PRIVACY POLICY FOR VISITORS TO THE WEBSITE

Foreword

This Privacy Policy is intended to describe the management of this website, with reference to the processing of personal data of users/visitors who consult it.

This notice is provided in accordance with art. 13 of EU Regulation 679/16 regarding the protection of personal data to those who connect to the corporate website of Brambati SpA at the addresses www.brambati.it and foodlab.brambati.it

The notice is only provided for the websites mentioned above and not for other websites that may be consulted by the user through special links on the websites.

The websites www.brambati.it and foodlab.brambati.it are owned and managed by Brambati SpA, which guarantees compliance with the provisions of EU Regulation 679/16 and, for parts not in contrast, of (It.) Legislative Decree 196/03.

Users/visitors must read the specific notice shown at the link below and on the contact form page carefully before providing their consent and sending any personal information and/or filling in any electronic form posted on the website itself.

Browsing data (TBV)

Information systems and software procedures used to operate the website acquire, during the normal course of operation, some personal data whose transmission is implicit in use of internet communication protocols. It concerns information that is not collected to be associated with specific individuals, but by its own very nature might, through the processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by users who connect to the website, URI addresses (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply from the

server (successful, error, etc.) and other parameters related to the operating system and the users. This data is only used to obtain anonymous statistical information on the website and make sure it operates correctly and is deleted immediately after processing. The data might be used to ascertain responsibility in case of hypothetical computer crimes against the website: except for this possibility, the data on web contacts is not stored for more than seven days.

Cookies (TBV)

Cookies are not used for the transmission of personal information, no so-called persistent cookies of any kind are used, as well as systems for tracking users. The use of so-called session cookies (which are stored temporarily by the user’s computer and which are normally deleted when the browser is closed) is strictly limited to transfers of the session identification data (consisting in random numbers generated by the server) required for secure, efficient website browsing. The so-called session cookies used on this website avoid the need to use other data processing techniques which might potentially reduce the confidentiality of the users' browsing on the website and would not permit the acquisition of personal information identifying the user.

Location of the data processing

Processing connected to the aforementioned website services occurs at the registered offices of Brambati SpA, via Strada Nuova no. 37 – 27050 Codevilla (PV), of the Data Controller and/or at the headquarters of the hosting company and are only handled by the Data Processor who provides sufficient guarantees to put in place suitable technical and organisational measures to ensure the protection of the rights of the data subject (art. 28 of EU regulation 679/16) and staff acting under their direct responsibility. No data deriving from the web service is transmitted or disclosed.


Data Controller

BRAMBATI SPA, via Strada Nuova no. 37 – 27050 Codevilla (PV) VAT no. 00516930187 in the person of its Legal Representative Mr. Fabrizio Brambati, e-mail titolare_trattamento@brambati.it , the in-house Data Processor is Mr. Andrea Brambati, e-mail responsabile_trattamento@brambati.it .

Rights of the data subject

The data subject may at any time contact the Data Controller to exercise the rights reserved to him/her, as provided for by Regulation EU 679/16, such as:

Right of access by the data subject (art. 15 of EU regulation 679/16)

1. The data subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data concerned;

c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

d) where possible, the intended period for which the personal data will be stored, or, if not possible, the criteria used to determine said period;

e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

f) the right to lodge a complaint with a supervisory authority;

g) where the personal data are not collected from the data subject, any available information as to their source;

h) the existence of automated decision-making, including profiling, referred to in Article 22, paragraph 1 and 4 and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

3. The Data Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the Data Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Right to rectification (art. 16 of EU regulation 679/16)

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (art. 17 of EU regulation 679/16)

1. The data subject shall have the right to obtain from the Data Controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b) the data subject withdraws consent on which the processing is based according to Article 6, paragraph 1, letter a) or Article 9, paragraph 2, letter a) and where there is no other legal ground for the processing;

c) the data subject objects to the processing pursuant to Article 21, paragraph 1, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21, paragraph 2;

d) the personal data have been unlawfully processed;

e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

f) the personal data have been collected in relation to the offer of information society services referred to in Article 8, paragraph 1.

2. Where the Data Controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the Data Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform Data Controllers which are processing the personal data that the data subject has requested the erasure by such Data Controllers of any links to, or copy or replication of, those personal data.

3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

a) for exercising the right of freedom of expression and information;

b) for compliance with a legal obligation which requires processing by Union or Member State law to which the Data Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

c) for reasons of public interest in the area of public health in accordance with Article 9, paragraph 2 letter h) and i) as well as Article 9, paragraph 3;

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89, paragraph 1 in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e) for the establishment, exercise or defence of legal claims.

Right to restriction of processing (art. 18 of EU regulation 679/16)

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

d) the data subject has objected to processing pursuant to Article 21, paragraph 1, pending the verification whether the legitimate grounds of the Data Controller override those of the data subject.

2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the Data Controller before the restriction of processing is lifted.

Right to data portability (art. 20 of EU regulation 679/16)

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Data Controller without hindrance from the Data Controller to which the personal data have been provided, where:

a) the processing is based on the consent pursuant to Article 6, paragraph 1, letter a) or Article 9, paragraph 2, letter a) or on a contract pursuant to Article 6 paragraph 1 letter b); and

b) the processing is carried out by automated means.

2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Right to object (art. 20 of EU regulation 679/16)

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on Article 6, paragraph 1, letter 3) or f), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6. Where personal data are processed for scientific or historical research or statistical purposes pursuant to Article 89, paragraph1, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

The complete text of Regulation EU 679/16 (GDPR) and (It.) Legislative Decree 196/03 (Privacy Code) is available on the website www.garanteprivacy.it.