Privacy Policy

PRIVACY POLICY 

(Information on the processing of personal data under Article 13 of Regulation (EU) 679/2016) 

April 2019

Foreword

Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter, the “Regulation”), LUIGI LAVAZZA S.P.A. invites you to carefully read this Privacy Policy, which contains important information regarding the protection of your Personal Data.  

Your Personal Data shall be processed in accordance with the principles of fairness, lawfulness, transparency, limitation of purpose and retention, data minimization, accuracy, integrity, and privacy, in compliance with the provisions of the Regulation. 

We wish to inform you that the perimeters of the buildings used by LAVAZZA may be monitored through video surveillance, for security reasons and for the protection of the company's property and assets against possible attacks, theft, robbery, or acts of vandalism, and for the purpose of protecting the Company’s rights in a court of law. In these cases, a privacy notice is provided through signs placed on site.

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Pursuant to the Regulation, LAVAZZA informs you that the Personal Data you may provide shall be processed in compliance with the above statutory regulation and in line with the criteria detailed below.  

1) DATA CONTROLLER

The Data Controller for your Personal Data is LUIGI LAVAZZA S.p.A. (hereinafter “Lavazza” and/or the “Data Controller”), with registered office at Via Bologna, 32, Turin, Italy, in the person of its pro tempore legal representative. 

2) PERSONAL DATA PROCESSED

LAVAZZA shall process the following categories of Personal Data: 

·        Personal Details  

·        Contact Details (e-mail, address, phone number)  

  • Geolocation and/or internet navigation data collected through the cookies installed on your computer or mobile device (for more information, please see our Cookie Policy)  

·        Bank details useful for the management of the business relationship

·        Photographic images and/or video footage

In addition to the above categories of Personal Data, additional data you share on Lavazza’s social network pages (Facebook, Twitter, Instagram, etc.) may also be processed; for more information on the processing of such additional data, we invite you to refer to the third-parties providing the above services.  The data collected through Social Networks include, for instance, likes, comments, and in general any content and information you may post. 

The data provided shall be processed for the purposes detailed in this Privacy Policy and shall be stored so as to ensure full respect for privacy. 

3) PURPOSES AND LEGAL BASIS FOR PROCESSING

Your Personal Data shall be processed in compliance with the laws and regulations in force on the processing of Personal Data.  Your Data shall be collected and processed for the following purposes:

-        Entering data in our data banks: the Personal Data you provide shall be entered in our data banks and shall be used to make statistical analyses, in aggregate form, on the composition of said data bank. The provision of said data is optional. The legal basis for processing is the Consent of the Data Subject, which may be revoked at any moment.

-        Registering with our Website: the process for registering to our Website, by creating an account or using an already existing social network account, is aimed at allowing you to use the Website as a “Registered User”, and access a series of exclusive services offered through the Website.  The provision of said data is optional. The legal basis for processing is the Consent of the Data Subject, which may be revoked at any moment.

-        Purchasing products: by using our Website, you may purchase Lavazza products as either a Registered User (in which case you don't have to re-enter all your Personal Data every time you make a purchase), or as a Non-Registered User (by re-entering, every time, your Personal Data necessary to complete a purchase). Both cases shall entail processing of your Personal Data.

Your Personal Data shall be processed for the purpose of managing orders and carrying out the following administrative-accounting tasks, and to contact you to provide you information concerning your purchases (such as the status of your orders, etc.). The provision of said data is optional, but it is necessary to complete your purchase order.   The legal basis for this processing is the Performance of the Contract. 

3.1) Additional Purposes: 

-        Participation in promotional events and activities: with your prior consent, we may process your Personal Data for the purpose of allowing you to participate in prize contests and sweepstakes, take advantage of discounts or promotions reserved to Clients, subscribe to our newsletter, receive commercial communications and promotional activities.  The legal basis for these processing operations is the Consent of the Data Subject, which may be revoked at any moment.

-        Profiling activities: with your prior consent, we may process your Personal Data for the purpose of profiling or to carry out market surveys and process your data for statistical purposes, or analyse or predict your preferences, potential habits and consumer choices in order to offer you personalised products, services, promotions and commercial communications. The legal basis for this processing is the Consent of the Data Subject, which may be revoked at any moment.

Profiling activities may be carried out also through our own or third-party cookies.   We invite you to read our Cookie Policy. This processing may be carried out on condition that you provide  your additional specific consent, which is optional.

-        Any additional purpose for which you have expressly provided your consent, which can be revoked at any moment. 

4) NATURE OF THE CONFERRAL

The conferral of your Personal Data is optional. However, if you do not provide your Personal Data, you may be unable to access certain services (such as making orders and purchases, participate in prize contests and sweepstakes, receiving our newsletter, etc.).

The mandatory or optional nature of conferral shall be indicated each time through symbols (such as “*”) next to the information for which your consent is mandatory in order to pursue the respective purpose.   

5) METHODS OF PROCESSING

Your personal data shall be processed in compliance with the provisions of the applicable laws and regulations on the processing of Personal Data, through both electronic and automated means or manually. Your Data shall be processed in manners suitable to guarantee their utmost security and confidentiality and only by individuals who have been instructed and authorised for processing.  The Data Controller adopts technical and organisational measures suitable to ensure a level of security that is appropriate to processing risks.  

6) DATA RECIPIENTS

Your Personal Data may be made accessible for the purposes detailed above, to employees and associates of LAVAZZA, in Italy or abroad.

The Personal Data you provided may be communicated to the companies within the Lavazza Group and/or to third-party companies that carry out activities in Italy or abroad on behalf of the Data Controller, in the capacity as Data Processors.

The Data Controller has drawn-up a list of the Data Processors, which is constantly updated, and can be available to you by contacting the Data Controller to the addresses listed at point 10 of this Privacy Policy. 

Your Personal Data may be transmitted to the judicial authority where necessary and in the cases in which it is required by law. 

7) DATA RETENTION PERIOD

The Personal Data you provide shall be entered in our data bank and shall be retained for the following periods:

-        The Personal Data we acquired and you provided as prospect (a person with whom there is no agreement in place with respect to the provision of goods or services) shall be kept in our data base for 24 months and subsequently erased unless there additional contacts.

-        Registration with our Website: The Personal Data you provided to register with our Website shall be retained for the entire time you are registered with the Website. If you are inactive for 24 months, your Account is erased.

-        Invoicing data shall be retained for a period of time sufficient to ensure the proper performance of the agreement and in any case for 10 more years for purposes connected to administrative and fiscal obligations.

-        The data collected for your participation in prize contests and sweepstakes shall be retained for the entire duration of the contest or sweepstake and for a period of time sufficient to ensure the proper performance thereof. The above shall be without prejudice to the time needed to discharge the administrative and fiscal obligations for which the period of retention of data is provided for by law.

-        The data collected for profiling purposes and for the purpose of sending promotional and advertising material shall be respectively retained for a period of time not exceeding 12 and 24 months or a different period of time as indicated by the supervisory authorities.  

8) CHILDREN’S PERSONAL DATA

Lavazza does not normally intend to collect children’s Personal Data or deliberately communicate with them. For this reason we invite parents to carefully monitor the online activities of their children aged up to sixteen.

However, in case we should be in contact with a minor, we shall adopt every possible measure to offer their parents or guardians the possibility to issue their consent before we use the Personal Data of minors, except in case we are providing an answer to a question that was posed to us or respond to a request.  

9) RIGHTS OF DATA SUBJECTS

You may at any time exercise, with respect to the Data Controller, the rights provided under Articles 15 et. seq. of the Regulation, including: 

a)      the right to obtain confirmation on the existence of personal data that concern you, including when not yet recorded, and obtain the communication thereof in intelligible form; 

b)     the right to revoke, at any time, your consent with respect to the purpose of processing; 

c)      the right to obtain access to, and the rectification, erasure, limitation of processing and portability of personal data; 

d)     the right to object to the processing, at any time you wish; 

e)     the right to lodge a complaint with the competent Supervisory Authority whenever you believe that the processing of your Personal Data is contrary to the laws and regulations in place.  

10) METHODS FOR EXERCISING YOUR RIGHTS - DATA PROCESSOR CONTACT DETAILS

If you wish to exercise the above rights, or wish to receive further information on the processing of your Personal Data, you may write to the Data Controller to the following e-mail address: PrivacyDPO@lavazza.com or to the address of its registered offices, and namely Via Bologna 32, 10152, Turin (TO), Italy.