Privacy Policy

Almo Nature Netherlands BV with registered office at Communicatieweg 3, 1-hoog, 3641SG te Mijdrecht, The Netherlands, acting as Data Controller (hereinafter, “Almo Nature”), advises, in accordance with Article 13 of Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation or “GDPR”), that it will use the data of users (hereinafter, “User” and/or “Users”) collected through the website www.almonature.com (hereinafter, the “Website”) in the manner and for the purposes described below.

 

I. Type of data processed by Almo Nature through the Website

Almo Nature processes the following types of personal data (hereinafter, “Data”) provided by Users of the Website when browsing and/or subscribing to the newsletter:

  1. Data obtained while a User is browsing on the Website
    The computer systems, cookie technology and software procedures used in the operating procedures of the Website www.almonature.com acquire, during their normal operations, certain Data whose transmission is implicit when using the Internet. This information is not collected to be associated to identified data subjects, but by their very nature could, through processing and association with Data held by third parties, allow Users to be identified while browsing. This category of Data includes, for example, the pages visited by Users inside the same, domain names and internet website addresses from which the User has logged on (by referral) to the Website, addresses in URI notation (Uniform Resource Identifier) 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 reply, the numerical code indicating the status of the response provided by the web server, and other parameters relating to the browser type (e.g. Internet Explorer, Firefox), operating system (e.g. Macintosh, Windows) and the User’s IT environment.

    These Data are collected using technical cookies and analytics cookies. For more information on browsing data, Users are asked to consult the Cookie Policy of the Website.

  1. Data provided by Users
    Most of the pages and content on the Website are accessed by the User (“Unregistered User”) without requiring his/her identification for browsing purposes. Logging on and browsing the Website does not require any registration, except when subscribing to the newsletter.

    In this case, the User shall provide the following personal details to Almo Nature: full name (first name and surname), e-mail address, city of residence, telephone number.

  1. Data provided by Professional Users
    Users falling under certain professional categories may register in the “Reserved Area” of the Website where they shall declare, under their sole responsibility, to have the requirements to log on (hereinafter, “Professional User” and/or “Professional Users”). In this case, they will provide Almo Nature, while registering in the “Reserved Area”, their personal details, including their full name (first name and surname) and e-mail address, and they will receive their own personalised password from the system to log on the “Reserved Area”.
  1. Data provided in the context of the “Donation Desk” project
    Users, whether representing a non-profit association or a profit association, may register their names in the special area to join the “Donation Desk” project. In that case, Users will provide Almo Nature with their personal details when registering, including their name and a copy of their identity card to be mandatorily included so as to activate their authentication credentials (login + password) with which Users will be subsequently identified during the course of the project.

 

II. Purpose of the processing

  1. The Data provided by Users, both registered and non-registered, will be processed without the Users’ prior consent in accordance with Article 6, letter b) of the GDPR, for the following purposes of the service:
    1. to manage and process statistical surveys on Website use;
    2. to perform the maintenance and technical assistance necessary to ensure the proper functioning of the Website and its related services;
    3. to improve the quality and structure of the Website and to create new services, functions and/or features thereof;
    4. to process any contact request submitted by the User while filling out the specific form or by e-mail, for example to receive explanations on the services offered by Almo Nature;
    5. to enable Almo Nature to exercise its rights in court and to crack down on illegal conduct;
    6. to fulfil legal obligations or comply with regulations.
  2. The Data provided by registered Users and by Professional Users will be processed with the Users’ consent, which will be separate, specific and individual for every item of this paragraph, in accordance with Article 6, letter a) of the GDPR, for the following purposes:
    1. to allow sending commercial, promotional and advertising notices to registered Users through automated systems, such as e-mail, on products, activities and/or services offered by Almo Nature and newsletters containing insights on the main topics related to dog and cat nutrition, their welfare and their protection;
    2. to allow their transfer to the Capellino Foundation in order to send promotional and advertising material through automated systems, such as e-mails, on the initiatives, opportunities and services offered by the Capellino Foundation on projects for the protection of dogs, cats and biodiversity;
    3. for profiling User consumption preferences according to parameters established by Almo Nature in connection with the pursuit of its commercial and business activities. The processing of such Data will consequently provide a profile of the data subject, referred to herein as the User. By analysing the parameters established by Almo Nature, processing for profiling purposes will therefore permit processing, using analytical and/or comparative methods, so as to send to the User who had provided that specific consent to processing personalised offers or to communicate specific promotions in connection with the User’s profile.
  3. The data provided by the registered User in the context of the “Donation Desk” project will be processed with the User’s consent, which will be separate, specific and individual for every item of this paragraph, in accordance with Article 6, letter a) of the GDPR, for the following purposes:
    1. to allow for participating in the “Donation Desk” project and to allow Almo Nature to manage the steps related to organising and developing the project;
    2. to allow sending commercial, promotional and advertising notices to registered Users through automated systems, such as e-mail, on products, activities and/or services offered by Almo Nature and newsletters containing insights on the main topics related to dog and cat nutrition, their welfare and their protection;
    3. to allow their transfer to the Capellino Foundation in order to send promotional and advertising material through automated systems, such as e-mail, on the initiatives, opportunities and services offered by the Capellino Foundation on projects for the protection of dogs, cats and biodiversity;
    4. for profiling User consumption preferences according to parameters established by Almo Nature in connection with the pursuit of its commercial and business activities. The processing of such Data will consequently provide a profile of the data subject, referred to herein as the User. By analysing the parameters established by Almo Nature, processing for profiling purposes will therefore permit processing, using analytical and/or comparative methods, so to send to the User who had provided that specific consent to processing personalised offers or to communicate specific promotions in connection with the User’s profile.

 

III. Nature of the Provision of Data

The provision of data by the User is mandatory for the purposes of the service referred to under Clause 2, paragraph 1 above. However, any refusal to provide such data may make it impossible to provide the services.

However, the provision of data by the User is voluntary and optional (and may be withdrawn without any formality, even after providing the service, by sending an e-mail to privacy@almonature.com) for the purposes referred to under Clause 2, paragraphs 2 and 3 above. Any refusal to provide Data will therefore only result in, for paragraph 2(1), failure to send commercial notices on products, activities or services to the User offered by Almo Nature and/or newsletters; for paragraph 2(2), failure to send commercial notices on events, initiatives and/or services to the User and to the Professional User offered by the Capellino Foundation and/or newsletters; for paragraph 2(3), the impossibility for Almo Nature to carry out the abovementioned processing for profiling purposes; for paragraph 3(1) the impossibility for the User to participate in the “Donation Desk” project; for paragraph 3(2), failure to send commercial notices to the User on products, initiatives or services offered by Almo Nature and/or newsletters; for paragraph 3(3), failure to send commercial notices on events, initiatives and/or services to the User and to the Professional User offered by the Capellino Foundation and/or newsletters; for paragraph 3(4), the impossibility for Almo Nature to carry out the abovementioned processing for profiling purposes.

In any event, the User may still use the services described under Clause 2, paragraph 1 above.

 

IV. Means of processing and storage

  1. The processing of the User’s personal data is carried out through the operations indicated in Article 4(2) of the GDPR, and specifically: collection, recording, organisation, storage, consultation, elaboration, modification, extraction, comparison, access, use, alignment, restriction, dissemination, erasure or destruction;
  2. The User’s Data are processed manually and with automated instruments, and only for the period necessary for the purposes for which they were collected and, in any case, for a period no longer than 10 years from their collection for the purposes of the service referred to at Clause II, paragraph 1, above, and for a period no longer than 10 years from their collection for the purposes referred to at Clause II, paragraphs 2 and 3, above.
  3. The User’s data will be processed by persons specifically authorised to carry out the tasks referred to at Clause I above; they will always be duly identified and instructed and informed on any security obligations imposed by the GDPR and Almo Nature.

 

V. Access to Data

Data may only be made accessible for the above purposes to the following persons:

  • Employees and staff of Almo Nature or its affiliates and/or parent company, in their capacity as persons authorised to process the Data;
  • Third-party entities or other persons (including, without limitation, associations or professional firms providing consulting and advisory services and especially, without limitation, IT management services for the IT system used by Almo Nature S.p.A. and telecommunication networks, providers (managed by Amazon Web Services), and email management services (by MailJet)), in their capacity as processors.

 

VI. Disclosure of Data

Without the User’s prior express consent (under Article 6, points (b) of the GDPR), Almo Nature may only disclose the User’s data for the purposes of the Service referred to at Clause II, paragraph 1, to supervisory bodies, judicial authorities and any other entities to which such disclosure must be made under the law for the above purposes, in their capacity as independent controllers. The User’s data will not be disclosed.

 

VII. Transfer of Data

The Data obtained from the registered User for the purpose of sending commercial messages via e-mail relating to Almo Nature’s products, events and/or services and/or newsletters with insights on the main topics concerning pet nutrition, health, wellness are processed in computerised form through the Mailjet provider; Mailjet privacy policy is available at https://www.mailjet.com/privacy-policy/. These Data will be processed and stored within the European Union.

Data will also be stored on Amazon Web Services’ cloud; Amazon Web Services’ privacy policy is available at https://aws.amazon.com/it/compliance/gdpr-center/?nc1=h_ls.

These Data will be transferred to the United States. Amazon Web Services is certified under the “Privacy Shield” and the transfer of personal data outside the European Union is authorised under Article 45 of Regulation (EU) 2016/679, based on Commission Implementing Decision (EU) 2016/1250 of 12 July 2016

In any other case, Data will be managed and stored in servers held by Almo Nature S.p.A. as processor within the European Union.

 

 

VIII. Third-party websites

Please note that, to the extent the Website contains links to third-party websites, Almo Nature has no control over their content and will not have access to personal data concerning the users of those websites.

The owners of those websites will be the exclusive data controllers and processors with regards to their users. Almo Nature assumes no responsibility for third-parties’ activities or any liability, damage or cost resulting from any failed or incorrect processing by third-parties.

We recommend that the User reads these third-party websites’ privacy policies and terms of use before consenting to any processing of their personal data.

 

IX. User’s rights

The User may exercise the rights referred to in Article 15 of the GDPR.

More specifically, the User will have the right to obtain from Almo Nature confirmation as to whether or not Data concerning him or her are being processed, including prior to the User’s registration, and to obtain such Data in intelligible form.

The User will have the right to obtain confirmation as to:

  1. the origin of the Data;
  2. the purposes and means of the processing;
  3. the rationale of any processing carried out by automated means;
  4. the identification information on the controller, the processors and the designated representative;
  5. the persons or categories of persons to whom the Data may be disclosed in their capacity as designated representatives in Italy, processors or persons in charge of the processing;
  6. the retention periods.

The User will also have the right to obtain:

  1. a) the update, rectification or, when it is in his or her interest, integration of Data;
  2. b) the erasure or anonymisation, or the restriction of the processing, of any Data processed in violation of any laws, including Data whose retention is not necessary for the purposes for which they have been collected or processed;
  3. c) a certification that the activities indicated at letters (a) and (b) above were notified – including with regards to their content – to the persons that received that Data, unless this proves impossible or involves disproportionate effort compared to the right being protected.

The User will have the right to object, in whole or in part, to: (1) if he or she has legitimate grounds to do so, the processing of Data concerning him or her, including if they are within the scope of the processing; (2) the processing of Data concerning him or her for the purpose of sending advertising material or carrying out direct sales or market surveys or commercial communications (e.g. newsletters).

The User will have the right to

  1. obtain the restriction of the processing of Data or object to such processing;
  2. data portability, i.e. to receive the Data from the controller in a structured, commonly used and machine-readable format, and transmit those data to another controller without hindrance from the initial controller;
  3. withdraw his or her consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  4. lodge a complaint with the Supervisory Authority.

Any rectification or erasure of Data or restriction of processing will be communicated to each recipient to whom the Data have been disclosed, unless this proves impossible or involves disproportionate effort. The User will have the right to receive a list of those recipients upon request.

The User may exercise these rights without any restriction, free of charge and by sending an e-mail to privacy@almonature.com

 

X. Withdrawal of consent and objection

If the User has given his or her consent to the processing for the purposes referred to at Clause II, paragraph 2 and 3, above, he or she may withdraw that consent at any time by sending a clear e-mail, without any specific formalities, at privacy@almonature.com or by clicking on the related link.

After receiving this opt-out request, Almo Nature will immediately erase any Data and instruct any third-party to whom the Data has been disclosed to do so as well. The reception of this opt-out request will constitute confirmation that the Data have been erased.

The User is specifically and expressly informed that, under Article 21 of the GDPR, he or she will have the right to object at any time to processing of Data concerning him or her and, where the User objects to the processing of Data for direct marketing purposes, such Data will no longer be processed for such purposes.

 

XI. Data Controller and Data Processor

A complete and updated list of the persons in charge of the processing is available at Almo Nature’s registered office and may be requested as indicated at Clause X above.

 

XII. Update of this Privacy Policy

This Privacy Policy will be regularly updated. All updates will be notified on the Website.

 

XIII. Last updated

This Privacy Policy was last updated on 24 May 2018