INFORMATION ON the PROCESSING OF PERSONAL DATA pursuant to Regulation (EU) 2016/679 of the european Parliament and of the Council of 27 April, 2016 (“GDPR” or “Regulation”)

Summary

No. 1. Identity and contact details of Minnelea s.r.l. in quality of holder of the processing of personal data.

No. 2. The processing of data for the purposes of access and registration to the Site, and the conclusion and execution of the purchase contract

No. 3. Data processing for the purpose of marketing generic

No. 4. Treatment of the e-mail address for the purposes of “soft spam”

No. 5. The processing of data for the purposes of service and customer care

No. 6. Data processing for administrative and accounting purposes and tax

No. 7. The processing of data for purposes of investigation, exercise or defence of a right

No. 8. The processing of data to allow the registered user to use the services of the Site

No. 9.Categories of subjects to whom Minnelea s.r.l. communicates personal data of the user (recipient)

No. 10. Transfer to third Countries

No. 11.The right of opposition

No. 12. The right of access

No. 13. Right of reply

No. 14. The right of cancellation

No. 15. Right to restriction of processing

No. 16. The right to data portability

No. 17. Timing and mode of response in the event of the exercise of the rights of the person concerned

No. 18. The right to lodge a complaint with a supervisory authority

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No. 1. Identity and contact details of Minnelea s.r.l. in quality of holder of the processing of personal data

Minnelea s.r.l. (“Minnelea”) is the holder of the processing of personal data of the users shown in the present disclosure and which was the subject of the data collected on the site https://www.terrabuona.it for the purposes therein mentioned.

The identity and contact details of Minnelea are the following:

- Minnelea s.r.l., with registered office in Rome, via Tufo n. 8/C, registered at the Rome Register of Companies with p. vat 15381801008, capital of € 10.000,00 the.v.

- e-mail: support@minnelea.com

- phone: +39 328 7017040

No. 2. The processing of data by Minnelea for the purpose of access and registration to the Site and of the conclusion and execution of the purchase contract

Minnelea will treat the personal data of the user for:

- allow registration on the Site and use the services reserved to registered users, including the possibility of purchasing online through the Site;

- allow for the completion of purchases through the Site, and the proper execution of the obligations arising from this agreement on the part of Minnelea;

- executing requests pre-submitted from the user.

The legal basis for this treatment is the fulfilment of the contract or, depending on cases, the implementation of precontractual measures taken at the request of the person concerned (art. 6.1.b) of the Regulation).

For this purpose, Minnelea will treat the data of the user for the time strictly necessary for the performance of the individual processing activities (ex: your registration data will be processed until the close of the account, taking into account the time necessary to the same; the data necessary for the execution of the purchase agreement, will be treated until the conclusion of the proceedings of purchase), provided that, after the expiry of the term, Minnelea may store the data for the purposes and to the maximum periods of retention referred to in other sections of this disclosure, if relevant, and/or, however, in the cases established by the Regulation and/or law.

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In particular, in the context of this purpose, Minnelea will treat the personal data of the users, among other things, to:

- to allow the user to register to the Website, creating an account, and use the services reserved to registered users, including, in particular, the possibility to buy through the Site;

- maintain and manage the account of the user;

- store in the user's account data and information;

- allow the user to conclude the purchase on the Website;

- the execution of the purchase contract concluded by the user with Minnelea through the Site, by making, where appropriate, the delivery of the purchased products.

The provision of data for the purpose in the object is optional: it does not exist any legal or contractual obligation of the communication of the data; however, because their processing is necessary to allow access to the Site and/or the navigation of the Website and/or registering for the Site and/or the provision of services of management and maintenance of the account Registration at the Site as well as the conclusion and the execution of the contract of purchase through the Site, or to respond to requests pre-made by the user in relation to the Site, the lack of communication of the data will entail the impossibility for the user to access and/or navigate on the Website and/or registering on the Site and make use of the services reserved for registered users and/or to conclude a purchase contract through the Website and/or receive a response to requests from pre-scan.

No. 3. Data processing for the purpose of marketing generic

The prior consent of the user, Minnelea will treat the personal data of the user to send, via email, information and promotional communications, including newsletters, related to the products and/or services and/or third parties, and for the purposes of direct sales or for carrying out market research.

The legal basis of this treatment is the express consent of the user (art. 6.1.a) of the Regulation).

The user can may at any time revoke the consent and/or oppose, at any time, to the processing of personal data for marketing purposes:

  • by contacting Minnelea to the following email address: support@minnelea.com

  • through the link in each promotional communication sent by Minnelea.

The provision of data for the purposes of marketing the generic is optional: there is no legal or contractual obligation assumed by the user to provide such data for such purposes and/or to provide consent to the processing of his personal data for such purposes.

For the purposes of marketing the generic, Minnelea will treat the data of the user until the revocation of the consent and/or the exercise of the right of opposition and, in any case, not later than 24 months from the collection of the data, reserving the right, before the expiration of that term, to ask the user for the renewal of the consent and/or updating of data.

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Informing the user as follows:

  • for the purposes of marketing the generic, Minnelea uses the personal data collected initially for other purposes, and, in particular, for the purposes of registration on the Website and/or conclusion and/or execution of the contract of purchase through the Site; such further processing is permitted, based on the consent of the data subject;

  • the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

  • in the event that the user objects to the processing of personal data for the purposes of marketing generic and/or revoke the consent to the treatment for purposes of marketing the generic, its data will not be processed by Minnelea for this purpose and will be retained by Minnelea only in the case where there is another legal basis (such as, for example, establishment, exercise or defence of a right in judicial or administrative);

  • the non-communication of data for the purpose of marketing generic and/or failure to provide consent to such treatment and/or the revocation of such consent and/or the exercise of the right of opposition does not involve any consequence on the possibility for the user to register to the Site and/or to make purchases on the same.

No. 4. Treatment of the e-mail address for the purposes of “soft spam”

Minnelea will e-mail details (i.e. email address) provided by the user in the context of a purchase on the Site, to allow Minnelea the direct sale of products or services which are similar (and then the sending for e-mail to the user of promotional communications with a subject such products and/or services) without the express consent and estimate of the interested party, as provided for by art. 130, FOURTH paragraph, of the Privacy Code, and provided that the user does not exercise the right of opposition with the procedures indicated in article 11 of this privacy policy (c.d. soft-spam).

The legal basis of this treatment is the art. 130, FOURTH paragraph, of the Privacy Code expressly allows the processing object.

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The provision of data for the purpose in the object is optional: there is no legal or contractual obligation assumed by the user to provide such data for this purpose. The non-conferment of data for the purpose of soft-spam or the opposition to this processing will not result in any impact on the possibility for the user to register to the Site and/or to make purchases on the same.

Informing the user as follows:

  • for the purposes of soft-spam Minnelea uses the personal data collected initially for other purposes, and, in particular, for the purposes of registration on the Website and/or conclusion and/or execution of the contract of purchase through the Site; such further processing is permitted, based on art. 130, IV paragraph, of the Privacy Code;

  • in the event that the user objects to the processing of personal data for the purposes of soft-spam, your data will not be processed by Minnelea for this purpose and will be retained by Minnelea only in the case where there is another legal basis (such as, for example, establishment, exercise or defence of a right in judicial and administrative).

No. 5. The processing of data for the purposes of service and customer care

Minnelea will treat users ' data for generic tasks of assistance and customer care, and then to give feedback to requests for information originating from the user or respond to complaints, complaints, complaints.

The legal basis of this processing is the execution of pre-contractual measures taken at the request of the person concerned (art. 6.1.b, last paragraph, of the Regulation) or, depending on cases, the legitimate interest of Minnelea (art. 6.1.f) of the Regulation).

Constitutes a legitimate interest of Minnelea respond to requests for information and/or reviews and/or reports and/or complaints and/or complaints of the users of the Site (to which, however, Minnelea is required to answer, also in accordance with the regulations referred to in the Code of the Consumption). Such a legitimate interest of Minnelea also coincides with the legitimate interest of the users of the Site who make requests and/or reports and/or complaints and/or claims in the subject and that, therefore, in the context of the relationship with Minnelea, it can be assumed that reasonably expect their personal data to be used by Minnelea to give them feedback.

The legitimate interest of Minnelea so identified can be considered to be so prevalent on the rights and freedoms of the data subject, also by reason of the reasonable expectations and the relationship between the data subject and Minnelea as well as in view of the nature of the treated data and the coincident interest of the interested parties themselves.

The user has, in each case, the right to oppose, at any time, for reasons related to his personal situation, to the processing of personal data concerning him for the purpose in the object (i.e. customer care).

The user can exercise this right by contacting Minnelea at the addresses indicated in art. 1 of this privacy statement.

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In the case of the exercise of the right of opposition to data processing for the purpose of service/customer care, Minnelea refrain from treating further personal data of the users for such purpose, except to demonstrate the existence of legitimate reasons, mandatory to proceed to the treatment that may prevail over the interests and the rights and freedoms of the data subject or for the determination, exercise or defence of a legal claim.

The provision of personal data for the purposes of object is optional: it does not exist, i.e., no legal obligation and/or contractual communication of the data; however, given the purpose of the treatment, the failure of communication of data and/or the exercise of the right of opposition can make it impossible to reply to the requests and/or reports and/or complaints, and/or to the complaints of the users, if the reply to these requests involves the processing of personal data of the user.

For this purpose, Minnelea will treat the data of the user only for the time necessary to carry out the required activities and, thus, in particular, for the time necessary to provide the information requested by the user or in order to respond to complaints and/or reports and/or complaints submitted by the user.

No. 6. Data processing for administrative and accounting purposes and tax

Minnelea will treat the user data for the purposes of performing the obligations of the administrative and/or accounting and/or tax associated with the provision of the services of the Site and/or the purchase contract concluded through the Website.

The legal basis of this treatment is the fulfilment of law obligations to which it is subject Minnelea (art. 6.1.c) of the Regulation).

The provision of data for the purpose in question is required, because the treatment is necessary to allow Minnelea to fulfill the requirements of the law on the same burden. The refusal to provide the data for this purpose will result in the inability for the user to use the Services of the Site and, in particular, to conclude purchases through the Site.

For this purpose, Minnelea will treat the user's data until the expiry of the terms of the law for the execution of each fulfillment of administrative, accounting and tax and/or for the storage time prescribed by law for the preservation of the documentation.

No. 7. The processing of data for purposes of investigation, exercise or defence of a right

Minnelea will treat the user data for the determination, exercise or defence of a right in all the relevant fora.

The legal basis of this processing is the legitimate interest (art. 6.1.f) of the Regulation.

Constitutes a legitimate interest of Minnelea seeking remedies to ensure the compliance of his contractual rights, or prove that you have complied with the obligations arising from the contract with the data subject or imposed on Minnelea by law. Such legitimate interest is in its turn foundation in the right of defence is constitutionally protected. It can therefore not be regarded as involving the fundamental rights and freedoms of the data subject, also because of the reasonable expectations of the same.

The user has, in each case, the right to oppose, at any time, for reasons related to his personal situation, to the processing of personal data concerning him for the purpose in the object (i.e. the defense of a law/legal purposes).

The user can exercise this right by contacting Minnelea at the addresses indicated in art. 1 of this privacy statement.

More information

Informing the user that, in particular, Minnelea will retain and possibly use the data:

  • for purposes of proof of fulfilment of the contract of purchase and/or provision of the services of the Site and/or to initiate or respond to actions relating to the contract and/or this performance in front of any administrative authority and/or jurisdiction and/or to protect their rights in the preliminary phase of the trial and/or the proceedings; for this purpose the data will be kept for 10 years from the conclusion of the purchase contract;

  • to try to have permitted the exercise of the rights provided for by the regulation and/or law and/or by the contract of purchase and logged as required by law and/or contract in respect thereof;

  • to prove that you have given feedback on complaints and/or reports and/or to the complaints of the users;

  • in the case of the exercise of the rights provided for by the Regulation, the data will be kept for 5 years from the date of certification have given any reply to the request of the person concerned or of such determination, if later;

  • in the case of the exercise of rights provided by the contract or by law, the data will be kept for 10 years from the closing of the practice or from the execution of the action that defines it; for the closure of the refers to the most recent correspondence relating to the exercise of the right in question;

  • in the case of complaints and/or reports and/or complaints, the data will be kept for three years from the closing of the practice, to be construed as the last correspondence in this regard.

It is also noted that:

  • the provision of data for this purpose is optional: there is no obligation of law or contract that imposes on the person concerned to provide the data for this purpose;

  • for the purposes in question are used data collected initially for a different purpose, for which further processing is allowed based on the legitimate interest of the owner, hold the compatibility of such purposes further the purposes of the initial collection, also considering the fact that, to the extent that the processing is necessary to establish, exercise and defend a right, the holder of the treatment is also exempted from the requirement of cancellation, by express provision of the Regulation;

  • in the case of the exercise of the right of opposition, in fact, the holder of the treatment we refrain from treating further personal data, unless he demonstrates the existence of legitimate reasons, mandatory to proceed to the treatment that may prevail over the interests, rights and fundamental freedoms of the data subject or for the determination, exercise or defence of a legal claim.

No. 8. The processing of data to allow the registered user to use the services of the Site

Minnelea will treat the data of the registered user to the Site to allow you to take advantage of the services indicated on the personal page of the latter.

The legal basis for this treatment is the fulfilment of the contract or, depending on cases, the implementation of precontractual measures taken at the request of the person concerned (art. 6.1.b) of the Regulation).

For this purpose, Minnelea will treat the data of the user for the time strictly necessary for the performance of the individual processing activities, provided that, after the expiry of the term, Minnelea may store the data for the purposes and to the maximum periods of retention referred to in other sections of this disclosure, if relevant, and/or, however, in the cases established by the Regulation and/or law.

More information

The provision of data for the purpose in the object is optional: it does not exist any legal or contractual obligation of the communication of the data; however, because their processing is necessary to allow you to take advantage of the services reserved for registered users of the Site, the lack of communication of the data will entail the impossibility for the registered user to avail these services.

No. 9.Categories of subjects to whom Minnelea communicates personal data of the user (recipient)

The personal data provided by the user can be communicated by Minnelea to the categories of recipients mentioned below.

The subjects to which Minnelea communicates the data, act as external managers of the treatment designated by Minnelea through a special agreement (as"data processors") or persons designated to the processing of personal data under the direct authority of Minnelea (“Designated”) or in the case of third parties which the controller uses, as “Sub-Managers”, for the purposes referred to in art. 28.4 of the Regulation, except in cases in which the recipients act in their capacity of autonomous controller of the data processing, such as, for example, in the case of the Payment Service Provider, or autonomous holders of the treatment, as in the case of couriers.

The personal data of users may be communicated by the Minnelea to the following categories of recipients:

  • sellers partner Minnelea that sell products through the Site;

  • employees of Minnelea, to carry out activities of administration, accounting and computer support, and logistics;

  • companies, consultants or professionals eventually in charge of installing, maintenance, updating and, in general, the management of the hardware and software Minnelea (including the platform);

  • to the company in charge from Minnelea the sending of commercial communications via e-mail or by mail;

  • to companies that perform support activities, logistics and/or shipping and delivery or pickup of Products purchased on the Site and the third party which they use;

  • the Payment Server Provider and/or acquirer and/or banks in order to allow the payment of purchases made on the Site or their refund, if any, and to the third parties which they use;

  • to all those persons, including public authorities, that have access to the data by virtue of legislation or administrative;

  • to all those public and/or private, natural persons and/or juridical persons (legal consultancy firms, administrative and tax), if the communication is necessary or functional to the correct fulfillment of the contractual obligations in relation to purchases made on the Site, as well as the obligations arising from the law, that is, in the case of assessment, exercise or defence of a right.

No. 10. Transfer to third Countries

The personal data of the users are not transferred to countries outside the EU.

No. 11. The right of opposition

The interested party has the right to oppose, at any time, for reasons related to his particular situation to the processing of personal data undertaken for the purposes of having as a legal basis for the legitimate interest of the data controller.

In the case in which the data are processed for the purposes of direct marketing, the data subject also has the right to object at any time to the processing of personal data carried out for such purposes.

The user can exercise this right by contacting Minnelea at the addresses indicated in art. 1 of this privacy statement.

In the case of the exercise of the right of opposition, Minnelea refrain from treating further personal data, unless he demonstrates the existence of legitimate reasons, mandatory to proceed to the treatment which shall prevail over the interests, rights and freedoms of the data subject or for the determination, exercise or defence of a legal claim.

If the person concerned objects to the processing for direct marketing purposes, the personal data are not processed for this purpose.

No. 12. The right of access

The interested party has the right to obtain from Minnelea confirmation as to whether or not the processing of personal data concerning him and, in this case, to obtain access to the personal data and information indicated below.

The user can exercise this right by contacting Minnelea at the addresses indicated in art. 1 of this privacy statement.

More information

In the case of the exercise of the right of access, the user can obtain access to the personal data and the following information:

  • the purpose of the processing;

  • the categories of personal data concerned;

  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or international organisations;

  • when possible, the period of retention of personal data provided or, if not possible, the criteria used to determine this period;

  • the existence of the right to request to the data controller the rectification or erasure of the personal data or restriction of processing of personal data or to oppose to their treatment;

  • the right to lodge a complaint with a supervisory authority;

  • if the data are not collected from the data subject, any available information as to their source;

  • the existence of an automated decision-making process, including profiling which produces legal effects concerning the data subject or which would affect in a similar way, significantly, on his person, and at least in such cases, meaningful information on the logic used, as well as the importance and the predicted consequences of such processing for the data subject.

Minnelea provides a copy of the personal data object of treatment. In the case of additional copies requested by the person concerned, Minnelea may charge a reasonable fee based on administrative costs. If the data subject makes the request using electronic means, and unless otherwise requested by the data subject, the information shall be provided in an electronic format in common use.

No. 13. Right of reply

The interested party has the right to obtain from Minnelea the rectification of personal data without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain completion of incomplete personal data, including by providing a declaration to the financial statements.

The user can exercise this right by contacting Minnelea at the addresses indicated in art. 1 of this privacy statement.

No. 14. The right of cancellation

The interested party has the right to obtain from Minnelea the erasure of personal data without undue delay and Minnelea has the obligation to erase, without undue delay, the personal data, if there is any one of the following reasons:

  • - the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

  • the person concerned revoke the consent on which the processing is based, if there is no other legal basis for the processing;

  • the data subject opposes to the processing based on the legitimate interest of the holder of the treatment, for reasons related to his particular situation and there is no legitimate reason prevailing or oppose to the processing of his personal data for direct marketing purposes, including profiling to the extent related to such direct marketing;

  • the personal data are processed unlawfully;

  • the personal data must be deleted in order to fulfil a legal obligation laid down by the law of the Union or of the member State to which it is subject, the holder of the treatment.

No. 15. Right to restriction of processing

The interested party has the right to obtain from Minnelea the limitation of the treatment when one of the following assumptions:

  • the data subject disputes the accuracy of the personal data for the period of time necessary to Minnelea to verify the accuracy of such personal data;

  • the processing is unlawful and the data subject opposes the erasure of personal data and instead asks that it is limited to use;

  • although Minnelea are no longer required for the purposes of the processing, the personal data are necessary for the interested party to the determination, exercise or defence of a legal claim;

  • the person concerned is opposed to the treatment in the case of the processing based on the legitimate interest of the owner of the processing, on grounds relating to their particular situation, pending verification as to whether the prevalence of legitimate reasons to Minnelea than those of the person concerned.

The user can exercise this right by contacting Minnelea at the addresses indicated in art. 1 of this privacy statement.

More information

If the treatment is limited, the personal data object of the limitation are treated, except for the storage, only with the consent of the data subject or for the determination, exercise or defence of a legal claim, or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or of a member State.

The subject who obtained the restriction of processing is informed by the controller before the restriction to be revoked.

No. 16. The right to data portability

The interested party has the right to receive, in a structured format, and readable by the automatic device, the personal data provided to Minnelea and has the right to transmit such data to another holder of the treatment without any impediments from the part of the holder of the treatment which he has provided, if:

  • the treatment is based on the data subject's consent or on a contract;

  • the treatment is carried out by automated means.

The user can exercise this right by contacting Minnelea at the addresses indicated in art. 1 of this privacy statement.

More information

In exercising his right to portability of data, the data subject has the right to obtain the direct transmission of personal data by a data controller of the processing to the other, if technically feasible.

The exercise of the right of portability is without prejudice to the right to cancellation.

The right to portability should not adversely affect the rights and freedoms of others.

No. 17. Timing and mode of response in the event of the exercise of the rights of the person concerned

Minnelea provides the data subject the information about the actions taken in relation to a request for exercise of the rights recognized by art. from 15 to 22 of the Regulation (i.e. right of access, right of rectification, right of erasure, right to restriction of processing, the right to data portability, right to object) and by this privacy notice (“Rights of the Interested party”), without undue delay and, in any event, within one month from the receipt of the request. This period may be extended by two months, if necessary, taking into account the complexity and number of requests. Minnelea shall inform the person concerned of such extension and the reasons for the delay, within one month from the receipt of the request. If the data subject makes the request using electronic means, the information shall be provided, where possible, by electronic means, unless otherwise specified by the person concerned.

More information

If you do not comply with the request of the person concerned, Minnelea shall inform the person concerned without delay, and no later than within one month from the receipt of the request, of the reasons for the non-compliance and of the possibility to lodge a complaint with a supervisory authority and seeking a judicial remedy.

Communications in response to the exercise of the Rights of the person Concerned and the actions taken are free of charge. If the requests are manifestly unfounded or excessive, in particular due to their repetitive character, the holder of the treatment can:

  • charge a reasonable fee, taking into account the administrative costs incurred to provide notices or to take the requested action;

  • refuse to meet the demand.

When Minnelea commission has reasonable doubts about the identity of the person submitting the request relating to the Rights of the data subject may request any additional information required to confirm the identity of the person concerned.

No. 18. The right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, the data subject considers that the processing which concerns him violates the Regulation shall have the right to lodge a complaint with a supervisory authority, in particular in the member State in which he resides, works, or of the place where occurred the alleged violation. The supervisory authority to which it was proposed the complaint shall inform the complainant of the status or outcome of the complaint, including the possibility of a judicial review.