Privacy Policy
Last updated on 24 May 2018
Disclosure pursuant to art. 13 of EU Regulation no. 2016/679 on the protection of personal data (GDPR) and request for consent for the processing of personal data collected from the Data Subject.

Legend
“Website”: this term indicates the following website created by SALUMIFICIO S. PAOLO SRL, to which this disclosure refers.
www.salumificiosanpaolo.it
Table of contents
1. Identity and contact details of the Data Controller and DPO
2. Purpose and legal basis for the processing
3. Recipients of the personal data
4. Transfer of data to third countries
5. Period of retention of personal data
6. Data Subject Rights
7. Communicating and providing data
8. Changes to the privacy policy
9. Questions and feedback
10. Cookie Policy

1. Identity and contact details of the Data Controller
The Data Controller is SALUMIFICIO S. PAOLO SRL, with registered office at Via A. Vivaldi 2, 43029 Traversetolo (PR), Italy, VAT no. and taxpayer identification no. 00250740347, e-mail: info@salumificiosanpaolo.it
The updated list of personal data processors and external data processors is kept at the Data Controller’s registered office.
The company has not appointed a Data Protection Officer (DPO), as it is not legally required to do so.

2. Purpose and legal basis for the processing
The user’s personal data will be processed:
a) without express consent (art. 24 a, b, c of the Privacy Code and art. 6 b and e of the GDPR) for the following Service Purposes:
• to provide the services requested by the user through the relevant section of the reference website;
• to respond to user requests;
• to comply with legal obligations;
b) Only after specific and separate consent has been expressed by means of a special “Flag” (arts. 23 and 130 of the Privacy Code and art. 7 of the GDPR), for the following Marketing Purposes:
• direct marketing related to the projects promoted:
• sending the product newsletter
• sending the events newsletter
• sending the corporate communications newsletter
It should be noted that the direct marketing activity has the purpose of collecting and using data relevant and limited to what is necessary with respect to the purpose for which they are processed. Specifically: to carry out studies and research, to send advertising and informational materials, to send business information, and to carry out interactive business communications.
Customers who have already received a disclosure under previous legislation may receive business communications relating to products and services of the Data Controller similar to those they have already used, unless they disagree (pursuant to art. 130, par. 4 of the Privacy Code).

3. Recipients of the personal data
In the context of the aforementioned purposes, user data will be the exclusive property of SALUMIFICIO S. PAOLO SRL and will not be transferred or shared with third parties, partners, or customers of SALUMIFICIO S. PAOLO SRL.

4. Transfer of data to third countries
The Data Controller does not belong to a corporate group and does not intend to transfer user data to other companies based in countries outside the European Union.

5. Period of retention of personal data
Personal data will be retained for the period of time necessary to achieve the specific purposes of the processing operations for which the user has expressed his/her consent. Specifically:
1) for at least 10 years from the termination of the relationship for the service purposes indicated in section 2 a;
2) until exercising the right to revoke consent for the marketing purposes described in section 2 b.

6. Data Subject Rights
The user may, at any time, exercise the rights indicated below.
1. Access to personal data: obtaining confirmation as to whether or not data concerning him/her are being processed and, if so, obtaining access to the following information: the purposes, the categories of data, the recipients, the retention period, the right to lodge a complaint with a supervisory authority, the right to request the rectification or erasure or restriction of the processing or the right to object to the processing itself and the existence of an automated decision-making process;
2. Request for rectification or erasure (right to be forgotten) of the data or restriction of the processing operations concerning him/her; “restriction” means the marking of retained data with the aim of limiting their processing in the future;
3. Objection to processing: opposing, for reasons related to your particular situation, the processing of data for the performance of a task of public interest or for the pursuit of a legitimate interest of the Data Controller;
4. Data portability: in the case of automated processing carried out on the basis of consent, to receive the data concerning him/her in a structured, commonly used, and readable format; specifically, the data will be provided by the Data Controller.
5. Withdrawal of consent to processing for marketing purposes, market research, and profiling, exercising this right does not affect in any way the lawfulness of the processing carried out before the withdrawal;
6. Lodging a complaint pursuant to art. 77 of the GDPR with the competent supervisory authority on the basis of his/her habitual residence, place of work, or place of violation of his/her rights; for Italy, this authority is the Italian Data Protection Authority, which can be contacted by means of the contact details provided on its website www.garanteprivacy.it
The aforementioned rights may be exercised by sending a specific request to the Data Controller through the contact channels indicated in section 1 of this disclosure.
Requests relating to exercising the user’s rights will be processed without undue delay and, in any case, within 30 working days of the request; only in cases of particular complexity and a high number of requests may this period be extended by a further 60 days.

7. Communicating and providing data
The provision of data by the user is mandatory as it is necessary for providing the requested service. Therefore, any refusal by the user to provide his/her data may result in the failure to provide the service, to the extent that such data are necessary for this purpose.

8. Changes to the privacy policy of SALUMIFICIO S. PAOLO SRL
The applicable law and the practices of SALUMIFICIO S. PAOLO SRL change over time. If SALUMIFICIO S. PAOLO SRL decides to update its privacy policy, it will publish the changes on its Websites and will communicate them through its newsletters. If there is a change in the way SALUMIFICIO S. PAOLO SRL processes personal data, it will provide notice, or where required by law, consent will be requested before implementing such changes. SALUMIFICIO S. PAOLO SRL strongly recommends that you read its policy and keep yourself informed about it. The Privacy Policy was last amended in May 2018.

9. Questions and feedback
SALUMIFICIO S. PAOLO SRL welcomes questions, comments, and concerns about its privacy policy and privacy practices.
If you would like to provide feedback or have any questions or concerns or wish to exercise your rights relating to personal data, please contact the Data Controller:
SALUMIFICIO S. PAOLO SRL, with registered office at Via A. Vivaldi 2, 43029 Traversetolo (PR), Italy.
You can also send an e-mail to info@salumificiosanpaolo.it
Privacy complaints will be evaluated in order to resolve the issue in a timely and effective manner. You also have the right to lodge a complaint with the data protection authority of your country of residence. For Italy, this authority is the Italian Data Protection Authority, which can be contacted by means of the contact details provided on its website www.garanteprivacy.it