Privacy

Privacy Policy – Information pursuant to Articles 13 of Legislative Decree 196/2003 ("Privacy Code") and 13 of EU Regulation 2016/679 ("GDPR")**

 

The company Frigo 1876 di Frigo Domenico, with registered office at Via Giacomuni, 34 – 36073 Cornedo Vicentino (VI), VAT No. 0124263040 (hereinafter, “Frigo 1876"), in its capacity as Data Controller, informs you pursuant to Article 13 of Legislative Decree 30.6.2003 No. 196 (hereinafter, "Privacy Code") and Article 13 of EU Regulation No. 2016/679 (hereinafter, "GDPR") that your personal data will be processed in the manner and for the purposes set out below:

 

1. Subject of Processing

Frigo 1876 processes personal, identifying data (e.g., name, surname, company name, address, telephone, e-mail, banking and payment details – hereinafter, "personal data" or "data") provided by you when entering into contracts for the services of Frigo 1876.

 

2. Purpose of Processing

Your personal data are processed without your express consent (Art. 24, letters a), b), c) of the Privacy Code and Art. 6, letters b), e) GDPR), for the following Service Purposes:

- to conclude contracts for the services of Frigo 1876;

- to fulfill pre-contractual, contractual, and tax obligations arising from relations with you;

- to comply with legal obligations, regulations, EU legislation, or orders of Authorities (e.g., anti-money laundering provisions);

- to exercise the rights of Frigo 1876, such as the right of defense in legal proceedings.

 

3. Methods of Processing

The processing of your personal data is carried out through the operations indicated in Art. 4 of the Privacy Code and Art. 4 no. 2 of the GDPR, namely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure, and destruction of data.

Your personal data are subject to both paper-based and electronic and/or automated processing. Frigo 1876 will process your personal data for the time necessary to fulfill the purposes mentioned above and, in any case, no longer than 10 years after the termination of the relationship for Service Purposes.

 

4. Access to Data

Your data may be made accessible, for the purposes referred to in Art. 2:

- to employees and collaborators of Frigo 1876, in their capacity as persons in charge and/or internal data processors and/or system administrators;

- to third-party companies or other entities (e.g., credit institutions, professional firms, consultants, insurance companies providing insurance services, etc.) that perform outsourcing activities on behalf of Frigo 1876, in their capacity as external data processors.

 

5. Disclosure of Data

Without the need for express consent (pursuant to Art. 24 letters a), b), d) of the Privacy Code and Art. 6 letters b), c) GDPR), Frigo 1876 may disclose your data for the purposes referred to in Art. 2 to Supervisory Bodies (such as IVASS), Judicial Authorities, insurance companies for the provision of insurance services, as well as to those entities to whom disclosure is mandatory by law for the said purposes.

These entities will process the data in their capacity as independent Data Controllers. Your data will not be disseminated.

 

6. Security

Data are kept and controlled by adopting suitable preventive security measures, aimed at minimizing the risks of loss and destruction, unauthorized access, unlawful processing, or processing not consistent with the purposes for which the data were collected.

 

7. Data Transfer

The management and storage of personal data will take place within the territory of the European Union.

 

8. Rights of the Data Subject

As the data subject, you have the rights set out in Art. 15 GDPR, and specifically the rights to:

i. obtain confirmation as to whether or not personal data concerning you exist, even if not yet recorded, and their communication in intelligible form;

ii. obtain indication of:

a) the origin of personal data;

b) the purposes and methods of processing;

c) the logic applied in the event of processing carried out with the aid of electronic instruments;

d) the identification details of the Data Controller, Data Processors, and the designated representative pursuant to Art. 5(2) of the Privacy Code and Art. 3(1) GDPR;

e) the entities or categories of entities to whom the personal data may be communicated or who may become aware of them in their capacity as designated representatives in the State’s territory, processors, or appointees;

iii. obtain:

a) the updating, rectification, or integration of data;

b) the erasure, anonymization, or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which they were collected or subsequently processed;

c) certification that the operations referred to in letters a) and b) have been notified, also as regards their content, to those to whom the data have been communicated or disclosed, except where this proves impossible or involves a manifestly disproportionate effort compared with the right protected;

iv. object, in whole or in part, on legitimate grounds, to the processing of personal data concerning you, even if pertinent to the purpose of the collection.

Where applicable, you also have the rights under Articles 16–21 GDPR (right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Supervisory Authority.

 

9. How to Exercise Your Rights

You may at any time exercise your rights by sending a communication:

1. by e-mail to: info@frigowine.it

2. or by registered mail to: Frigo 1876, Via Giacomuni, 34 – 36076 Cornedo Vicentino (VI)

 

 

10. Data Controller, Processors, and Appointees

The Data Controller is Frigo 1876.

The updated list of Data Processors and persons in charge of processing is kept at the registered office of the Data Controller.