Even before visiting the various sections of the “Barilla for Professionals” website, this policy enables you to understand how Barilla will process your personal data, whether provided directly by you using the Form (e.g. name, surname, postal and e-mail addresses, land line and mobile telephone numbers) or collected by Barilla in other ways, all as described in the section entitled “Personal Data processed and how we collect it” (hereinafter, together, the “Personal Data”). You must read this policy before providing your Personal Data.
Identity and contact details of the Controller
The Controller is Barilla G. e R. Fratelli Società per Azioni (hereinafter “Barilla” or “Controller”), [email protected], with registered office at Via Mantova 166, 43122, Parma and the following contact details.
Barilla will process your Personal Data in compliance with Regulation (EU) 2016/679 and the domestic legislation on the protection of personal data (hereinafter, the “Privacy Regulations”).
Personal Data processed and how we collect it
Completion of the Form or registration with the Website also results in the collection and processing of your Personal Data (such as name, surname, postal and e-mail addresses, profession/position, telephone number etc.).
In particular, your Personal Data may be collected via:
- your completion of on-line forms;
- your publication of Contributions (as defined below), the contents of which may include Personal Data provided directly by you, on social networks managed independently by third parties, such as, but without limitation, Facebook, Twitter etc. (hereinafter “Social Networks”). The term “Contributions” means images, comments, catch phrases associated with the Website/App, content and other information devised by you and published on Social Network pages dedicated to the branded products of the Barilla group, including any personal image that you provide. Contributions may also be published under the nickname that you chose when registering with the Website/App, including any image that you associated with your nickname. When choosing a nickname and any associated image, you accept sole responsibility for any detrimental effects on third parties that their use may cause.
Should you choose to register with the Website or send us a request using the Form or the “Contact us” section of the Website, you will have to provide certain Personal Data so that Barilla can satisfy your requirements within the capabilities of the Website; accordingly, the registration form contains required fields that are marked with an asterisk, or otherwise identified as mandatory. The provision of Personal Data not marked with an asterisk, or otherwise identified as mandatory, is entirely optional and there are no consequences for failing to provide it, in whole or in part, or for providing inexact information. By contrast, it will not be possible to provide you with the service requested if the Personal Data marked with an asterisk, or otherwise identified as mandatory, is not provided completely and accurately. If you forget to provide any mandatory Personal Data, a Barilla error message will appear listing the mandatory Personal Data that is missing.
Some sections of the Website contain empty fields, available so you can provide information to Barilla, that could contain Personal Data.
Given that these fields are empty, you might use them to provide voluntarily certain categories of special Personal Data that could reveal your racial or ethnic origin, political opinions, religious or philosophical convictions or union membership, as well as genetic data, biometric data that identifies you unambiguously, or data relating to your health, sex life or sexual orientation.
Barilla does not recommend sending this type of Personal Data. Indeed, these categories of special Personal Data can only be processed with your explicit consent and in compliance with the regulations in force at the time. Considering the nature of the services/products offered by Barilla and the types of processing carried out internally and/or via the Website, it is not necessary to process any categories of special Personal Data and, therefore, Barilla emphasises that it will not process them and asks you not to share such information. In the event of real need, please contact us at [email protected] so we can check your requirements and arrange for processing in compliance with the applicable regulations.
As already mentioned above, some sections of the Website allow you to input text messages, readable by Barilla, that might contain the personal data of third parties other than the author of the message.
In that case, you will become an independent controller, accepting all the obligations and responsibilities imposed by law. Accordingly, in this regard, you agree to relieve and hold free Barilla from all disputes, demands, compensation claims for losses caused by processing etc., that may be received by the latter from third parties whose personal data has been processed via your use of the Website functions, in violation of the applicable regulations protecting personal data. In all cases, should you provide or, in any other way, process the personal data of third parties when using the Website, you hereby guarantee - accepting all related responsibilities - that such processing is founded on consent obtained from the third party concerned, or on another suitable legal basis that justifies processing by the Controller of the information concerned.
Purposes of processing your Personal Data and their legal basis
The purposes of processing your Personal Data and their legal basis, described below, vary depending on the needs expressed by you each time you visit the various sections of the Website (without prejudice to individual initiatives involving the provision of certain Personal Data, about which specific information will be published on the Website on a case-by-case basis).
Your Personal Data will only be processed for the following purposes after your consent has been given, which may be revoked at any time by visiting your profile page (where you can deselect the relevant box), by deleting your profile, by following the link placed at the foot of each promotional e-mail (with regard to marketing activities and the newsletter), or by contacting the Controller at the following e-mail address: [email protected] , or in the manner indicated each time by the Controller when requesting your consent.
a) Marketing activities
You can decide to consent to the processing of your Personal Data for marketing purposes i.e. for commercial communications, including promotional newsletters sent by e-mail, text messages or push notifications, telephone, traditional post, instant messages or operator calls about sending promotional and advertising materials concerning any Barilla group brand, or for market research purposes. For this purpose, your consent is requested when you complete the Form or register with the Website. In this case, you can choose via which channels you prefer to receive the commercial communications (e.g. all or some of the following: e-mail, text messages, traditional post, push notifications) and select the Barilla group brands of interest to you.
b) Profiling activities
You can decide to consent to profiling activities i.e. analysis of your habits and/or consumer choices, including comparison of your Personal Data held on the various databases owned or used by Barilla, in order for example to receive customised promotional communications, view customised content and banners on the Website, and participate in statistical surveys. Various activities may contribute to the creation of your profile including, for example, your participation or otherwise in prize competitions, interactions with the Website, purchase of various brands of Barilla group products and publication of Contributions on the Social Network pages dedicated Barilla group products. For this purpose, your consent is requested when you complete the Form or register with the Website.
Additionally, even without your consent, Barilla may process your Personal Data for the following purposes:
i) administer the contact request you made by completing the Form and activities related to your use of the Website, your interaction with the Website and its various sections (being processing necessary to execute a contract or perform pre-contractual activities);
ii) administer your participation in prize competitions (if applicable), including evaluation, assignment and communication of the offer of gift points and bonus points, as well as the opportunity to accumulate them (by sending so-called “transactional” e-mails linked to your participation in the promotion), and assignment of the prizes (being processing necessary to execute a contract or perform pre-contractual activities);
iii) administer and comply with legal obligations (of an accounting, administrative, tax or other nature);
iv) check how the Website is used, prevent or identify any improper use of the Website, and manage any complaints or disputes (being in the legitimate interests of the Controller).
How we process your Personal Data
The processing of your Personal Data may include any type of operation, including its collection, registration, organisation, retention, consultation, analysis, amendment, selection, extraction, comparison, use, interconnection, blockage, communication, cancellation and erasure.
Your Personal Data will be processed mostly in an automated manner, but also on paper, using logic closely correlated with the purposes for which it was collected and databases, electronic platforms administered by Barilla or third parties specifically appointed as processors, and/or integrated IT systems operated by Barilla and the above processors and/or websites and/or Apps owned or used by Barilla.
The Controller considers the level of security provided to be adequate, having regard for the risks that might derive from the loss, erasure, amendment, unauthorised disclosure, accidental or illegal access, abuse or alteration of your Personal Data. In particular, Barilla:
- has adopted security measures commensurate with the risks;
- stores your Personal Data on servers located in Europe (see the later section entitled “Transfer of your Personal Data outside of the European Economic Area” for information on how your Personal Data is transferred outside of the EEA). In all cases, the servers concerned benefit from an advanced system of daily back-ups.
Where we process your Personal Data
Your Personal Data is mostly processed on the premises of the Controller and/or the appointed processors, using servers located solely and exclusively within the European Economic Area. For further information, please contact the Controller at the addresses indicated in the section entitled “Identity and contact details of the Controller”.
How long we retain your Personal Data
To ensure compliance with the principles governing the need for and proportionality of processing, the Controller has identified different retention times for your Personal Data, depending on the specific purposes pursued:
(i) in order to administer the contact request you made by completing the Form (found in the “Contact us” section of the Website), your registration with the Website, activities related to your use of the Website, your interaction with the Website and its various sections, your Personal Data will be retained for the time strictly needed by us and, in any case, not after your profile has become inactive. For security reasons, we will use log data to check the use of your account and, if you are inactive for more than 60 months, we will contact you to check whether you wish to maintain your account, indicating how you can confirm your interest in doing so. Should your account remain inactive over the following 30 days, it will be deleted;
(ii) in order to administer and respond to your requests regarding products and initiatives involving the various Barilla group brands, advertising or the Website (via the “Contact us” section), your Personal Data will be retained for the time strictly needed to respond to your request and, in all cases, for not more than 18 months;
(iii) in order to carry out marketing activities i.e. for commercial communications, including promotional newsletters sent by e-mail, text messages or push notifications, telephone, traditional post, instant messages or operator calls about sending promotional and advertising materials concerning any Barilla group brand, or for market research purposes, your Personal Data - with the exclusion of your contact details - will be retained until you revoke your consent and, in all cases, for not more than 36 months;
(iv) in order to carry out profiling activities i.e. analysis of your habits and/or consumer choices, including comparison of your Personal Data held on the various databases owned or used by Barilla, for example to receive customised promotional communications, view customised content and banners on the Website, and participate in statistical surveys, the Personal Data that contributes to the creation of your profile will be retained for a maximum of 36 months;
(v) in order to administer your participation in prize competitions (if any) and comply with the related regulatory, administrative and accounting obligations, your Personal Data will be retained for the duration of each prize competition and for the time strictly necessary to complete the related activities;
(vi) in order to administer and comply with legal obligations (of an accounting, administrative, tax or other nature), your Personal Data will be retained for the time strictly necessary to satisfy the related requirements;
(vii) in order to check how the Website is used and prevent or manage objections and disputes, your Personal Data will be retained for the time strictly necessary for that purpose and, in any case, not after the applicable time-expiry dates.
Recipients of your Personal Data
Your Personal Data may be communicated to and processed by:
(i) legal or natural persons, operating as processors on an outsourcing basis, that are appointed by Barilla or by other third-party processors (including parties entrusted to provide support, perform communication, marketing, advertising and promotional activities, sell products and/or services and place advertisements, as well as advertising concessionaires, providers of IT services, Website administrators, administrators of e-platforms, partners, banks and professional firms);
(ii) those employees and/or collaborators of the Controller (including system administrators) who, working under the direct authority of the Controller, are authorised to process your Personal Data; and
(iii) those employees and/or collaborators of the processors (including system administrators) who, working under the direct authority of the processors, are authorised to process your Personal Data.
Your Personal Data will not be communicated to third parties, unless Barilla has to provide it to consultants in order to protect its rights, or otherwsie disseminated.
Transfer of your Personal Data outside of the European Economic Area
Your Personal Data will not be transferred outside of the European Economic Area, being the European Union, Iceland, Norway and Liechtenstein. Further information is available by writing to the following address: [email protected] .
Minors below the age of 16 must not provide information or Personal Data to Barilla without consent from their parent or guardian. A minor cannot register with the Website without this consent. Barilla invites all parents and guardians of minors to inform them about the safe and responsible use of the Internet and the Web, and to activate the Website registration procedures applicable to persons under the age of 16.
Identity and contact details of the processors
A complete list of processors is available from the Controller at the addresses indicated in the section entitled “Identity and contact details of the Controller”.
Contact details of the Data Protection Officer or “DPO”
The contact details of the Data Protection Officer appointed by the Controller are as follows: [email protected].
Your rights in relation to the processing of your Personal Data
As the Data Subject, the Privacy Regulations grant you numerous rights. In particular, you are entitled to:
1- obtain confirmation from the Controller about the existence or otherwise of your Personal Data, even if not yet recorded, and its communication in an intelligible form, as well as to access such Personal Data (obtaining a copy of it) and the related information (including the purposes of processing, the categories and origins of the Personal Data, the categories of recipient to which it has been or may be communicated, the retention period (if possible) and the rights that can be exercised);
2- obtain from the Controller the rectification of your Personal Data and the completion of any incomplete Personal Data;
3- delete your profile from the Website and, in all cases, obtain from the Controller the erasure of your Personal Data without unjustified delay when, for example, it is no longer needed for the purposes for which it was processed or there is no further legal basis for its processing;
4- obtain from the Controller the anonymisation or blockage of your Personal Data processed in violation of the law, including Data whose retention is not necessary in relation to the purposes for which it was collected or subsequently processed;
5- obtain from the Controller the restricted processing of your Personal Data, including when you dispute its accuracy or object to its processing, for the time needed to complete the respective checks;
6- receive your Personal Data in a structured, commonly-used and machine-readable format, as well as to transmit or, if technically feasible, obtain the direct transmission of your Personal Data to another controller without impediments, in cases in which processing is carried out using automated means and is based on your consent, or is necessary for the execution of a contract to which you are a party;
7- revoke consent to process your Personal Data for any of the purposes for which it was given;
8- object, at any time and for reasons linked to your specific situation, to any processing of your Personal Data that is needed to pursue a legitimate interest of the Controller or of third parties. In that case, the Controller must cease any further processing of your Personal Data, unless it can show the existence of legitimate overriding reasons that prevail over your interests, rights or freedoms, or unless processing is necessary in order to determine, exercise or defend a right in court.
You may exercise your rights in relation to Barilla by visiting the “Contact us” section of the Website, by writing to the following e-mail address [email protected] , or by posting a letter to Barilla at the address indicated in the section entitled “Identity and contact details of the Controller”.
In addition, in cases in which you believe that the processing of your Personal Data infringes the Privacy Regulations, you may file a complaint with the Data Protection Authority of your country of residence, place of work or place in which the alleged infringement occurred, or request that Authority for information about exercising your rights under the Privacy Regulations; or apply for a judicial remedy.