Website Privacy Policy
Terre di Eolo S.R.L. Società Agricola, with registered office in via del Gallitello 55, Potenza 85100 P iva 01492930761, is committed to protecting the online privacy of the users of this website ("Website") and will do everything in its power to ensure that users' Personal Data are treated with respect for their fundamental rights and freedoms and for their personal dignity, in particular as regards confidentiality. To this end, this Privacy Policy has been drawn up to enable users to understand the policy of Terre di Eolo S.R.L. Società Agricola regarding privacy and the way in which personal information will be treated when using the Website. This Privacy Policy will also provide information so that users can consent, where appropriate, to the processing of their personal data in an explicit and informed manner. In general, the information and data that you provide to Terre di Eolo S.R.L. Società Agricola through the Website or otherwise collected through the Website by Terre di Eolo S.R.L. Società Agricola in connection with your use of the services of Terre di Eolo S.R.L. Società Agricola ("Services"), as better defined in Section 3 below, will be processed by Terre di Eolo S.R.L. Società Agricola in a lawful, fair and transparent manner, in accordance with Regulation (EU) 2016/679 ("GDPR"). To this end and as further described below, Terre di Eolo S.R.L. Società Agricola adopts internationally recognised principles governing the processing of personal data, such as lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimisation, data quality and confidentiality.
1. Data Controller and Data Protection Officer
Terre di Eolo S.R.L. Società Agricola, identified at the beginning of this Privacy Policy, is the data controller of all personal data processed through the Website. Terre di Eolo S.R.L. Società Agricola has appointed a Data Protection Officer (DPO) / Data Protection Officer. If you wish to contact the Data Protection Officer of Terre di Eolo S.R.L. Società Agricola regarding information on the processing of Personal Data by Terre di Eolo S.R.L. Società Agricola , including a list of its data processors, please write to: [email protected].
2. Personal data processed
When you use the Web Site, Terre di Eolo S.R.L. Società Agricola will collect and process information about you (as a natural person) that allows you to be identified either independently or in conjunction with other information already collected. Terre di Eolo S.R.L. Società Agricola may also collect and process information about other people in the same way if the user chooses to provide it. Terre di Eolo S.R.L. Società Agricola may also collect information about users through their representatives, employers or benefit plan sponsors and third parties who provide services to users, their employer or benefit plan sponsor (including insurance companies, benefit plan administrators and providers, brokers or agents, credit agencies and financial institutions). Such information may be classified as "Personal Data" and may be collected by Terre di Eolo S.R.L. Società Agricola either when the user chooses to provide it (e.g. when requesting the Services provided by Terre di Eolo S.R.L. Società Agricola on the Website) or simply by analysing the user's behaviour on the Website. The Personal Data that may be processed by Terre di Eolo S.R.L. Società Agricola through the Website are as follows:
2.1 Name, contact data and other personal data
Within the Website, you may be asked to provide information about yourself, such as your name, address, telephone/cell phone numbers, email address, date of birth, marital status and gender. You may also be asked to provide Personal Data of a financial nature, such as tax code or other financial identification numbers, bank details, credit/debit card information, social security information and salary. Terre di Eolo S.R.L. Società Agricola will also process information related to decisions made on the Website regarding benefits provided to you. Where applicable, your data will be processed:
(a) for essential purposes such as:
1. the creation and management of your account, and security, in the event of any registration;
2. the correct fulfilment of the obligations provided for by law, including the regulations on prize-winning events in the event of your participation in competitions or prize operations on the site;
3. to follow up any requests you may have made to Terre di Eolo S.R.L. Società Agricola, for example by sending spontaneous e-mail or traditional messages to the addresses of Terre di Eolo S.R.L. Società Agricola given on the site, which entail subsequent acquisition of the sender's address, including e-mail address, or telephone number necessary for responding to such requests, and of any other personal data included in the message.
For the processing of data for the purposes referred to under a) points 1 and 3, your consent is not required as the processing is necessary for the performance of a contract to which you are party or for the performance of pre-contractual measures taken at your request (Art. 6, para. 1, letter b) of the Regulation).
For the processing of data for the purpose referred to under a) point 2, your consent is not required as the processing is necessary to fulfil a legal obligation (Art. 6, para. 1, letter a) of the Regulation).
b) Subject to your consent, for marketing purposes, by sending you by post, e-mail, SMS, social networks, push notifications, fax and telephone, newsletters and commercial communications/offerings (including personalised ones, in the event of consent also given under point c below) from Terre di Eolo S.R.L. Società Agricola and/or other companies in the Terre di Eolo S.R.L. Società Agricola group or third party companies designated by them and for statistical analyses, surveys and market research relating to their products.
c) Subject to your consent, for profiling purposes, including but not limited to the processing of data relating to your purchasing choices, habits and preferences, geographical area of reference, as well as for the creation of profiles (individual and/or aggregated) for the purpose of proposing targeted offers that may be of interest to you.
Users are not required to provide any personal data in order to consult the public pages of this site. The provision of personal data for the purposes referred to in point a) is optional; however, failure to provide the necessary data (marked as such, if applicable, in the registration forms) makes it impossible to complete the registration process or to use the relevant service. The provision of any optional data is completely free of charge and does not affect the use of services or participation in prize competitions. The data are kept for the time strictly necessary to provide the service requested or required by law (e.g. data retention for the maximum time foreseen by law for the verification of the regularity of prize competitions or, in the case of data processing for marketing and profiling purposes, retention of the data for the maximum time provided for by law, 24 months for the purpose referred to in point b) in the case of marketing carried out on the basis of profiling data, and 12 months from the collection of the data for the purpose referred to in point c) or such longer period as may be allowed by the Regulations) and subsequently deleted, unless further retention obligations are provided for by law.
The acquisition of consent to the processing of personal data is not necessary for the purposes referred to in letters a.1, a.2 and a.3 and for all processing operations that are in any case connected with and/or necessary in order to comply with an obligation provided for by law, a regulation or Community legislation or to perform obligations deriving from a contract to which you are a party or to fulfil, prior to the conclusion of the contract, specific requests made by you. Consent to the processing of personal data for the purposes referred to in letters b) and c) of this information notice is, on the other hand, entirely optional and not compulsory; in the event of failure to consent to the purposes referred to in letter b) Terre di Eolo S.R.L. Società Agricola will not be able to keep you informed of new offers and promotions; whereas, with reference to the purposes referred to in letter c), failure to consent will make it impossible for us to offer you products or services that meet your needs or preferences. You may revoke one or more of the consents given at any time, or change your contact channels, by contacting Terre di Eolo S.R.L. Società Agricola in the ways indicated below. In any event, if you have given your consent for the purposes referred to in points b) and c), you will be asked to renew it each time you log in; if you fail to do so, your consent will be deemed revoked.
Your personal data will be processed exclusively by staff appointed by Terre di Eolo S.R.L. Società Agricola or by its external suppliers appointed as data processors. As part of its activities and for the purposes indicated above, Terre di Eolo S.R.L. Società Agricola may use the services of third parties who act on behalf of Terre di Eolo S.R.L. Società Agricola and according to its instructions, as data processors. These are parties that provide Terre di Eolo S.R.L. Società Agricola with processing or instrumental services (e.g. management of activities relating to prize competitions, consumer services, IT services for site operation, emailing). You may request a complete and updated list of the subjects appointed as data processors by contacting one of the contacts listed below. The data shall not be disclosed or transferred to third parties; it is understood that, in the event of any extraordinary corporate transactions, the data may be transferred or disclosed to third party purchasers/tenants or assignees.
2.2 Special Categories of Personal Data
In some areas of the Website you may be asked to provide health information, such as health insurance claim codes, information provided in connection with an application for health insurance or information relating to your health or mental health status or respective treatment, claims or payments for health care.
Please note that this information is processed by Terre di Eolo S.R.L. Società Agricola pursuant to the need to fulfil obligations and allow the exercise of rights as defined in applicable employment, social security and social protection laws or on the basis of the user`s explicit consent requested at the time of submission of Personal Data for such purposes.
2.3 Personal data of other persons
In the event that the user decides to share Personal Data relating to other persons on the Website, the user shall be considered the independent data controller for such Personal Data and shall assume all relevant legal obligations and responsibilities. This means, among other things, that it will be obliged to fully indemnify Terre di Eolo S.R.L. Società Agricola against any complaints, claims or requests for damages that may arise from the processing of such Personal Data, made by third parties whose information it provides through the Website. Since Terre di Eolo S.R.L. Società Agricola does not collect such information directly from such third parties (but collects it indirectly from you), you must ensure that you have their permission before providing Terre di Eolo S.R.L. Società Agricola with information about them; otherwise, you must ensure that there are other valid reasons for you to legitimately provide such information to Terre di Eolo S.R.L. Società Agricola .
2.4 Navigation Data
The operation of the Web Site, which is standard for any web site on the Internet, involves the use of computer systems and software procedures that collect information about users of the Web Site as part of their routine operation, the transmission of which is automatic when using Internet communication protocols. Although Terre di Eolo S.R.L. Società Agricola does not collect such information in order to associate it with specific users, it is nevertheless possible, due to its nature and through processing and association with other data held by third parties, that such information may allow the user to be identified directly or through the use of other information collected. Such information shall therefore also be considered Personal Data.
This information includes various parameters relating to the user`s operating system and computer environment, including the IP address, location (country), computer domain names, URI (Uniform Resource Identifier) addresses of the resources you request on the Website, the time of the requests made, the method used to make requests to the server, the size of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.) and so on.
Such data will be used by Terre di Eolo S.R.L. Società Agricola only in aggregate form for statistical and anonymous purposes related to the use of the Website, without associating them with the users' identifiers, to ensure its proper functioning and to detect any failure and/or abuse of the Website. Such data may also be used to define responsibilities in case of computer crimes committed against the Website.
2.5 Cookies
- Definitions, characteristics and implementation of standards
Cookies are small text files that can be sent and stored on the user's computer by websites visited and then sent back to those websites when the user logs in again. Thanks to these cookies, such websites can 'remember' actions and preferences (e.g. login data, language, font size, other display settings, etc.) so that the user does not have to reconfigure them on the next visit to the website or when changing pages within a website.
Cookies are used for electronic authentication, session tracking and storing information about user activity when accessing a website. They may also contain a unique ID code that allows tracking of browsing activities within a website for statistical or advertising purposes. Certain operations within a website cannot be performed without the use of cookies, which in some cases are technically necessary for the website to function. While browsing a website, it is also possible to receive cookies from websites or web servers other than the website you are visiting (i.e. 'third-party cookies').
Depending on their characteristics and functions, there are different types of cookies that can be saved on your computer for different periods of time: 'session cookies', which are automatically deleted when you close your browser, and 'persistent cookies', which remain on your device until the end of the predefined expiry period. Depending on the applicable laws, the user's consent may not always be required to use cookies on a website. In particular, "technical cookies" (i.e. cookies that are only used to send messages over an electronic communication network or are necessary to provide the requested services) generally do not require such consent. These include navigation or session cookies (used to allow users to log in) and function cookies (used to remember choices made by a user when accessing the website, such as language or products chosen for purchase).
On the other hand, 'profiling cookies' (i.e. cookies used to create profiles on users and send advertising messages in line with the preferences revealed by users while browsing websites) generally require specific consent from users, which may however vary depending on the applicable law.
- Types of cookies used by the website
The Web Site uses the following types of cookies:
Browsing or session cookies, which are strictly necessary for the operation of the Website and/or to enable the use of the Website content and Services.
Analytical cookies, which allow Terre di Eolo S.R.L. Società Agricola to understand how users use the Website and to track traffic to and from the Website.
Function cookies, used to activate specific functions of the Website and configure it according to the user's choices (e.g. language) to improve the browsing experience.
Cookie Settings
you can block or delete cookies used on the Website through your browser options. Your cookie preferences will be reset if you use different browsers to access the Website. For further information on how to set your cookie preferences using your browser, please refer to the following instructions:
Internet Explorer
Firefox
Chrome
Safari
it is also possible to set preferences for third-party cookies using online platforms such as AdChoice.
WARNING: if you block or delete the technical and/or function cookies used by the Website, your navigation may be impaired, some of the services or functions of the Website may no longer be available or other malfunctions may occur. In this case, you will have to change or manually enter certain information or preferences each time you access the Website. Terre di Eolo S.R.L. Società Agricola uses Google Analytics on the Website, a tool developed by Google and used to collect information to evaluate the use of the Website, analyse user behaviour and improve user experience with the Website. You can obtain more information on how to exclude Google Analytics at: https://tools.google.com/dlpage/gaoptout .
3 Purpose of processing
Terre di Eolo S.R.L. Società Agricola intends to use Personal Data collected through the Website for the following purposes:
to verify identity and provide assistance if the user loses or forgets login/password information for Terre di Eolo S.R.L. Società Agricola`s registration services, to enable the creation and maintenance of a registered user profile, to carry out required transactions and registrations, to enable the administration of the benefits programme, to contact the user when necessary and respond to requests and queries, to enable the purchase of services and products from third party suppliers, to process card payments and to provide any other Services requested by the user ("Provision of Services");
for the purpose of compliance with laws that require Terre di Eolo S.R.L. Società Agricola to collect and/or further process certain types of Personal Data ("Compliance");
prevent and detect any abuse of the Web Site or any fraudulent activities carried out through the Web Site ("Abuse/Fraud");
analysing and improving the Services, enhancing the Website, evaluating the effectiveness of marketing activities and the Services of Terre di Eolo S.R.L. Società Agricola, conducting statistical and demographic analysis of business customers and registered users of Terre di Eolo S.R.L. Società Agricola ("Analysis").
The provision of Personal Data for the above purposes is optional. However, failure to provide the requested data (indicated as such in the registration form, if applicable) may prevent users from completing the registration or availing themselves of the respective services.
4 Basis of processing and mandatory/discretionary nature of processing
The legal bases of Terre di Eolo S.R.L. Società Agricola for the processing of Personal Data in accordance with the purposes set out in Section 3 are as follows:
Provision of Services: processing for this purpose is necessary for the provision of Services and, consequently, for the performance of a contract signed with the user. For this purpose, the user is not obliged to provide personal data to Terre di Eolo S.R.L. Società Agricola; however, if this is not the case, Terre di Eolo S.R.L. Società Agricola cannot proceed to provide the Services.
Compliance: Processing for this purpose is necessary for Terre di Eolo S.R.L. Società Agricola to fulfil its legal obligations. When you provide Personal Data to Terre di Eolo S.R.L. Società Agricola, it is required to process it in accordance with applicable laws, which may include the retention and reporting of Personal Data to official authorities for the purpose of fulfilling tax, customs or other legal obligations.
Abuse/Fraud: processing for this purpose is necessary so that Terre di Eolo S.R.L. Società Agricola can pursue its legitimate interests in preventing and detecting fraudulent activities or abuse of the Website (for potentially criminal purposes);
Analysis: processing for this purpose is necessary for Terre di Eolo S.R.L. Società Agricola to pursue its legitimate interests in the development and administration of the Website and the improvement of the Services provided on the Website.
5 Recipients of Personal Data
Your Personal Data may be shared with the following natural/legal persons ('Recipients'):
individuals, companies or professional firms that provide Terre di Eolo S.R.L. Società Agricola with advice on accounting, administrative, legal, tax, financial and debt collection matters in connection with the provision of Services and that generally act as data processors on behalf of Terre di Eolo S.R.L. Società Agricola;
entities entrusted with the provision of the Services (e.g., affiliated third parties offering services and products available on the Website);
natural persons authorised to carry out technical maintenance (including maintenance of network equipment and electronic communications networks);
the user's employer or the sponsor of the benefit programme;
natural persons authorised by Terre di Eolo S.R.L. Società Agricola to process Personal Data necessary to carry out activities strictly related to the provision of Services who have undertaken an obligation of confidentiality or are subject to a legal obligation of confidentiality (e.g. employees of Terre di Eolo S.R.L. Società Agricola );
other companies within the Terre di Eolo S.R.L. Società Agricola Group for internal administrative purposes, including the processing of employees' personal data;
public entities, bodies or authorities to which your Personal Data may be transmitted, in accordance with applicable law or pursuant to binding orders of such entities, bodies or authorities.
6 Transfer of Personal Data
Your Personal Data may be transferred, for the purpose of providing the Services, to recipients located in various different countries, including countries outside the European Union. Terre di Eolo S.R.L. Società Agricola takes appropriate safeguards to ensure the lawfulness and security of transfers of Personal Data, for example, by relying on European Commission adequacy decisions or other safeguards or conditions deemed appropriate for such transfers. Further information on such transfers is available by sending a written request to Terre di Eolo S.R.L. Società Agricola at the following address: [email protected].
7 Storage of Personal Data
Personal Data processed for the purpose of providing the Services will be kept by Terre di Eolo S.R.L. Società Agricola for the period of time deemed strictly necessary for such purposes (however, given that such Personal Data are processed for the purpose of providing the Services, Terre di Eolo S.R.L. Società Agricola may continue to keep them for such longer period as may be necessary to protect the interests of Terre di Eolo S.R.L. Società Agricola related to any liability arising from the provision of the Services). Personal Data processed for Compliance purposes will be retained by Terre di Eolo S.R.L. Società Agricola for the period required by the specific legal obligation or applicable law. Personal Data processed for the purposes of Analyses will be kept by Terre di Eolo S.R.L. Società Agricola for the period deemed strictly necessary for the purposes for which they were collected.
8 Personal Data Security
All Personal Data collected and processed through the Website will be stored and processed in such a way as to minimise the risk of destruction, loss (including accidental loss), unauthorised access/use or use incompatible with the initial purpose of collection. This is achieved with the technical and organisational security measures implemented by Terre di Eolo S.R.L. Società Agricola . A detailed list of the security measures of Terre di Eolo S.R.L. Società Agricola can be found here.
9 Retention of Personal Data
Terre di Eolo S.R.L. Società Agricola will retain the User's Personal Data for as long as is strictly necessary according to the reasons for which it was collected:
Personal data collected for the purposes of providing the Services will be kept by Terre di Eolo S.R.L. Società Agricola for the period deemed strictly necessary for such purposes. However, the information will be kept for a longer period if it is necessary to deal with complaints relating to the Services or to protect the interests of Terre di Eolo S.R.L. Società Agricola in connection with any liability arising from the provision of the Services;
Personal Data processed for the purposes of Compliance shall be retained by Terre di Eolo S.R.L. Società Agricola for the period provided for by the specific legal obligations for which it was processed;
Personal Data processed for the purposes of the Analyses will be kept by Terre di Eolo S.R.L. Società Agricola for the period deemed strictly necessary for the purposes for which they were collected.
Once these periods have expired, all data will be deleted or anonymised, with the exception of data that must be kept longer by law.
10 Rights of data subjects
As a data subject, you may at any time exercise the following rights vis-à-vis Terre di Eolo S.R.L. Società Agricola :
obtain confirmation of the existence of personal data processed by Terre di Eolo S.R.L. Società Agricola, the possibility of accessing and having a copy of such data;
update, amend and/or rectify Personal Data if inaccurate or incomplete;
obtain the deletion of Personal Data if their processing is deemed unnecessary or otherwise unlawful, render Personal Data anonymous, block data whose processing is unlawful, or set limits on processing;
object to the processing of Personal Data, on the grounds related to the specific situation, because the user believes that they may prevent Terre di Eolo S.R.L. Società Agricola from processing Personal Data for a specific purpose;
request the restriction of the processing of Personal Data if the user believes that the Personal Data processed is inaccurate or that the processing is unnecessary or unlawful, in addition to the case of objecting to its processing; or portability: the user has the right to obtain a copy of the Personal Data provided to Terre di Eolo S.R.L. Società Agricola in a structured, commonly used and machine-readable format, as well as to request the transmission of such Personal Data to another data controller.
Please note that the Personal Data provided to Terre di Eolo S.R.L. Società Agricola can be modified at any time, including the user's email preferences, by accessing the user profile created on the Website, if applicable. In addition to the above means, you may exercise these rights at any time by sending a written request to the DPO/DPO of Terre di Eolo S.R.L. Società Agricola at the physical address and email address: [email protected].
Finally, you can lodge a complaint with the European Union Data Protection Authority or the data protection authority of the country of the Legal Entity Terre di Eolo S.R.L. Società Agricola, if you believe that the information has been handled unlawfully.
11 Amendments
This Privacy Policy came into effect on 30 April 2018.
Terre di Eolo S.R.L. Società Agricola reserves the right to amend this Privacy Policy in whole or in part, or simply to update its content, e.g. due to changes in applicable law. Terre di Eolo S.R.L. Società Agricola will inform you of such changes as soon as they are introduced and they will be binding as soon as they are published on the Website. Therefore, Terre di Eolo S.R.L. Società Agricola invites you to regularly consult this Privacy Policy for the latest updated version so that you are always aware of how personal data is collected and used by Terre di Eolo S.R.L. Società Agricola .