DATA CONTROLLER

DIAMALTERIA Italiana S.r.l., subject to management and coordination of Malteurop Groupe SA, with registered office in Corso Lepetit n°6 – 25047 Darfo –Boario Terme (BS), Tax code (codice fiscale) and VAT number 13238140159.

The Data Controller is part of the VIVESCIA Group – one of the leading French grain cooperative group specialized in the production and processing of cereals, which brings together both agricultural companies and companies dedicated to industrial processing, based in France, Europe and all over the world (hereinafter “the VIVESCIA Group”).

SCOPE

This Privacy Policy aims to explain how DIAMALTERIA collects, uses, stores, discloses, records the personal information (hereinafter ” Personal Data”) of the data subject (hereinafter the User”) during the use of its services or its website www.diamalteria.com (hereinafter the “Site”).

DIAMALTERIA will process the User’s Personal Data in compliance with EU Regulation no. 2016/679 (hereinafter “GDPR”) and national legislation on the protection of personal data (hereinafter jointly “Privacy Law”).

DEFINITIONS

The following terms have the following definitions under the Privacy Law:

Personal Data” means any information relating to an identified or identifiable natural person (“data subject”), directly or indirectly.

Processing“: refers to any operation, or set of operations, relating to personal data, regardless of the process used (collection, recording, organization, storage, adaptation, modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, alignment or interconnection, blocking, erasure or destruction, etc.).

TYPE OF DATA PROCESSED

Data collected automatically by the Site

The computer systems and procedures that allow the operation of the Site will process, during their normal operation, some personal data implicitly collected through the use of Internet communication protocols.

This information is not collected to be associated with data subjects individually, but by its very nature could, through processing and association with data held by third parties, allow its identification.

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

In order to improve the browsing experience of Users, the Site uses Cookies. To learn more about the cookies used, please refer to the relevant Cookie Policy.

Data communicated by Users

DIAMALTERIA provides contact forms on the Site in which the Users can require information about products and services such as recipes and products accreditations. The submission of requests for information via these forms requires the User to communicate the categories of Personal Data such as:

–              Name of the Artisan or Industry’s representative

Name of the contact person

–              Surname of the contact person

–              Title of the contact person

–              Email address of the contact person

–              Partita IVA (professional VAT number)

Users interested to become “Ambassadors” of DIAMALTERIA shall also communicate Personal Data in a form dedicated particularly to this purpose in order to access into a dedicated selection process. The categories of Personal Data collected will be the following:

–              Name

–              Surname

–              E-mail address

–              Phone number

–              Social Media Profile (URL)

The provision of such Personal Data of the User takes place on a voluntary basis: if the User does not provide them, he or she can still browse the Site without benefiting from these features.

Personal Data is collected if and to the extent that it is communicated by the User.

The User’s Personal Data that are mandatory to perform the activities requested are marked with an asterisk (*).

The User is invited not to communicate to DIAMALTERIA personal data of third parties, unless it is necessary (e.g., because the User does not have his own e-mail address and has no other direct contact details). In this case, we shall emphasize that it is the User’s duty to fulfill the legal obligations regarding the protection of personal data and, in particular, inform third parties of the communication and obtain, where appropriate, their consent.

MINORS

Minors under the age of 16 must not provide information or Personal Data to DIAMALTERIA without the consent of the operators of parental responsibility over them. In the absence of such consent, it will not be possible to register the minor on the Site. DIAMALTERIA invites all those who exercise parental responsibility over minors to inform them about the safe and responsible use of the Internet and the web and to implement the procedures indicated during registration on the Site concerning the registration on the Site of subjects under the age of 16.

PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING

PURPOSELEGAL BASIS
Responding to Artisan’s and Industry representative’s requests on DIAMALTERIA’s services and productsLegitimate interest (Business relation management on a business-to-business basis)  
Responding to requests for information/inquiry through DIAMALTERIA’s electronic mail address.  Legitimate interest (Business relation management on a business-to-business basis)  
Performance of statistical analysis for improvement of DIAMALTERIA’s services and products (Business and R&D).Legitimate interest (On a business-to-business basis)
Commercial prospecting (sending of newsletters, commercial campaigns, advertising) on the basis of User’s preferences and consumption habits.  Legitimate interest (Business relation management on a business-to-business basis). In any case, as recommended by the supervisory authorities, DIAMALTERIA aims to collect the User’s consent and provides necessary information when submitting personal data via the contact form.
Implementation of Cookies functionalities as further informed in the Cookies Policy  for proper operation and continuous improvement of the Site: – Improvement of the navigation on the Site; – Technical security related to the activation and use by the Users of the services offered in the Site – Adaptation of the Site configuration to the User device (tablet, computer, mobile, etc.).Legitimate interest for essential cookies Consent for non-essential cookies
Manage and respond to Users requests to exercise their Data Subject Rights. Legal obligation
Compliance with legal and regulatory provisions (such as maintaining appropriate business records, handling complaints made to our customer service, complying with lawful requests by public authorities and with applicable laws and regulations or as otherwise required by law).Legal obligation
Management of disputes and legal claimsLegitimate interest  

RECIPIENTS OF PERSONAL DATA

Personal Data processed by DIAMALTERIA may be communicated, depending on the context and within the limits of the purposes described above, to authorized personnel of internal departments of DIAMALTERIA and VIVESCIA GROUP (customer service, accounting, marketing, commercial, advertising, legal, administrative, financial, etc.), within the limits of their attributions and acting under DIAMALTERIA’s and VIVESCIA GROUP’s direct authority.

DIAMALTERIA may also be required to communicate User’s Personal Data to service providers (Data Processors and Sub-processors, if applicable, as defined in the GDPR), where necessary for the management of the Site and the related services and purposes listed above.

In particular, User’s Personal Data may be communicated to / and processed by:

The complete list of Data Processors is available upon request of the User to be transmitted to the DPO’s contacts indicated below in the “User’s rights” section.

DIAMALTERIA may also communicate the User’s Personal Data to persons entitled to access it by virtue of legal provisions, regulations, judicial authority, as well as to all other recipients to whom communication is mandatory by law.

RETENTION PERIOD OF PERSONAL DATA

In order to ensure compliance with the principles of necessity and proportionality of the data processing, DIAMALTERIA shall keep the User’s Personal Data for a period of time not exceeding the achievement of the purposes for which they are processed, except if otherwise provided by law.

In particular, DIAMALTERIA will retain the User’s Data for the following periods

PURPOSERETENTION PERIOD
Responding to Artisan’s and Industry representative’s requests on DIAMALTERIA’s services and products.  For the duration of the business relationship and then stored in an intermediate archive for the duration of the applicable legal prescription period (5 years) for evidence purposes.
Responding to requests for information/inquiry through DIAMALTERIA’s electronic mail address.
  Performance of statistical analysis for improvement of DIAMALTERIA’s services and products (Business and R&D).Retention for as long as necessary to the performance of the statistical analysis, then archiving for the applicable legal prescription period according to the purpose.
Commercial prospecting (sending of newsletters, commercial campaigns, advertising).Personal Data will be kept until the withdrawal of Users consent (unsubscribe via the link provided for this purpose) or, if applicable, for the duration of the business relationship, then for three (3) years after the last contact.
Implementation of Cookies functionalities as further informed in the Cookies Policy for proper operation and continuous improvement of the Site: – Improvement of the navigation on the Site; – Technical security related to the activation and use by the Users of the services offered in the Site; – Adaptation of the Site configuration to the User device (tablet, computer, mobile, etc.).The duration of conservation of the various cookies installed by DIAMALTERIA is detailed in the Cookies Policy. In particular, the choices made by Users regarding the deposit of cookies (both acceptance and refusal) are kept for a period of six (6) months. The lifespan of cookies that do not require consent, such as linguistic preference or purely technical tracers, or audience measurement tracers is limited to thirteen (13) months. However, the information collected through the tracers may be kept for a maximum of twenty-five (25) months.
Manage and respond to Users requests to exercise their Data Subject Rights.Retention for as long as necessary to process the User’s request, then archiving for the applicable legal prescription period.
Compliance with legal and regulatory provisions (such as maintaining appropriate business records, handling complaints made to our customer service, complying with lawful requests by public authorities and with applicable laws and regulations or as otherwise required by law).Retention for as long as necessary to compliance with legal and regulatory provisions, then archiving for the applicable legal prescription period.
Management of legal disputes and legal claimsRetention for as long as necessary to the management of legal disputes and legal claims, then archiving for the applicable legal prescription period.

DATA TRANSFER

As a general principle, DIAMALTERIA processes and stores Personal Data exclusively in the European Union, or in a territory considered as providing an adequate level of protection of personal data by the European Commission. In the event that the Personal Data were to be transferred to a country outside de European Union or not recognized as having an adequate level of protection by the European Commission (hereinafter “Third Country”), DIAMALTERIA undertakes to provide all the appropriate guarantees in accordance with the provisions of the Privacy Law. In particular, DIAMALTERIA may rely on the standard clauses as adopted by the European Commission on June 4th, 2021, to ensure the lawful transfer of personal data to a Third Country.

SECURITY MEASURES

The Data Controller will adopt all the necessary security measures in order to avoid and minimize the risks of accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

DETAILS ON THE USE OF SOCIAL NETWORKS

While browsing the Sites, Users may click on social media buttons (digital buttons i.e., links connecting directly with social network platforms) that redirects them to DIAMALTERIA’s social networks.

The social networks allow DIAMALTERIA to improve the user-friendliness of the Site and help to promote DIAMALTERIA brand through social media interaction.

Where the User chooses to access DIAMALTERIA’s social networks through these buttons, DIAMALTERIA may have access to personal information that the User have indicated as public and accessible from his or her personal profile on these social networks. 

However, DIAMALTERIA does not create or use any databases from these social networks.

When accessing third-party platforms, the User should refer to their own privacy policies to better understand how Personal Data is processed by these third parties. For more information:

– Facebook Privacy Policy

– Instagram Privacy Policy

– LinkedIn Privacy Policy

– Youtube Privacy Policy

DIAMALTERIA holds no liability for how Personal Data is processed by third-party platforms.

In order to limit access to their Personal Data on social networks, the Users can set up their profile and/or the visibility of their publications via the dedicated spaces on the social networks concerned in order to control their accessibility and audience.

DETAILS ON THE USE OF GOOGLE MAPS

DIAMALTERIA displays Google Maps hyperlinks in the Site which redirects the User to DIAMALTERIA location as indicated on Google Maps platform.

Google Maps hyperlinks allow the User to locate the addresses of DIAMALTERIA establishments more easily.

DIAMALTERIA holds no liability for how Personal Data is processed on Google platforms.

For more information on data protection in connection with the use of Google Maps, the User shall consult Google Maps Privacy Policy on Google’s website.

USER RIGHTS

The User may exercise at any time the following rights towards DIAMALTERIA:

These rights may be exercised, or for any question related to the processing of Personal Data, with DIAMALTERIA’s Data Protection Officer (DPO):

–       By mail to:  Corso Lepetit n°6 – 25047 Darfo –Boario Terme (BS) to the attention of the DIAMALTERIA’s Data Protection Officer:

UPDATES

This Privacy Policy is effective on 24th  May 2023.

DIAMALTERIA reserves the right to review, modify or simply update, in whole or in part, at its sole discretion, in any way and / or at any time, without notice, this Privacy Policy also in consideration of changes in laws or regulations on the protection of personal data. Changes and updates to the Privacy Policy may be notified to users as appropriate by (i) sending e-mails to Users registered on the Site and / or (ii) appropriate publication on the Site and will be binding as soon as they are published and / or communicated. We therefore ask the Users to regularly access this section to check the publication of the most recent and updated Privacy Policy conditions or to check their e-mail box.