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SOCIAL MEDIA PRIVACY POLICY

March 2026

Dear User,

our social media pages are a space for meeting and dialogue through which we wish to connect with you, share our passion for coffee and explore topics related to our world. We believe in the importance of an open, inclusive and respectful community: that's why we invite you to actively participate by sharing questions, advice, opinions and experiences, and to engage in dialogue with us and other users.
We are constantly working to offer valuable content and to ensure a safe, positive and stimulating environment for all coffee lovers.

This Social Media Policy describes the purposes and methods of use of our social media channels, distinguishing between:

  • Consumer channels: Facebook, Instagram, TikTok and any other similar platforms
  • Professional channel: LinkedIn

1. DATA CONTROLLER AND DATA PROTECTION OFFICER (DPO)

The Data Controller is the company belonging to the Lavazza Group responsible for managing the relevant social media page. For any communication regarding the processing of personal data, please contact the Group Data Protection Officer (DPO) at the following email address: PrivacyDPO@lavazza.com

2. FACEBOOK, INSTAGRAM, TIKTOK and any other similar platforms

(Consumer and brand engagement channels)

2.1 Purposes of personal data processing

Content shared on Lavazza social media pages (such as likes, reactions, comments, private messages, multimedia content and interactions in general) may involve the collection and processing of personal data.
Your personal data may be processed for the following purposes:

a) Brand awareness and institutional communication: Lavazza promotes its brand, communicates its values, initiatives and products, and shares editorial, cultural and informational content related to the world of coffee. The legal basis is the legitimate interest of the Data Controller.

b) Engagement and community management: Interactions between users and the brand — including responses to comments and messages — stimulate conversation, encourage participation and allow for appropriate moderation of published content, ensuring a safe and respectful online environment. The legal basis is the legitimate interest of the Data Controller.

c) Promotional campaigns and lead collection: Personal Data may also be used in promotional campaigns, competitions or other marketing initiatives. In these cases, processing allows us to manage promotional activities, collect contacts voluntarily provided by users and carry out targeting activities, displaying relevant content or advertisements based on the interests and interactions expressed through social media profiles. The legal basis is the user's consent where required by applicable law or the legitimate interest of the Data Controller, depending on the specific initiative.

d) Management of complaints and requests: if a complaint or grievance is published, Lavazza may contact you directly in private to manage the request as effectively as possible. In this context, the data is used exclusively to follow up on the report, always in full compliance with the applicable legislation on the protection of personal data. The legal basis is the implementation of pre-contractual measures taken at the request of the data subject and/or the legitimate interest of the Data Controller.

2.2 Responsibility for published content

When you decide to share content on Lavazza's social media pages, it is important to consider that what you publish may be indexed by search engines, spread rapidly and gain considerable visibility, as well as remaining accessible online for a long period of time, sometimes even after removal. Each user remains fully responsible for the content they choose to publish and the opinions they express.
To ensure a respectful environment that complies with current legislation, content that is offensive, vulgar, threatening or otherwise harmful to the dignity and rights of other users is not permitted. Similarly, material that violates personal data protection regulations, copyright, trademarks or image rights, as well as unauthorised promotional content or spam, may not be published.
Lavazza reserves the right to remove, without prior notice, any content that does not comply with these rules, to report any particularly serious behaviour to the competent authorities and to exclude users who violate this policy from the community. Moderation is not preventive: checks are carried out after users have published content.

3. LINKEDIN

(Professional and recruitment channel)

LinkedIn is used as a platform primarily for professional, commercial and employer branding purposes.

3.1 Purposes of processing on LinkedIn

On LinkedIn, personal data – in particular professionally-related data publicly available on profiles – is processed for the following purposes:

a) Networking and B2B relationship development: Lavazza uses LinkedIn to facilitate networking and the development of professional relationships in the B2B sector. The platform can be used to identify and contact business contacts who may be interested in the services and products offered, initiate professional communications, consolidate business relationships and share information relevant to the sector in question. The use of LinkedIn also includes communication activities aimed at the business audience. In this context, Lavazza may promote products and solutions dedicated to companies, disseminate case studies, research, events and corporate initiatives, and monitor the interest generated by the information materials published or sent. The legal basis is the legitimate interest of the Data Controller, as well as consent for features that require it.
As part of the features offered by the platform, tools such as InMail — which allows direct messages to be sent to professionals, even those who are not connected, based on information made public by the user — and Smart Links, which allows digital documents to be shared and their views to be tracked in order to assess the level of commercial interest, may be used. Access to content via Smart Links requires the user's consent to the collection of related viewing data, which can be revoked at any time via LinkedIn's privacy settings or by contacting the platform's support team.

b) Staff search, selection and recruitment: In this context, Lavazza may identify potential candidates by analysing publicly available professional profiles, contact users directly to propose job opportunities, promote job offers and employer branding initiatives, and carry out an initial assessment of the consistency between the professional profile and the open positions. The processing of data for recruitment purposes is based on the legitimate interest of the Data Controller in seeking qualified personnel.

4. PRINCIPLES OF PROCESSING

Personal data is processed in accordance with the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality. We ask you not to publish sensitive data (e.g. information about health, political or religious beliefs, sexual orientation). We do not collect or intend to process such special categories of data.

5. SHARING AND TRANSFER OF DATA

Your personal data may be disclosed to Lavazza Group companies and external suppliers who support our activities, both within and outside the European Union or the European Economic Area. If your request concerns another Lavazza Group company, your data may be transmitted to the relevant company so that it can handle the request directly. Any data transfers, both within the EU/EEA and to third countries, are carried out in compliance with applicable data protection legislation and, where necessary, on the basis of appropriate safeguards, such as the Standard Contractual Clauses approved by the European Commission. The use of social media platforms may involve the transfer of data to countries outside the EU/EEA. In such cases, transfers are also carried out in compliance with the GDPR and through the adoption of appropriate safeguards.

6. METHOD OF PROCESSING

Your Personal Data will be processed in full compliance with current legislation on the protection of personal data, using both electronic and automated tools — including Artificial Intelligence systems, including generative ones — and manual methods for activities such as content analysis, improvement of digital services, management of interactions and support for moderation activities, always in compliance with the principles of transparency, proportionality and data minimisation. No decisions are made based solely on automated processing that produce significant legal effects for the data subject pursuant to Article 22 of the GDPR.

7. STORAGE PERIOD

Personal data is retained for the time strictly necessary to pursue the purposes indicated above and in compliance with applicable legal obligations.

8. RIGHTS OF DATA SUBJECTS AND CONTACTS

The processing of personal data for the purposes indicated above is carried out in compliance with the fundamental rights and freedoms of data subjects.
Users may exercise their rights under applicable data protection legislation at any time by writing to: PrivacyDPO@lavazza.com
For any questions or requests for clarification on the processing of personal data, please use the same email address.