Information notice pursuant to Articles 13 and 14 of EU Regulation 2016/679 on the protection of personal data

The following sets out how this website is managed with regard to the processing of the personal data of users who visit it.

General Beverage  S.r.l. – Sede legale:  Galleria del Corso, 1 – 20122 Milano tel.  +39 0187 832305  –  fax.  +39 0187 461368  – Partita I.V.A. 00645690454 – e-mail: info@iobevo.com  è consapevole dell’importanza della tutela della riservatezza dei dati personali e si impegna nel rispettare le direttive e le norme vigenti in materia di privacy che garantiscono navigazione in internet sicura e riservata

Users of the website www.ristosanohome.com (the “website”) who are concerned about the processing of their personal data are invited to read this document carefully. It sets out, in general, the rules that General Beverage S.r.l. follows when collecting and processing personal data and, in particular, the methods and purposes of processing the personal data provided by the user whilst browsing the website, using the registration and contact forms available thereon, and when purchasing goods or services made available and offered via the website.

This privacy notice is also provided pursuant to Articles 13 and 14 of EU Regulation 2016/679 on the protection of personal data to those who interact with the website of RISTOSANO HOME, the data controller, and is available online at www.ristosanohome.com

The Data Controller

Il “titolare” del trattamento è General Beverage  S.r.l. – Sede legale:  Galleria del Corso, 1 – 20122 Milano tel.  +39 0187 832305  –  fax.  +39 0187 461368  – Partita I.V.A. 00645690454 – e-mail: info@iobevo.com

General principles governing the processing of personal data

The processing of personal data is guided by the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimisation, accuracy, integrity and confidentiality. In particular:

• to process data solely for the purposes and in the manner set out in the privacy notice;
• to process data for purposes for which the data subject’s prior consent is required only where there is express authorisation to do so;
• respect for anonymity, allowing users to browse the website anonymously in areas that do not require authentication, subject to the automatic collection of browsing data;
• to make data available to third parties solely for purposes necessary for the provision of the requested service or, in other cases, unless permitted by law, only where the data subject has given their consent;
• to respect the rights of data subjects by responding to requests for the erasure, rectification or supplementation of the data provided, and to requests to object to the processing of data for the purpose of sending commercial and advertising information;
• to ensure the proper and lawful processing of personal data, safeguarding the data subject’s right to privacy, and to implement appropriate security measures to protect the confidentiality, integrity and availability of the data processed;
• to ensure maximum transparency, accompanying every data collection activity with appropriate information notices;

Types of data processed

‘Personal data’ means ‘any information relating to an identified or identifiable natural person (i.e. the data subject); a natural person is considered identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity;” (Article 4 of EU Regulation 2016/679).

Therefore, personal data includes the user’s name, contact details and contact information, as well as any other information relating to the website user that can be derived, directly or indirectly, from these details

REGISTRATION DETAILS

When registering on the website and creating an account, as well as subsequently when completing the relevant registration forms and fields, users will be asked to provide certain personal data, such as their first name and surname, email address, postal address and billing details.

The information requested during registration will be used to grant access to online services and to ensure the proper conduct of all activities connected with or necessary for the provision of those services.

Furthermore, as registration is a prerequisite for accessing and using our services, the personal data of website users – once they have selected a service and following the provision of further information – will be processed for purposes related to and/or necessary for the selected service.

Where the selected services are managed by third parties, the data will be disclosed to the individual service providers, provided the user has been informed in advance. These service providers act as “data controllers” for the processing of data relating to the provision of the services for which they are responsible (banks, payment institutions, couriers)

PURCHASING DATA

The data required to facilitate online purchases of the specified products, in accordance with the procedures set out in the contractual terms and conditions of sale; (Legal basis for processing: Performance of the contract)

DATA PROVIDED VOLUNTARILY BY THE USER

The voluntary and explicit sending of e-mails to the addresses indicated on the various access channels of the website www.ristosanohome.com and the completion of the forms specifically provided for this purpose entail the subsequent collection of the sender’s/user’s email address and personal data, which are necessary to respond to the enquiries made and/or to provide the requested service.

The provision of this data is optional, explicit and voluntary, and involves the subsequent collection of the sender’s email address – which is necessary to respond to enquiries – as well as any other personal data provided.

IO SANO will process this data on the assumption that it relates to the user or to third parties who have expressly authorised the user to provide it, on the basis of an appropriate legal basis that legitimises its processing. In such cases, the user is the independent data controller and assumes all legal obligations and responsibilities, providing the fullest indemnity against any dispute, claim, request for compensation for damage arising from processing, etc., which may be received by IO SANO from third parties whose personal data has been processed through the use of the website in breach of current legislation.

IO SANO advises users not to submit personal data unless strictly necessary: certain categories of personal data may only be processed with the user’s explicit consent and in accordance with current legislation.

The Data Controller therefore emphasises the importance of giving your explicit consent to the processing of special categories of personal data, should you decide to share such information.

BROWSING DATA

The IT systems and software procedures used to operate the website www.ristosanohome.com collect, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected with the intention of being linked to specific users, but by its very nature it could, through processing and cross-referencing with data held by third parties, make it possible to identify users.

This category of data includes the IP addresses or domain names of the computers used by users connecting to the website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response provided by the server (successful, error, etc.), the browser and operating system used, and other parameters relating to the user’s operating system and IT environment.

This data is used solely for the purpose of obtaining statistical information – not linked to any user identification data – regarding the use of the website and to monitor its correct functioning; it is deleted immediately after processing or, at the latest, within one week. The data may be used to establish liability in the event of hypothetical cybercrimes committed against the website.

This data is stored on the data controller’s systems or on those of the data processors responsible for managing the website.

SYSTEM LOG

Access to the Website, viewing its content and using the services offered enable the web server to automatically record so-called ‘system logs’, i.e. the information that the user’s browser sends whilst browsing the site. This information consists of the web pages requested by the user, the documents viewed, edited or created, the IP address, the browser type, the browser language, and the date and time of the request.

STATISTICAL DATA

Statistical analysis services enable the Data Controller to monitor and analyse traffic data, with a view to measuring the website’s performance for research purposes, usability assessments and to gauge interest. The data is in aggregated or anonymous form; it is therefore not possible to identify the user.

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). On this website, Google Analytics is configured to collect data anonymously. The data collected relates to cookies and website usage data.

COMMERCIAL AND PROMOTIONAL COMMUNICATIONS AND NEWSLETTERS

The processing of personal data for commercial and promotional communication services is carried out for the purpose of promoting and advertising our products and services, by sending, via email (or also via SMS, mobile messaging apps and services, social media, fax where specified), of commercial communications and informational and advertising material.

This type of service enables the Data Controller to manage a database of email addresses, telephone numbers or any other type of contact details, which are used to communicate with the user.

These services may also enable the collection of data relating to the date and time at which the user views the messages, as well as the user’s interaction with them, such as information on clicks on links included in the messages.

At any time, the user may stop receiving marketing communications by using the unsubscribe options provided within the communications themselves, or update their preferences regarding the receipt of such communications, either by restricting them or opting out entirely.

Data processing for requests for a personalised “Dysphacare” plan

The Data Controller processes the personal data provided via the page dedicated to the “Dysphacare” programme, which is accessible by invitation only, in order to enable the processing of requests for nutritional advice and the development of a personalised dietary plan for the person receiving care. In this context, the following data are collected and processed:

– the carer’s personal and contact details (first name, surname, contact details, relationship to the person being cared for);

– information relating to the health of the person receiving care, with particular reference to dysphagia, nutritional status, any related medical conditions and eating habits.

Health data falls within the special categories referred to in Article 9 of Regulation (EU) 2016/679. The provision of such data is optional but necessary in order to provide the nutritional advice service and draw up a personalised dietary plan; without it, it will not be possible to proceed with the request. The processing is based on the data subject’s explicit consent and, with regard to health data, on the conditions set out in Article 9(2) of Regulation (EU) 2016/679 concerning the purposes of diagnosis, medical care or treatment, where applicable. The carer completing the form declares that they are authorised to provide the Data Controller with the personal data and health-related data of the person being cared for, for the purposes set out above.

The data are processed, including by electronic means, by staff authorised by the Data Controller and, where applicable, by specifically appointed healthcare professionals and nutritional advisers or bypartners and associated companies,in accordance with the security measures laid down by current legislation. The data will be retained for the time strictly necessary to draw up the nutritional plan and to manage the relationship established within the framework of the “Dysphacare” programme, as well as, subsequently, for any period required by regulatory obligations or to safeguard the Data Controller’s rights in legal proceedings..

Cookies

This website uses cookies to provide its users with the best possible experience on the site and to optimise their visit. Please see the specific information.

Purpose of processing data provided by users

Personal data provided voluntarily by users of the website is processed for various purposes, as set out below, for which consent may be required:

Purpose of the processing	Legal basis and consent to data processing
a. to create your user account and for purposes relating to its management, should you register on the website; b. to verify your identity, including when assisting with account recovery; c. to manage your purchases and any requests for technical, commercial or administrative support, and to provide any additional services requested by the user	The processing is carried out in connection with the performance of a contract to which the user is a party or in connection with the implementation of pre-contractual measures taken at the user’s request (Article 6(1)(b) of the Regulation). Consent is not required.
d. to respond to any enquiries addressed to us, for example, through unsolicited messages, emails or letters sent to the contact details provided on the website, which involve the subsequent collection of the sender’s address (including their email address) or telephone number, as required to respond to such enquiries, as well as any other personal data included in the relevant communications.	The processing is carried out in connection with the performance of a contract to which the user is a party or in connection with the implementation of pre-contractual measures taken at the user’s request (Article 6(1)(b) of the Regulation). Consent is not required if you are not currently a customer.
e. to fulfil obligations laid down by laws, regulations and legislation, whether national and/or EU, as well as by provisions issued by authorities lawfully empowered to do so or by supervisory and regulatory bodies;	The processing is necessary to comply with a legal obligation (Article 6(1)(a) of the Regulation). Consent is not required.
f. to prevent or detect any misuse of the website, or any fraudulent activity, and thereby enable the company to defend itself in court.
2. MARKETING AND SALES PROMOTION ACTIVITIES
a. Marketing and promotional purposes relating to the data controller’s services, etc.	Consent pursuant to Article 6(1)(a), except where the data controller has a legitimate interest in sending promotional emails to existing customers, in accordance with Article 130(4) of Legislative Decree 196 of 2003, as amended.

One or more consents given may be withdrawn at any time by contacting General Beverage srl in the manner set out for the exercise of rights at the end of this privacy policy.

Purpose of processing browsing data and system logs

Personal data whose transmission is inherent in the use of Internet communication protocols, and system logs, are processed solely to obtain anonymous statistical information on the use of the website, to check that it is functioning correctly, and to protect the IT systems that enable it to operate.

The data do not allow the identification of the data subjects and are not linked to other data sources that could enable cross-referencing capable of identifying users.

Such data, such as the user’s IP address, may also be used to establish liability in the event of any cybercrimes committed against the website.

Obligation or right to provide data

Apart from the provisions set out above regarding browsing data, you are free to provide the personal data requested in the forms or during the registration process. Failure to provide such data may make it impossible to obtain what you have requested or to carry out certain services, as specified below in relation to the purposes set out above:

1. REQUEST MANAGEMENT AND SERVICE DELIVERY

The provision of data (where marked as required on the forms) is necessary for the purposes set out in point 1; any refusal to provide such data will make it impossible to process orders or fulfil users’ requests, and will prevent users from making use of the services available via the website.

Furthermore, the processing of data for these purposes is necessary in order to comply with any legal obligations: personal data must be processed in accordance with the applicable legislation, including its retention and disclosure to the authorities for accounting, tax or other obligations.

2. MARKETING AND SALES PROMOTION ACTIVITIES

The provision of data, which is based on the user’s consent, is optional for the purposes set out in point 2; failure to provide such data, or the withdrawal of consent, will prevent us from sending commercial and promotional communications. Failure to provide such data will not affect the provision of services in any way.

Methods of processing

Personal data is processed using automated tools, methods and procedures for the time strictly necessary to achieve the purposes for which it was collected and to fulfil the purposes set out in this privacy notice.

In particular, the processing is carried out by specially appointed staff, primarily using electronic, IT or other automated means, via email or other remote communication techniques.

Data retention

Data is retained for as long as is strictly necessary to provide the requested service or for the period specified by current legislation.

In general, personal data provided by users which is no longer necessary for the purposes for which it was collected is immediately deleted or anonymised, subject to the retention obligations set out herein, as required by law or unless the data subject indicates otherwise.

In order to protect its own interests, the company will also process personal data for as long as permitted by law, in accordance with Article 2947 of the Italian Civil Code, in particular to the extent necessary to safeguard the Data Controller’s interests against any potential complaints relating to the services provided.

For the purposes of marketing and commercial promotion, the data will be retained for no longer than 2 years from the date of collection and, in any event, until consent is withdrawn, after which the company will no longer use the user’s personal data for such purposes, whilst reserving the right to retain it for as long as may be necessary to protect its interests against any potential claims arising from such processing.

Data security

The Data Controller implements specific, appropriate and preventative security measures to safeguard the confidentiality, integrity, completeness and availability of the data subject’s personal data, as well as to prevent data loss, unlawful or improper use, and unauthorised access.

In particular, to protect the personal data of the data subject, the Site uses an encryption system with SSL (Secure Sockets Layer) technology – find out more), which ensures protection by encrypting information both on the login page and in other sections where you can submit, view or amend your personal data.

Recipients of personal data

Personal data may be disclosed to parties who are authorised to access the data pursuant to statutory provisions, regulations or EU legislation, within the limits set out in those provisions.

For the provision and management of the services requested by the user, the user’s personal data may be disclosed to other parties, acting as data processors and/or independent data controllers (such as credit card issuers, couriers or Poste Italiane S.p.A., providers of web services, email services or technical services that provide services essential to the operation of the website; entities providing assistance and consultancy in accounting, administrative, legal, tax, financial and debt recovery matters relating to the provision of the services; in-house staff authorised to process data and bound by confidentiality obligations) to the extent necessary to carry out their duties within our organisation, and who act as data processors or who have undertaken to maintain confidentiality, including through an appropriate legal obligation.

The data may also be disclosed to individuals, organisations or authorities where required by law, to protect against abuse or fraud, or in response to orders from the authorities.

L’elenco completo dei predetti soggetti può essere richiesto direttamente a info@ristosanohome.com

The personal data collected is not disclosed.

Place where data is processed

Data processing in connection with the web services on this website takes place at the Data Controller’s aforementioned premises, which uses external providers for website hosting, and is carried out solely by technical staff authorised to process the data and, occasionally, by persons appointed to carry out maintenance operations.

Where necessary, the data may be processed by staff of the company responsible for maintaining the technical aspects of the website, who have been appointed as data processors at the company’s registered office.

Personal data will be stored on servers or in databases belonging to the Data Controller or its service providers, located within the European Union. Unless otherwise specified, the data will not be transferred outside the European Union.

Transfer to third countries

Some of your personal data may be transferred to recipients located outside the European Union, as indicated in the various purposes of the processing. The company ensures that the electronic and paper-based processing of personal data by these recipients takes place in accordance with the requirements of current legislation, namely by basing the transfer on an adequacy decision or, alternatively, on the standard contractual clauses approved by the European Commission.

Rights of data subjects

Agli utenti del sito cui si riferiscono i dati personali, in qualità di interessati al trattamento e nei limiti della normativa vigente, sono riconosciuti i diritti di cui gli articoli dal 15 al 22 del Regolamento EU 2016/679, ovvero, in sintesi, il diritto di chiedere a General Beverage  S.r.l. – Sede legale:  Galleria del Corso, 1 – 20122 Milano tel.  +39 0187 832305  –  fax.  +39 0187 461368  – Partita I.V.A. 00645690454 – e-mail: info@iobevo.com , in qualunque momento:

• access to personal data, as well as further information on the processing of such data
• the rectification or updating of data
• the erasure of data

The user can also:

• to object to the processing,
• request the restriction of processing
• to obtain, in a structured, commonly used and machine-readable format, data relating to the user
• to withdraw consent for the purposes of processing that require it

In accordance with and within the limits of current legislation, you have the right to lodge a complaint with the relevant supervisory authority (the Italian Data Protection Authority) if you believe that the processing of your personal data breaches the law.

I diritti sopra elencati possono essere esercitati dall’interessato, in qualsiasi momento, rivolgendosi a General Beverage  S.r.l. – Sede legale:  Galleria del Corso, 1 – 20122 Milano tel.  – Partita I.V.A. 00645690454 – e-mail: info@iobevo.com

Operational headquarters – Industrial Estate, Novoleto, Pontremoli;

e-mail: info@ristosanohome.com

tel +39 0187 832305 

Si informa inoltre che l’utente registrato al sito potrà in ogni momento visualizzare e modificare i propri dati personali, accedendo alla maschera di modifica dei dati all’interno del proprio account personale; potrà concedere o revocare il consenso in precedenza eventualmente fornito per l’invio di comunicazioni commerciali scrivendo una mail a info@ristosanohome.com; potrà richiedere l’eliminazione del proprio account scrivendo una mail a info@ristosanohome.com.

Changes and updates

La presente privacy policy è in vigore dal 1/1/2023 e General Beverage  S.r.l. – Sede legale:  Galleria del Corso, 1 – 20122 Milano tel.  +39 0187 832305  –  fax.  +39 0187 461368  – Partita I.V.A. 00645690454 – e-mail: info@iobevo.com  si riserva di modificarne o aggiornarne il contenuto anche in relazione a variazioni della normativa applicabile. Tutte le modifiche ed aggiornamenti saranno vincolanti non appena pubblicati sul sito.