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Privacy, Policy and Cookies

With this disclosure, drafted pursuant to art. 13 of EU Regulation 679/2016 (“GDPR”), Venchi S.p.A. provides you with information concerning the processing of your personal data provided to Venchi in relation to: 

A.    registration on the website Venchi.com, in the Italy (https://it.venchi.com/), Europe (https://eu.venchi.com/) and United Kingdom (https://uk.venchi.com/) sections (“Website”), which allows for the creation of a user profile and entails automatic registration in the “V-CLUB” Loyalty Programme (“Loyalty Programme” or “Programme”); 
B.    access to the Website for the purchase of products without any registration (“Guest Profile”); 
C.    registration in the “V-CLUB” Loyalty Programme (“Loyalty Programme” or “Programme”); 
D.    the use of the “contact us” and “careers” sections (“Contact Us and Careers”);
E.    the receipt of commercial communications (“Commercial Communications”).

hereinafter referred to, overall, as the “Channels”. 

1.    DATA CONTROLLER AND DATA PROCESSORS 

The Data Controller as concerns the personal data collected is Venchi S.p.A. (hereinafter, “Venchi” or the “Data Controller”), with registered office at Via V. Monti 8, 20123 Milan (MI) and administrative office at Via Venchi 1, 12040, Castelletto Stura (CN). 
The personal data collected may also be processed by employees of Venchi, duly appointed as parties authorised to perform processing, and by third parties, Venchi Group Companies or service providers that act on behalf of Venchi as Data Processors, which will process the data in compliance with the purpose for which the data were collected.


2.    PROCESSING METHODS 

The processing of personal data consists of the operations set forth in art. 4, no. 2 of the GDPR or: the collection, recording, organisation, storage, consultation, processing, alteration, selection, extraction, comparison, use, combination, blocking, dissemination, erasure and destruction of the data. The processing may take place in hard copy and/or digital form, with organisational methods and approaches strictly correlated with the purposes specified.


3.    PERSONAL DATA PROCESSED, PURPOSES OF THE PROCESSING AND LEGAL BASIS

With respect to each Channel, Venchi collects and processes specific personal data for the following purposes. 

A. Registration on the Website 

By registering on the Website, users create their personal profile with which their purchases on the Website will be associated, and enrol in the Loyalty Programme (in relation to which, for additional information, please refer to Section 3.C below). At that time, Venchi may collect the following personal data: 
a)    identifying data (name, surname); 
b)    email address;
c)    language;
d)    domicile or residence post code;
e)     date of birth;
f)    telephone number. 

The provision of the data pursuant to letters a), b) and c) above is optional but necessary in order to complete registration. Therefore, lacking such data, it will not be possible to complete registration and therefore place orders with one’s personal profile and enrol in the Loyalty Programme.

The provision of the data set forth in letters d), e) and f) is instead at the discretion of the user.

Specifically with reference to the telephone number, the data controller specifies that should the user freely decide to provide a telephone number and provide consent to the receipt of Commercial Communications (as defined in more detail in section “3.E.1. Commercial Communications (Generic, Profiled and Third-Party Marketing)” below), this information will be used for sending Commercial Communications via SMS (as defined in more detail in section 3.E.1 below).

Furthermore, when products are ordered, the following additional information will be requested, which is required in order to complete the order:
a)    delivery address; 
b)    payment data, credit/debit card number and associated name and surname, date of expiry of the credit/debit card, billing address. 

If the user wishes to receive an electronic invoice after making a purchase, the personal data provided to request electronic invoicing (including the tax code) will be processed by Venchi with the same methods as those set forth above in order to proceed with such invoicing. The provision of invoicing data is optional, but refusal to provide them will make it impossible to proceed with electronic invoicing. 

Venchi will process the personal data mentioned above for the following purposes and on the following legal bases: 
(i)    to create your profile and perform the contract to which you are party (in order to complete a product order and, possibly, request electronic invoicing) or precontractual measures at your request, as well as meet the legal obligations and/or the accounting purposes connected to the contract in addition to allowing the Data Controller to exercise its right to defence. The legal basis of the processing is therefore the performance of the contract, the fulfilment of a legal obligation and the pursuit of a legitimate interest pursuant to art. 6.1, letters b), c) and f) of the GDPR. 
(ii)   to enrol the user in the Loyalty Programme, to send you, as a registrant, communications linked to the Programme and to enable you to take advantage of any correlated benefits, pursuant to art. 6.1, letter b) of the GDPR, as described in more detail in Section 3.C below;
(iii)  if you provide your autonomous and specific consent, to send you generic commercial communications (as described in more detail in section 3.E.1.a) below). The legal basis of the processing is therefore user consent pursuant to art. 6.1, letter a) of the GDPR;
(iv)  if you provide your autonomous and specific consent, to analyse your consumption habits and the relative purchase decisions and send you commercial communications in line with your preferences as described in more detail in section 3.E.1.b) below. The legal basis of the processing is therefore user consent pursuant to art. 6.1, letter a) of the GDPR;
(v)  if you provide your autonomous and specific consent, Venchi may send you commercial communications in order to promote and/or advertise products/services of Venchi’s commercial partners (as described in more detail in section 3.E.1.c) below). The legal basis of the processing is therefore user consent pursuant to art. 6.1, letter a) of the GDPR; 
(vi)  to send you, on the basis of the legitimate interest of the Data Controller, commercial communications aligned with your previous purchases, as described in more detail in section 3.E.2. below, pursuant to art. 6.1, letter f) of the GDPR. 

The personal data will be stored and shared in accordance with what is set forth below in sections “4. Recipients of personal data and processing location” and “5. Duration of processing and data retention period”. 

You may cancel your registration in the Loyalty Programme at any time, in compliance with its terms and conditions. In this case, your personal data will be processed by Venchi only for the purposes connected only to registration on the Website and the correlated purchases made through the Website. In any event, you may delete your personal profile created in order to register on the Website at any time by contacting the Data Controller at the address privacy@venchi.com; subsequently, you will receive a cancellation confirmation notice. 

Cancellation of your personal profile will also entail, in and of itself, cancellation from the Loyalty Programme and de-registration from the Commercial Communication receipt service, as described in more detail in sections 3.E.1. and 3.E.2.

With regard to navigation on the Website, please note that we use cookies and analogous mechanisms to facilitate your navigation, understand how you interact with us and, in certain cases, to show you ads based on your navigation habits or combine such data with other data processed internally in order to enhance your user profile. Please read our cookie disclosure at the link uk.venchi.com/cookie-policy to obtain detailed information about the functioning of the cookies and similar mechanisms that we use, the respective purposes and other pertinent information.

B. Purchases through the Website using a “Guest Profile” 

Users who wish to purchase products without creating a profile on the Website may proceed in guest mode. In this regard, it will be necessary to enter personal data (name and surname), contact data (email address), a telephone number, the necessary delivery information and payment data. 
Unless you provide your autonomous consent, the information entered will be processed only for the purposes pursuant to section 3.A, point (i), limited to the completion and fulfilment of the purchase order placed and the fulfilment of the associated legal obligations, and point (vi); with respect to the purposes pursuant to point (vi), please note that only the email address provided by the user in relation to the purchases made will be used. 
The personal data will be stored and shared in accordance with what is set forth below in sections “4. Recipients of personal data and processing location” and “5. Duration of processing and data retention period”. 

C. Registration in the Loyalty Programme 

Within the scope of the Loyalty Programme, Venchi will process the personal data of the data subjects, as described in more detail in section A above, for the following purposes and on the following legal bases:
(i)    to complete registration in the Loyalty Programme, to send you, as a registrant, communications linked to the Programme, and to enable you to take advantage of any correlated benefits, pursuant to art. 6.1, letter b) of the GDPR;
(ii)   if you provide your autonomous and specific consent, to send you generic commercial communications as described in more detail in section 3.E.1.a) below, pursuant to art. 6.1, letter a) of the GDPR;
(iii)  if you provide your autonomous and specific consent, to analyse your consumption habits and the relative purchase decisions and send you commercial communications in line with your preferences (as described in more detail in section 3.E.1.b) below), pursuant to art. 6.1, letter a) of the GDPR;
(iv)  if you provide your autonomous and specific consent, Venchi may send you commercial communications in order to promote and/or advertise products/services of Venchi’s commercial partners (as described in more detail in section 3.E.1.c) below), pursuant to art. 6.1, letter a) of the GDPR. 

In the event of registration in the Loyalty Programme, consent for the receipt of the Commercial Communications mentioned above is optional, and you may in any event register in the Programme even without providing this consent and may in any event, at any subsequent time, revoke the consent previously provided, without this jeopardising the lawfulness of the processing performed based on the consent provided prior to revocation. If such consent is not provided or is revoked, you will continue to receive only emails relating to the Programme and the benefits accrued in relation to registration in the Programme.

The personal data will be stored and shared in accordance with what is set forth below in sections “4. Recipients of personal data and processing location” and “5. Duration of processing and data retention period”. 

D. Use of the Contact Us and Careers sections

The user may contact Venchi through the “Contact Us” section on the Website. The personal data provided by the user, such as name, surname, email address (compulsory in order to send the request) and telephone number (optional in order to send the request), as well as the reason for contact and any additional personal data entered within the text of the request, sent by completing the form present on the Website, will be processed in order to respond to the request sent by the user, and the legal basis consists of the performance of a contract to which the user is party or the performance of the precontractual measures adopted at the user’s request or the fulfilment of legal obligations, pursuant to art. 6.1, letters b) and c) of the GDPR.

Users may also contact Venchi by sending a job application and their CV to the email address specified in the “Careers” section of the Website. The personal data transmitted (contact data, data relating to professional qualification and other data contained in the CV) will be processed only for recruitment purposes, to enable the Data Controller to evaluate job applications from users and to contact users when necessary. Although the provision of the data is optional, the failure to provide such data will make it impossible for us to take your application into consideration. If the user provides us with special categories of data (included on the list pursuant to art. 9 of European Regulation no. 679/2016, such as data relating to health, racial or ethnic origin or trade union membership) to process your request such data will be processed pursuant to art. 9, par. 2, letter B). The legal basis of the processing of common personal data consists of the performance of precontractual measures adopted at the request of the user pursuant to art. 6, paragraph 1, letter b) of the GDPR while, for the processing of special categories of personal data, the legal basis is the need to meet obligations and exercise the specific rights of the data controller or the data subject concerning labour law and social security and social protection law, in compliance with article 9, paragraph 2, letter b) of the GDPR.

The personal data will be stored and shared in accordance with what is set forth below in sections “4. Recipients of personal data and processing location” and “5. Duration of processing and data retention period”. 

E.1. Commercial Communications (Generic, Profiled and Third-Party Marketing)

By registering, users may take advantage of the Commercial Communication receipt service. 
    a)    In this regard, users may provide their explicit consent to receiving generic Commercial Communications (“Generic Marketing”), including the receipt of newsletters containing informational, promotional, commercial and advertising information relating to Venchi products and invitations to events and communications regarding any special store openings/closings, catalogues and postcards with invitations to Venchi events and special promotions. The processing of personal data in order to send Generic Marketing communications will be possible only with the explicit consent of the user, provided by ticking the relative box, pursuant to art. 6.1, letter a) of the GDPR. The provision of an email address to this end is optional, but lacking such information, the user’s request to register for the generic commercial communication receipt service cannot be fulfilled. 
    b)    Users may also provide their explicit consent to profiling (analysis of their consumption habits and the relative purchase decisions, categorisation of parties with similar characteristics, automated processing to this end) and the receipt of profiled Commercial Communications (“Profiled Marketing”), other than those pursuant to section 3.E.2 below, including the receipt of newsletters, personalised in line with preferences, characteristics and the consumption and purchase habits of users and with their behavioural data (for example, if users have expressed their interest in a specific product, we may offer them this type of communication again in the future, assuming that it is of interest to them, or send them dedicated commercial offers) and Website navigation data (such as, for example, the selection of products included in the shopping cart), in order to guarantee a personalised service to users, which is as aligned as possible with their personal tastes. The processing of personal data for profiling purposes in order to subsequently send Profiled Marketing communications will be possible only with the explicit consent of the user, provided by ticking the relative box, pursuant to art. 6.1, letter a) of the GDPR. The provision of an email address to this end is optional, but lacking such information, the user’s request to register for the profiled commercial communication receipt service cannot be fulfilled.
   c)    Users may also provide their explicit consent to Venchi sending Commercial Communications that promote or advertise products/services of third-party partners of Venchi (“Third-Party Marketing”). The processing of user personal data in order to send Third-Party Marketing communications will be possible only with the explicit consent of the user, provided by ticking the relative box, pursuant to art. 6.1, letter a) of the GDPR. The provision of an email address to this end is optional, but lacking such information, the user’s request to register for the third-party commercial communication receipt service cannot be fulfilled. 
The personal data will be stored and shared in accordance with what is set forth below in sections “4. Recipients of personal data and processing location” and “5. Duration of processing and data retention period”.

Users may revoke the consent previously provided for Generic Marketing, Profiled Marketing and/or Third-Party Marketing Commercial Communications at any time, by following one of the procedures set forth below: 
-    by accessing their personal area on the Website and then revoking, individually, each of the consents previously provided for such Commercial Communications; 
-    by de-registering using the cancellation link present at the end of the communications received (any additional instructions will be provided to you directly in the communications that you will receive from Venchi). By following this de-registration procedure, users will revoke all consents previously provided for such

Commercial Communications at the same time, when not specified otherwise;
-    by sending a request in this regard to privacy@venchi.com in which users may specify which specific consent previously provided that they would like to revoke. 

In any case, any revocation will not jeopardise the lawfulness of the processing activities carried out by Venchi until that moment as well as the lawfulness of the processing activities carried out by Venchi on the basis of consent that has not been expressly revoked. 

The revocation of consent to the receipt of commercial communications does not entail in and of itself the cancellation of the personal profile on the Website, which must take place according to the methods set forth in section “A. Registration on the Website and online purchases” above. 

E.2. Commercial Communications in line with purchases already made 


Venchi may also send you emails concerning Venchi brand products analogous to those you have already purchased, on the basis of Venchi’s legitimate interest in this regard, as set forth in art. 130, par. 4 of the Personal Data Protection Code - Italian Legislative Decree no. 196/2003 (“soft spam”). The interest of the Data Controller is linked to a company’s general interest in promoting its products and is considered legitimate provided it is aligned with the reasonable expectations of the data subjects, taking into account the relationship between them and the Data Controller. 

Therefore, as this processing is based on the legitimate interest of the Data Controller pursuant to art. 6.1, letter f) of the GDPR, no explicit user consent is required for this processing. In any event, at any moment you may express your desire to no longer receive the communications mentioned above by exercising, pursuant to the law, the right to object, by sending a request in this regard to the address privacy@venchi.com. 

Any objection to processing by the user shall not jeopardise the lawfulness of the processing carried out until that moment, nor will it have any effect on the future purchase of Venchi brand products.

4.    RECIPIENTS OF PERSONAL DATA AND PROCESSING LOCATION 

Your personal data may be shared with: 
o    Venchi Group companies; 
o    the personnel of Venchi and service providers for the processing and management of your orders;
o    the personnel of Venchi, providers of logistics services, couriers and shippers in order to deliver the products; 
o    banks and providers of payment services for the management of collections and payments deriving from the performance of contracts with the user;
o    the personnel of Venchi and service providers for the creation and maintenance of the Website; 
o    the personnel of Venchi and service providers for the management and hosting of databases;
o    the personnel of Venchi and service providers for the assessment of job applications from users and to recontact them if necessary;
o    legal, administrative and tax consultants, banks, companies, entities, consortia or credit protection associations; 
o    in the required cases, the personnel of Venchi, service providers and collaborators linked to marketing and advertising, such as social media websites, networks, advertising agencies or advertising partners.

Your personal data will be processed primarily in the European Union. Your personal data may also be processed by parties (internal or external with respect to the Data Controller) whose registered office or data processing location is not found in a Member State of the European Union or in another Country party to the European Economic Area Agreement. In these cases, we ensure prior to the transfer that, except when permitted by law, the party performing the processing guarantees an adequate level of data protection (for example, as it operates in a country that guarantees an adequate level of data protection according to an adequacy decision of the European Commission pursuant to article 45 of the GDPR, by means of appropriate safeguards pursuant to article 45 of the GDPR or by entering into EU standard contractual clauses with the data importer, pursuant to article 46, paragraph 2, letter c) of the GDPR or, alternatively, by meeting the obligations and arranging for the protections set forth in art. 49, par. 1 of the GDPR) or you have expressed your consent to such data transfer pursuant to art. 49, paragraph 1, letter a) of the GDPR.

5.    DURATION OF PROCESSING AND PERSONAL DATA RETENTION PERIOD

User personal data will be stored only for the period necessary to achieve the purposes for which they are processed, or for any different period set forth by regulations in force. Specifically:

A. Registration on the Website and online purchases and
B. Purchases through the Website using a “Guest Profile”

With the exception of data processed in relation to registration in the Loyalty Programme, for which what is set forth in section 5.C below will apply, the personal data provided for registration on the Website and the resulting creation of a personal profile will be stored until the user requests the cancellation of the personal profile, without prejudice to any longer term required to permit the Data Controller to meet its legal obligations, accounting purposes and/or to exercise its right to defence. 
The personal data provided in order to purchase a product (through registration on the Website or by means of a Guest Profile) or a service will be stored for the entire duration of the contract and for a period of 10 years subsequent to its termination. 

C. Registration in the Loyalty Programme 

The personal data processed in relation to registration in the Loyalty Programme will be stored for a period of time not to exceed that strictly necessary for the purposes for which the data were collected. In particular, the data will be stored for the entire duration of the Loyalty Programme and, following discontinuation, for the ordinary prescriptive period of 10 years. 

D. Use of the Contact Us and Careers sections

The personal data provided by users who contact us via the “Contact Us” section will be stored for 24 months or any longer term necessary to resolve the request. 
The information and personal data provided by users who send us their job application/CV via the Careers section will be stored for a period of time exceeding the purposes for which they were gathered and, in any event, not beyond 24 months from when they were provided. 

E.1. Generic, Profiled and Third-Party Marketing Communications

The personal data voluntarily entered by the user on the Website will be stored - for Generic, Profiled or Third-Party Marketing purposes - until the revocation of each of the consents provided and, in any event, not beyond 36 months from the date of the last specific expression of consent, or modification of consent previously provided, by the user (for example: if the user decides to revoke consent to Profiled Marketing and Third-Party Marketing communications, the consent - not expressly revoked at that time - to General Marketing communications will be renewed for an additional 36 months, in any event without prejudice to the user’s right to revoke any of the consents provided at any time).

E.2. Commercial Communications in line with purchases already made

For the processing linked to Commercial Communications sent in line with purchases already made, the user’s personal data will be stored until the user’s exercise of the right to object, as described in section 3.E.2. 

At the end of the storage periods laid out above, your personal data will be completely erased, aggregated or rendered anonymous so that they may be used in a non-identifiable manner for statistical analysis purposes.

6.     RIGHTS OF THE DATA SUBJECTS 

In your capacity as “Data Subject”, at any time and when the conditions laid out by regulations are met, you may exercise the rights set forth in arts. 15 et seq. of the GDPR. 
In particular, you may exercise: 
-    the right of access: you may request information concerning the processing of your data, as well as receive a copy of the data processed;
-    the right of rectification: you may verify the accuracy of your data, as well as request their rectification or updating;
-    the right to erasure: you may request, when specific conditions are met, the erasure of your data;
-    the right of restriction: you may request, when specific conditions are met, the restriction of the processing of your data;
-    the revocation of consent: in all cases in which the legal basis of the processing is consent, you may revoke such consent at any time, without prejudice in any event to the lawfulness of the processing performed prior to such revocation;
-    right to submit a complaint to the Personal Data Protection Authority: without prejudice to any other administrative or legal action, you may submit a complaint to the Personal Data Protection Authority, according to the procedures and instructions published on the Authority’s website, available at the address https://www.garanteprivacy.it/.

7.    CONTACTS

To exercise the rights set forth above or obtain additional information on processing, you may contact the Data Protection Officer (DPO) of the Data Controller directly at the email address privacy@venchi.com or send a registered letter for the attention of the Privacy Office of Venchi S.p.A., Via V. Monti 8, 20123 Milan (MI). 

8.    AMENDMENTS TO THE PRIVACY POLICY 

This policy is valid as of the date specified in the header. 

When deemed appropriate, we may amend and/or supplement the information contained in this policy, also - but not only - as a consequence of any subsequent regulatory amendments of and/or additions to the GDPR. Any update and/or amendment will be disclosed to you in various methods via the Website (for example, with a banner, a pop-up or a push notification) or via additional means identified by the Data Controller, so that you may view the changes, make your assessments and, if appropriate, object to or cancel any services or functions. In any event, we urge you to regularly view this policy, which is always available on our Website, to verify any minor amendments or interactive improvements.  

Date of most recent update: 09/06/2023