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PRIVACY POLICY UNDER ARTICLE 13 OF REGULATION (EU) No. 2016/679 

Dear User, 

This privacy policy has been drawn up in compliance with Article 13 of Regulation (EU) No. 2016/679 (also referred to as the “GDPR” or “Regulation”). It is intended for visitors to the website https://www.sacla.it who interact with the web services of F.lli Saclà S.p.A. The policy describes how personal data is processed and, where necessary, seeks informed and voluntary consent for such processing. 

This privacy policy applies to the website www.sacla.it and to all other websites of the Saclà Group (also collectively referred to as the “Website”), including – by way of example – www.sacla.fr, www.sacla.de, www.sacla.co.uk and www.sacla.us, which the user may access via links on these websites. 

1. DATA CONTROLLER AND DATA PROTECTION OFFICER 

The Data Controller is F.lli Saclà S.p.A., with its administrative headquarters at Piazza Amendola No. 2 – 14100 Asti (AT), Italy, which can be contacted by standard post or using the form available on the Website in the “Customer Service” section. 

2. CATEGORIES OF PERSONAL DATA PROCESSED BY THE WEBSITE WWW.SACLA.IT 

The section below describes the types of data processed and the methods used for this processing via the website. 

2.1. Browsing data 

The IT systems and software procedures used to operate the Website collect certain personal data during their normal operation. This data is transmitted implicitly when Internet communication protocols are used. Although this information is not collected with the intention of linking it to identified data subjects, it could, through processing and cross-referencing with data held by third parties, enable users to be identified. 

This category includes IP addresses or domain names of the computers used, 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 operating system and computer environment of the user. 

This data is used solely to compile anonymous statistical information and ensure the Website is functioning correctly. It is erased immediately after processing. Apart from establishing liability in the event of potential cybercrimes, web traffic data is currently retained for as long as necessary for statistical collection purposes. 

2.2 Data collected via cookies 

Cookies are small text files sent to and stored on your computer by the Website. They are then sent back to the Website when users visit it again. For further details, please refer to the Cookie Policy on the Website. 

2.3 Location data 

Subject to specific authorisation, the Website may collect approximate location data provided by the IP address. This data is also processed in an aggregated and anonymous form for statistical purposes. 

2.4 Data collected via the URL 

The Website may collect data on the viewing of certain promotional campaigns run by the Data Controller in order to assess their effectiveness. In such cases, personal data is collected in an anonymous format that does not allow the Data Controller to identify users. 

2.5 Data provided voluntarily by the user 

Some sections of the Website require personal data for account registration and/or to use the services (i.e., first name, surname, home or delivery address). 

Completing the forms in the various sections of the Website to request information requires explicit consent to the processing of the data contained therein, in order to process the enquiry accordingly. 

Notably: 

– to subscribe to the newsletter, users must complete the relevant form on the Website (or made in conjunction with events and trade fairs organised by F.lli Saclà S.p.A.) and also give their explicit consent to the processing of the personal data provided, in order for their subscription to be processed; 

– to access the “Thanks Planet” noticeboard, users must register by completing a specific online form. The form requires users to explicitly consent to their personal data being processed in order for the service to be provided; 

– access to the Consumer Service is granted upon completion of the relevant forms, which are available at https://www.sacla.it/servizio-customer/. Consent to the processing of the personal data contained within these forms is required to enable appropriate action to be taken; 

– to submit an application via the “Work with us” section at https://www.sacla.it/lavora-con-noi/, users must first register for the service and then create and set up a personal account. This process requires users to explicitly consent to the processing of their personal data, enabling the application to be assessed on its merits. For further details, please refer to the specific information available on the “Work with us” portal (https://sacla.intervieweb.it/). 

If users provide or process personal data relating to third parties while using the Website, the Data Controller guarantees that this processing is based on an appropriate legal basis as defined in Article 6 of the GDPR. This article legitimises the processing of that information. 

3. DATA CONCERNING CHILDREN 

The Saclà Group does not intentionally collect the personal data of anyone under the age of 16. Protecting children’s privacy is a priority for us. We encourage parents and those with parental responsibility to monitor and guide their children while they browse the Website. 

Children under the age of 16 must not provide any personal data or use any of the services available on this Website without the consent and supervision of a parent or guardian. If the Data Controller becomes aware that it has inadvertently collected personal data from a child under the age of 16 without the necessary authorisation, it will delete the data. 

4. PLACE AND PURPOSE OF THE DATA PROCESSING 

Data processing in connection with the web services on this Website takes place at the registered office of F.lli Saclà S.p.A., as mentioned above, and is carried out by staff appointed to process the data. The web service does not disclose any of its data. Any personal data provided by users when submitting specific requests (e.g., requests for information or complaints) will be used solely for the purpose of providing the requested service or performance or fulfilling any legal, accounting or tax obligations. This data may be disclosed to third parties only where necessary for these purposes or with the user’s consent. 

5. PURPOSES OF AND LEGAL BASIS FOR THE PROCESSING 

The user’s personal data will be processed for the following purposes, on the following legal bases, and for the following retention periods: 

  • Ensuring the proper functioning of the Website and the provision of relevant services, including monitoring their correct operation and handling support requests and complaints. For this purpose, the legal basis lies in the performance of a contract to which the data subject is a party. Personal data is retained for as long as is necessary for the proper functioning of the Website and the provision of services. In accordance with Article 5(1)(e) of Regulation (EU) No. 2016/679, the data will be erased or anonymised at the end of this period. The provision of personal data is necessary for this purpose. Any refusal to provide such data may prevent the company from delivering the requested service, complying with its legal obligations and processing and responding to user requests. 
  • Statistical analysis of performance through the use of cookies. The legal basis for this is the data subject’s consent. For more information, including details regarding the retention period, please consult the relevant Cookie Policy. 
  • Marketing. This includes sending advertising material and commercial communications by post; telephone calls with an operator; emails; SMS/MMS; automated calls (if the user has provided a telephone number); and via the Website and social media platforms. It also includes taking part in non-consumer-habit- or -preference-related surveys. The legal basis for this is the data subject’s consent, which may be withdrawn at any time. The retention period is 26 months from the date of collection, unless the data subject withdraws their consent before the end of that period. At the end of the 26-month period, personal data will be erased or anonymised automatically, permanently and irreversibly. For this purpose, the provision of personal data is optional. However, any refusal to provide the data may mean that users are unable to receive advertising material in the manner described above. 
  • Profiling. This is the analysis of consumer habits and related purchasing decisions, so that personalised recommendations can be offered and/or sent. The legal basis for this is the data subject’s consent, which may be withdrawn at any time. The retention period is 26 months from the date of collection, unless the data subject withdraws their consent before the end of that period. At the end of the 26-month period, personal data will be erased or anonymised automatically, permanently and irreversibly. For this purpose, the provision of personal data is optional. However, refusal to provide this information may mean that users will be unable to receive personalised offers based on their consumption habits. 
  • Prevention and suppression of fraud, abuse and fraudulent acts committed through the Website. The legitimate interest pursued by the company is the legal basis for this. The data retention period is in line with this purpose and, in all cases, shall not exceed 48 months from the date of collection. Once this period has expired, personal data will be erased or anonymised. For this purpose, the provision of personal data is necessary. 

Furthermore, in accordance with Article 130(4) of Italian Legislative Decree No. 196/2003 (as amended), the company may send the user promotional communications about products or services similar to those they have already viewed (i.e., “soft spam”), unless they opt out. 

6. PERSONS OR CATEGORIES OF PERSONS TO WHOM PERSONAL DATA MAY BE DISCLOSED OR WHO MAY BECOME AWARE OF SUCH DATA IN THEIR CAPACITY AS DATA PROCESSORS OR PERSONS AUTHORISED TO PROCESS DATA 

Personal data may be disclosed for the purposes set out in Section 5 of the GDPR: 

  • within the limits strictly relevant to the obligations, tasks and purposes set out above, and in compliance with the relevant legislation in force, with internal staff acting as data processors or data controllers. 
  • to persons who typically perform the role of data processors, such as: 
    • individuals, companies or professional firms that provide F.lli Saclà S.p.A. with support and consultancy services; 
    • entities with which it is necessary to liaise in order to provide the services, and specifically the companies listed below: 
    • TONIK DESIGN S.r.l., Piazzale Bertozzi No. 39, 43125 Parma (PR), info@tonikdesign.it 
    • THE AD STORE ITALIA S.r.l., Viale Fratti No. 20/d, 43121 Parma (PR), info@adstore.it 
    • WIIT S.p.A., Via dei Mercanti No. 12, 20121 Milan (MI), info@wiit.cloud 
    • ZUCCHETTI S.p.A., Via Solferino No. 1, 26900 Lodi (LO), zucchettispa@gruppozucchetti.it  such as companies delegated exclusively with the task of carrying out procedures relating to data processing activities. 
    • WTL S.r.l., Via San Gregorio No. 34 – 20124 Milan (MI), VAT No.10042630961, Economic and Administrative Index No. 2500385, as the company tasked with managing the prize draw organised by F.lli Saclà S.p.A. for the period between April and September 2026, for the processing of participants’ personal data solely for this purpose and for as long as is necessary to complete it; 
    • VF E-COMMERCE CONSULTING, 756 Chemin de Saint Julien, 06410 Biot, VAT No. FR89977744150, as the platform for managing enquiries received via the «Contact Us» section of the French branch’s Website (www.sacla.fr), the use of which involves the processing of data voluntarily provided by the user when completing the form; 
    • Gorgias Inc., 34 Harriet Street, San Francisco, CA 94103, CIN: 32-0475327, as the platform for managing enquiries received via the «Contact Us» section of the UK branch’s Website (www.sacla.co.uk), the use of which involves the processing of data voluntarily provided by the user when completing the form; 
  • to entities, organisations or authorities to which the disclosure of the user’s personal data is mandatory to comply with legal provisions or orders from the authorities; 
  • to persons authorised by F.lli Saclà S.p.A. to process personal data necessary for carrying out activities strictly related to the provision of the services, who have sworn to maintain confidentiality or are bound by an appropriate legal duty of confidentiality. 

Personal data will not be disclosed under any circumstances. 

7. PROCESSING METHODS 

Data is processed using electronic and paper-based resources, including those organised into databases or filing systems. Where necessary, this will involve telephone and electronic communication, which will be limited to the methods strictly required to provide the services. 

Personal data is processed using automated and non-automated systems and is retained for as long as is strictly necessary to fulfil the purposes for which it was originally collected, or until the time specified by a relevant legal obligation or applicable legislation. In all cases, it is retained for no longer than is permitted by Italian legislation for the protection of the data subject’s interests (Article 2946 of the Italian Civil Code and subsequent articles). 

More specifically, processing is carried out by employees and independent contractors of the Data Controller, who have been 

expressly identified and authorised to process data in accordance with the provided instructions, in compliance with current privacy and data security legislation. Processing is also carried out by parties outside the Data Controller’s organisation who have been appointed as Data Processors for this purpose, in accordance with Article 28 of the GDPR. 

The collected data is recorded and retained in electronic and/or paper-based filing systems. These systems are safeguarded and monitored to ensure the security, integrity and confidentiality of the data, in accordance with relevant legislation on the protection of personal data. 

Specific security measures are in place to prevent data loss, unlawful or improper use, and unauthorised access. 

8. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES 

The Saclà Group conducts business on an international level, with the processing of personal data primarily taking place within the European Economic Area (EEA). However, some of the recipients of the data, such as the Group’s branches and service providers, may be located outside the EEA. This includes countries that do not offer an equivalent level of data protection to that guaranteed within the EEA. 

Although other countries may not have the same data protection standards as the user’s country of residence, the Saclà Group will continue to protect the personal information we transfer in compliance with this Privacy Policy. 

9. RIGHTS OF DATA SUBJECTS 

In accordance with Articles 15 and subsequent articles of the Regulation, the data subject may exercise the following rights vis-à-vis the Data Controller at any time: 

  • Right of access to their personal data (Article 15 of the GDPR). 
  • Right to obtain, without undue delay, the rectification of inaccurate personal data concerning them and/or the right to have incomplete personal data completed (Article 16 of the GDPR). 
  • Right to erasure (“right to be forgotten”) in the cases provided for by the Regulation (Article 17 of the GDPR). 
  • Right to object to the processing of data (Article 21 of the GDPR). 
  • Right to request the restriction of data processing in the cases provided for in the Regulation (Article 18 of the GDPR). 
  • Right to data portability, whereby the data subject has the right to receive the personal data concerning them in a structured, commonly used and machine-readable format in the cases specified (Article 20 of the GDPR). 
  • Right to withdraw consent at any time (Article 7(3) of the GDPR). 

In any event, the data subject also has the right to lodge a complaint with the competent supervisory authority (in Italy, the Italian Data Protection Authority), pursuant to Article 77 of the Regulation, if they consider that their personal data have been processed in breach of the applicable legislation. 

All enquiries must be submitted in writing to F.lli Saclà S.p.A. or via the online form available in the “Customer Service” section of the Website. 

10. CHANGES TO THIS PRIVACY POLICY 

This policy may be changed over time. The Data Controller encourages users to check this page from time to time for any updates. 

11. SPECIAL SECTION – RESIDENTS OF THE UNITED STATES OF AMERICA 

If you are a resident of Connecticut, Colorado, Utah or Virginia, or any other US state that has consumer privacy laws, the data protection laws in force in your state will apply to you. 

  • Connecticut’s privacy law, the Connecticut Data Privacy Act (“CTDPA”) 
  • Colorado’s privacy law, the Colorado Privacy Act (“CPA”) 
  • Utah’s privacy law, the Utah Consumer Privacy Act (“UCPA”) 
  • Virginia’s privacy law, the Virginia Consumer Data Protection Act (“VCDPA”) 

In addition to the rights of access, data portability, rectification and erasure already set out in Section 9 of this Policy, users have the right to object to the sale of their personal data and to the processing of their data for targeted advertising purposes. Under the laws referred to above, “sale” means the transfer of personal data by the Data Controller to a third party in return for monetary consideration. “Targeted advertising” refers to the display of advertisements selected on the basis of personal data obtained or inferred from a consumer’s activities over time and on unaffiliated websites or online applications, which are used to predict their preferences or interests. 

12. SPECIAL SECTION – CALIFORNIA RESIDENTS 

This section provides additional information to the general privacy policy and is provided pursuant to applicable federal and state laws of the United States of America, including the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA/CPRA”), and applies exclusively to residents of the United States, with specific provisions for residents of the State of California. 

Information collected, sources and purposes 

For a description of the categories of personal information that we may collect – and that we may have collected over the past 12 months – the sources from which it is obtained, the purposes for which it is processed, and the categories of third parties with whom it is shared, see Sections 2 and 5 of this Privacy Policy. We do not collect or process sensitive personal information for the purpose of identifying consumers’ personal characteristics. Where we process data in an anonymised form, we will retain and use it exclusively in that form. We will not re-identify it, unless permitted by applicable law. 

Retention. Personal data is retained for the period specified in Section 5 of this Privacy Policy. This period takes into account applicable statutes of limitations and statutory retention obligations. 

User rights. If you are a resident of California, you may exercise the following rights: 

  1. Access: You have the right to request, up to twice in any 12-month period, that you be provided with: the categories and specific personal data collected about you; the categories of sources from which the data was obtained; the commercial purposes for which the data was collected; the categories of third parties with whom the data has been shared; and the specific personal information relating to you. 
  2. Rectification: You have the right to request that we correct any personal information we retain about you if it is inaccurate. 
  3. Erasure: You have the right to request the erasure of certain personal information that we have collected about you. 
  4. Objection to the sale or sharing of personal data: You have the right to object to your personal data being sold or shared for advertising purposes. 
  5. Non-discrimination: You have the right not to be discriminated against by us for exercising your privacy rights under the CCPA. 

To exercise your rights, either on your own behalf or on behalf of another person, simply fill in the form in the “Customer Service” section of the Website or email us at export@sacla.it