Processing of personal data
Browsing the Website/APP and/or accessing parts of the Website/APP https://www.gamberorosso.it or the "Ristoranti, Vino e magazine" mobile App (hereinafter "APP") and/or any requests of information or services contracted by users of the Site/APP may involve the processing of personal data by Gambero Rosso Spa (hereinafter "Owner"), as Data Controller, which will be in compliance with GDPR "regulation".
This information is intended to allow users browsing our Site to know, even before accessing the various sections of the Website/APP, how Gambero Rosso Spa treats users' personal data, and it will still be necessary for the user to read this section before sharing personal data when registering on the Website/APP.
Purposes of treatment
According to the needs expressed from time to time by users who access the various sections of the Site/APP (except for specific rules and information for individual operations that involve the provision of specific personal data, published from time to time on the Site/APP), the purposes of the processing of personal data are indicated below, i.e. those conferred directly by users by filling in online forms, or through the use of social networks (see following section "Nature and methods of providing Personal Data of users") or those acquired automatically by browsing (see the following section "Categories of Personal Data subject to processing") (hereinafter, "Personal Data"):
a) supply and manage the various services offered; as well as allowing registration on the Website/APP, which is necessary for accessing particular sections of the Website/APP itself, and providing and managing the various services offered;
b) allow users to publish Content directly on the Website/APP, or on sites independently managed by third parties with whom Gambero Rosso Spa has possibly reached agreements in this regard, such as, for example but not limited to, social networks such as Facebook, Twitter, etc. (hereinafter "Social Network"); Content may also be published together with a pseudonym ("nickname") chosen by the user during registration on the Website/APP, and possibly by the user image associated with his/her nickname for which: i) the user will be exclusively responsible for any choice that affects the interests of third parties; ii) the user is not required to use personal data that allows third parties other than Gambero Rosso to identify him or her, but the user, through Gambero Rosso Spa, may also disclose personal data if he has entered them in his nickname, as well as the photo associated with the profile.
c) subject to the user's consent and until revocation, carry out marketing activities such as sending promotional and advertising material of Gambero Rosso Spa, also by means of e-mail, mms and sms;
d) in compliance with legal requirements and in order to customize the user experience on the Website/APP and improve services and products offered by Gambero Rosso to its customers, or transmit profiled advertisements (with email, banners and dynamic content on the Website) on the basis of of users' tastes and browsing history, subject to the user's consent and up to the revocation of the same, to analyze consumption habits or choices and to define the profile of the interested parties using the information provided by the latter at time of registration, or when filling out questionnaires either on the basis of actions taken or information provided during navigation on the Website/APP. These purposes will also be implemented through the use of cookies;
e) respond to user requests in relation to Gambero Rosso Spa products, advertising, or the Website/APP ("Privacy" section of the Website/APP);
f) with prior user consent, and until the revocation of the same, carry out comparison and combination activities, for profiling purposes, of personal data of the user present in different databases of or in use by Gambero Rosso Spa.
User registration on the Website/APP is not required for the provision of certain services offered by Gambero Rosso Spa (Eg. those referred to in paragraph e). However, in order to process users' requests regarding these services, users will be asked to provide personal data, which will be processed only for the related purposes and for the time strictly necessary.
Lawfulness of treatment foundation - legal bases
The bases of lawfulness of the treatment are indicated in art. 6 of the GDPR and for the present disclaimer constitute fulfillment of contractual obligations:
| a) website services | Execution of contractual and pre-contractual measures at user's request |
| b) content publication | Consent of the interested party |
| c) marketing | Consent of the interested party |
| d) profiling | Consent of the interested party |
| e) answering user inquiries | Execution of contractual and pre-contractual measures at the user's request |
| f) profiling through comparisons and combinations of databases | Consent of the interested party |
Processing methods
Personal Data will be processed by means of collection, registration, organization, storage, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.
Personal Data will be processed mainly in automatic form, with logic strictly related to the aforementioned purposes, through the Data Base, personally managed electronic platforms or by third parties appointed for the purpose; for the updated list contact the Owner at the e-mail address below) and/or integrated IT systems and/or websites or APP owned or used by Gambero Rosso Spa.
In regards to profiling:
a) profiled data is personal information, telephone numbers and e-mail addresses.
b) objective of profiling is related to target customers, business and consumers.
Place of processing
Personal Data is mainly processed at the Data Controller's headquarters and in places where the Manager iand the authorized personnel are located in Rome, Via Ottavio Gasparri 13/17. For more information, please contact Data Controller at [email protected]
Data processing and storage time
The Data Controller will process Personal Data for a period of time that will not exceed the time necessary to achieve the purposes for which personal data is being processed, or for a longer period, for purposes permitted by law, and in any case cancelled without unjustified delay. Data processed for contractual purposes will be kept for the entire duration of the relationship; data processed for profiled marketing purposes will be kept for a period of 12 months. Users may at any time cancel their account or registration on the Website or request the interruption of the processing or revoke consent, in the manner indicated in the personal profile section of the Website.
Nature and methods of providing users' Personal Data
Nature of the provision of personal data is indicated in the following chart:
| a) website service | necessary |
| b) content publication | optional |
| c) marketing | optional |
| d) profiling by analysis | optional |
| e) respond to user requests | necessary |
| f) profiling through comparisons and combinations of databases | optional |
In cases indicated in letter a) and letter e), provision of data is necessary so that Gambero Rosso Spa can satisfy the user's needs in the functionalities of the Website/APP. The failure, partial or incorrect provision of Mandatory Personal Data, as necessary for the execution of the requested service, does not make such execution possible; while the failure, partial or incorrect provision of the Optional Personal Data does not entail any consequences.
The provision of Personal Data may take place: a) by filling out pertinet fields in the various sections of the Website/APP; or b) browsing the Website/APP or using cookies; or c) with automatic compilation, thanks to the request of the interested party to a Social Network which is registered to communicate to Gambero Rosso Spa part of the data that the interested party has already given to the Social Network; in the latter case, Gambero Rosso Spa recommends paying attention to the following:
i) selecting the link that allows registration through a Social Network, present on the Website/APP, or on one of Gambero Rosso Spa pages on the Social Network, a window will appear that will contain a box to tick to accept the communication of Personal Data from the Social Network to Gambero Rosso Spa and three links to select:
a) reading the present discolure agreement;
b) for the list of personal data either necessary or optional, according to specific processing purposes;
c) for the list of data that the Social Network is about to communicate to Gambero Rosso Spa;
ii) once the disclaimer has been read, and the box with which users declare to be of age learning which data is required to be transferred, users can then select the link referred to in point c) above to deselect those data not intending to provide to Gambero Rosso Spa through the communication of the same by the Social Network.
Both in the case of providing Personal Data with the compilation of appropriate fields, and in that of automatic compilation via the Social Network, if users fail to provide one or more necessary information, an error message will appear from Gambero Rosso Spa with the list of necessary Personal Data that’s missing.
Categories of Personal Data subject to processing
In addition to Personal Data provided directly by users (such as name, surname, postal address, e-mail address, password, age, date of birth, sex, etc.), when connecting to the Site, IT systems and software procedures for the operation of the Website itself administer and/or automatically and indirectly acquire some information that could constitute personal data, the transmission of which is implicit in the use of Internet communication protocols (such as, by way of example but not limited to, so-called "cookies" (As better specified below), "IP" addresses, domain names of computers used by users connecting to the Website, addresses in "Url" of requested resources, time of request to the server, navigation on Website/APP).
Categories of subjects that may be aware of users' Personal Data
Personal Data may be brought to the attention of employees or collaborators of the Data Controller who, operating under the direct authority of the latter, process data and are authorized for processing and who will receive adequate operational instructions in this regard from the Data Controller.
Personal Data may also be brought to the attention of the Data Controller's external Managers, if authorized with specific consent, such as third-party companies or other subjects (for example, subjects who are entrusted with assistance, communication, marketing, advertising, promotions and sales of products and/or services, advertisers, advertising dealers, IT service providers, Website managers, electronic platform managers) - who carry out outsourcing activities on behalf of Gambero Rosso Spa.
Scope of communication or spreading of users' Personal Data
Personal Data will not be disclosed to third parties, except for the hypotheses envisaged in the "purpose of processing".
Data controller and data processors
The data controller is Gambero Rosso Spa.
For any further request concerning the processing of personal data, send an e-mail to the Data Controller at the following e-mail address: [email protected]
Users’ rights
As interested parties, users have the right to ask data controller to access personal data and to correct or delete it or limit the processing of personal data concerning them, or to oppose their processing, in addition to the right to data portability; the right to withdraw consent at any time.
In particular the interested parties have the right, at any time, to revoke their consent, cancel their APP account and/or cease to be registered on the Website, requesting the interruption of processing, cancellation, transformation into anonymous form or blocking Personal Data therein processed.
Users can finally file a complaint with the Guarantor Authority where necessary, or contact the same to request information on the exercise of their rights deriving from the European regulation 2016/679 through the DPO whose contact details are: Head of Data Protection (RPD) which can be reached at the following address: Gambero Rosso SpA - Head of Personal Data Protection - via Ottavio Gasparri 13/17 - 00152, Rome, email: [email protected]
How to exercise the rights and to know the list of Data Processors
Users may, at any time, exercise their rights by sending an e-mail to [email protected] or a ordinary mail letter addressed to the Data Controller.
Furthermore, users, if agreed to, may object to the processing for the purposes referred to in letter c) by means of user's email address, by clicking on a special "link" present in every email message.