PRIVACY POLICY PURSUANT TO ARTICLE 13 EU REG. 679/2016

San Marzano Vini S.p.A. hereby informs you and all the users and/or visitors of the website https://www.sanmarzano.wine (respectively the “Users” and the “Website“), about the use of personal data, collected and processed via the Website in accordance with the privacy legislation in force and, specifically, the:

  • EU Regulation No. 679 dated 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of personal data (hereinafter the “EU Regulation“);
  • Legislative Decree No. 196 dated 30 June 2003 (hereinafter the “Privacy Code“), as novated by Legislative Decree No. 101 dated 10 August 2018;
  • Recommendation no. 2 dated 17 May 2001 on minimum requirements for online data collection in the European Union, adopted by the European authorities for the protection of personal data, meeting in the Group set out by Article 29 of Directive no. 95/46/EC (hereinafter the “Recommendation of the Working Group pursuant to Article 29”).

Specifically, the processing of personal data may be carried out by persons specifically authorised to carry out processing operations on the personal data of Users and, to this end, duly instructed by the Company.

In application of the legislation on the processing of personal data, Users who consult and use the Company’s website become “data subjects”, namely, the individuals to whom the personal data being processed refers.

It should be noted that the information does not extend to other websites that may be consulted by Users through links, including Social Buttons, present on the Company’s website.

Specifically, Social Buttons are digital buttons or direct links to Social Network platforms (such as, by way of example, LinkedIn, Facebook, Twitter, YouTube), configured in each “button”.

By clicking on said links, Users shall be able to access the Company’s social accounts.
The managers of the Social Networks, to which the Social Buttons refer, act as autonomous Data Controllers; consequently, all information relating to the modalities through which the aforementioned Data Controllers carry out the processing operations on the personal data of the users can be found in the relative Social Network platforms.

1. Data Controller and Data Processors
The data controller for the personal data is San Marzano Vini S.p.A. (VAT No. 03017840731), with registered office in 74020 San Marzano di S.G. (TA), Via Monsignor Bello n. 9, email privacy@sanmarzanovini.com (hereinafter the “Data Controller“).
An updated list of the designated Data Processors can be provided upon request by data subjects and/or Users.

2. Information automatically collected by the Website
In consideration of the interaction with the Website, the Company may process the following personal data of the Users:

  • a. Browsing data: the computer systems and software procedures used to operate this Website acquire, during normal operation, some personal data the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with personal data held by third parties, allow for the identification of Users. This category of personal data includes IP addresses or domain names of the computers used by the Users who connect to the Website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the User’s operating system and computer environment. These personal data are used only to obtain anonymous statistical information on the use of the website and to check its correct functioning.
    Browsing data do not persist for more than (12 months), except for any need to ascertain crimes by the judicial authorities.
  • b. Personal data voluntarily provided: the optional, explicit and voluntary transmission of personal data to the Company, by filling out the forms on the Website, involves the obtaining of the email address and all other personal data of the Users requested by the Company in order to comply with specific requests.
    With reference to the processing of personal data provided by virtue of filling in the contact form, newsletter and e-commerce placed on the Website, please refer to the relative Contact form, newsletter and e-commerce information.

3. Purpose and legal basis of personal data processing
As regards the personal data referred to in point 2), section a) of this informative report, the personal data of the Users are processed, in an automatic and “obligatory” manner, by the Company in order to: i) allow for browsing itself; in this case, the processing takes place on the basis of a legal obligation to which the Company is subject, as well as on the basis of the legitimate interest of the Company to ensure the proper functioning and security of the Website; therefore, the express consent of the Users is not necessary.
As regards the personal data referred to in point 2), section b) of this policy, the processing is carried out in order to:

  • ii) provide information or assistance to Users, as per the specific information provided via the link https://sanmarzano.wine/en/legals/privacy-policy-contacts/;
  • iii) use the e-commerce platform and related services, as per the specific privacy policy via the following link www.sanmarzano.wine/legals/privacy-policy-shop;
  • iv) receive the newsletter, the information of which can be found via the following link https://sanmarzano.wine/en/legals/newsletter-information/.
  • v) gain your loyalty and access to the benefits of our Wine Club, the information of which is available via the following link_________.
    The data you provide shall be processed mainly by computer under the authority of the data controller, by persons specifically entitled, authorised and trained to process data, pursuant to article 2-quaterdecies of the Privacy Code and article 29 of the Privacy Regulation. We hereby inform you that appropriate security measures are complied with in accordance with Articles 5 and 32 of the Privacy Regulation to prevent loss of data, illegal or incorrect use and unauthorised access.

4. Type of data provided
With reference to the purposes referred to in Article 3, points ii), iii), iv) and v), please refer to what is expressly indicated in the specific information referred to in this Privacy Policy; for the purposes referred to in point i) of Article 3 above, the provision of your personal data is necessary given that, without it, you shall not be able to use the services offered by the Website. Consequently, for the purpose referred to in point i), the legal basis of the processing is the fulfilment of legal obligations, pursuant to Article 6, paragraph 1, section c) of the Privacy Regulation.

5. To whom and to what extent we may pass on your data
Your data may be disclosed, within the EU, to external facilities, subjects and companies (including consultants and service providers) which the Data Controller uses to manage the Website and to carry out activities connected, instrumental or consequent to the execution of the services offered by the Website.
Further details regarding the above are contained in the specific information reported or displayed on the Website and prepared for the relative services on request.

6. Your rights
At any time, you can exercise your rights under Article 15 et seq. of the Privacy Regulation, for access, rectification, transformation, blocking, erasure, restriction of treatment, in the manner and within the limits set out by Article 12 of the Privacy Regulation.
In the event of a of lack of timely response or inadequate response from the writing company, or if you believe there has been a breach of the Privacy Code and/or of the Privacy Regulation, you may appeal to the Personal Data Protection Authority, via the following contact details: www.gpdp.it – www.garanteprivacy.it, Email: protocollo@gpdp.it, Telephone switchboard: (+39) 06.69677.1.

7. Security measures
Via the Website, your data is processed in compliance with applicable law and using appropriate security measures in accordance with the regulations in force, also pursuant to Articles 5 and 32 of the Privacy Regulation.
In this regard, we confirm, amongst other things, the adoption of appropriate security measures to prevent unauthorised access, theft, disclosure, modification or destruction of your data.

8. Cookies
The Website www.sanmarzano.wine (the “Website”) uses cookies. Cookies are text files stored on a computer medium, which record certain parameters and data disclosed to the computer system, via the browser you use. These tools therefore analyse your habits in using the Website, for different purposes: execution of computer authentication, session monitoring, storage of information on specific configurations concerning users who access the server, storing preferences, etc.
Cookies are divided into:

Technical cookies: used for browsing or to provide a service you have requested. Without the use of these cookies, certain procedures cannot be carried out or would be more complex and/or less secure.

Profiling cookies: are used to track your browsing and create profiles on your tastes, habits, choices, etc.. In this way, advertising messages can be sent to your device in line with your preferences already expressed in the previous online browsing.
Your consent is not required for the installation of technical cookies. Your consent is required for the installation of profiling cookies when you access the Website. If you do not want your device to receive and store any more profiling cookies, to which you have given your consent, you can change or withdraw your consent through the button below: “Change your consent”
It should be noted, however, that, by deactivating the use of profiling cookies, you will not be able to take full advantage of certain functions of the Website.

Whilst browsing the Website, you may also receive cookies on your terminal that are sent from different sites or web servers (hereinafter “Third Parties“). The Third Parties, who use cookies on our Website, are:

9. Changes to the Privacy Policy
The Data Controller reserves the right to make changes to this Privacy Policy. In this case, you will be promptly informed when you use the Website again.