in Paris (France) 13-13 bis, Rue de l’Aubrac – 75012, e-mail: firstname.lastname@example.org, as e-mail service provider.
- Oracle500 Oracle Parkway Redwood Shores, CA 94065, USA Tel: +1 650 506 7000.Chief Privacy Officer, Oracle Corporation 10 Van de Graaff Drive Burlington, MA 01803, USA
- Amazon web services
The complete and updated list of the persons in charge of processing is kept at the registered office of Almo Nature and can be requested as set out in Article X above.
Please note that this Policy will be subject to periodic updates which will be published on the Site.
XI. Date of last update