CONTROLLERSHIP OF THE DATA PROCESSING
The Data Controller of your personal data is Fratelli Carli S.p.A. with registered office in Italy - Via Garessio 11 - 18100 Imperia.
NATURE OF THE PERSONAL DATA
Your personal data are all the data entered by you in your account on the website www.oliocarli.us or given by you on the occasion of the telephone orders, online and in mail- orders to Fratelli Carli USA Inc. together with the purchased products, to the average ticket (i.e. the average of the amounts of the purchases made in the last 24 and 48 months).
SOURCE OF DATA
Your personal data are collected from Fratelli Carli USA Inc. that communicates them to Fratelli Carli S.p.A. through the insertion in the CRM shared by Fratelli Carli USA Inc. with Fratelli Carli S.p.A..
OPTIONALITY
The collection of personal data from Fratelli Carli USA Inc. is made on a voluntary and optional basis for the purposes specified in the short information released – if you purchased one of our products - on delivery or - if you are registered in the website www.oliocarli.us - at the confirmation of the registration process.
PLACE AND APPLICABLE LAW
Your data processing is performed in Italy by Fratelli Carli S.p.A. For your personal data processing Fratelli Carli S.p.A. shall apply the European legislation (General data Protection Regulation 2016/679/EU and the local legislation (Legislative Decree no.196/2003).
PURPOSES OF THE PROCESSING
If you purchase some of our products, Fratelli Carli S.p.A. may process your data in its Customer Relationship Management system – in order to profile you, and to define promotions and commercial offers as much as possible customized to your interests and to your purchase behaviors. The purpose of Fratelli Carli S.p.A. is to select in a homogenous way the targets of the commercial campaigns by Fratelli Carli USA Inc. (sending out price list and commercial communications to its customers).
PROFILING SOLUTION ADOPTED
On the basis of the analysis and of the automatic elaboration of some parameters performed in Business intelligence systems, Fratelli Carli S.p.A. can associate in an automatic way the information related to your previous orders and information related to orders of similar set of customers.
LEGAL BASIS FOR THE PROCESSING
The legal basis for the processing is the legitimate interest of Fratelli Carli S.p.A., which owns the Carli trademark, that produces Italian products, to inform you- in its quality of brand owner and “natural” marketer of its products - about the commercial opportunities related to Fratelli Carli’s products. As a matter of fact, you chose Fratelli Carli’s products just for the characteristics related to their Italian origin in accordance with your expectations.
DURATION OF THE DATA PROCESSING
Your data shall be processed for a time proportionate to the above mentioned legitimate interest and anyway by ensuring adequate protection of your rights and of your privacy from any risk.
EXTRA EU DATA TRANSFER
Company policy aims at minimizing the opportunities of transfer of personal data of costumers (even if established outside the EU) outside the EU. Only in some cases, in relation to some specific technical or assistance services (for instance maintenance of the software of the CRM management system,) a transfer outside the EU can occur, deriving by the service architecture offered by our providers, appointed as Data Processors (mainly in the U.S.). In these cases, the data transfer is made after the subscription with the provider of contractual clauses compliant with the standard defined by the EU Commission.
EFFECTS OF THE POSSIBLE OPT-OUT TO THE PROFILING
Fratelli Carli has appointed a Data Protection Officer (DPO) who is available for all the data subjects who want to exercise the rights recognized by the data protection legislation (art. 15-22 EU Regulation 679/2016). To opt-out to the profiling (i.e. if like to receive communications and offers, but you don’t want to receive customized offers) you can write to Data Protection Officer at the email address dpo@fratellicarli.com or use the section “My choices” of the website www.oliocarli.us.
In addition to opt-out to profiling purposes, you can ask Fratelli Carli S.p.A. not to process your data or to delete your data, and/or to be included in the blacklist. If you request Fratelli Carli S.p.A. shall automatically accept your request, giving up its interest in profiling you.
EXERCISE OF OTHER RIGHTS
At any time we will ensure the opportunity to contact us to request information / clarification regarding the utilization of personal data, submitting an email to the email address dpo@fratellicarli.com.
For any question about the products, you can write to customer.service.us@fratellicarli.com.
LEGAL PROTECTION
Any dispute related to the above described data processing shall be object of claim to the Italian Data Protection Supervisory Authority (“Garante”, protocollo@gpdp.it) or to the judicial authority.
