Privacy policy

1.    Introduction

This document sets out the external privacy policy to be published on all Foodbrand Group websites. Pursuant to Article 13 of the GDPR, when personal data relating to a data subject are collected from the data subject, Foodbrand will provide the data subject with the following information:

a) Foodbrand’s identity, contact details and representative, where applicable;

b) the contact details of the data protection officer, where applicable;

c) the purposes of the processing for which the personal data are to be used as well as the legal basis for the processing;

d) where the processing is based on Article 6 (legitimate Interest), paragraph 1, letter f), the legitimate interests pursued by the controller or by a third party;

e) the recipients or categories of recipients of the personal data, if any;

f) where applicable, the fact that Foodbrand intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49, reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.

In order to ensure fair and transparent processing in respect of the data subject, Foodbrand will provide the following additional information (Article 13(II):

a) the retention period of the personal data or, if not possible, the criteria used to determine that period;

b) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;

(c) where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;

d) the right to lodge a complaint with a supervisory authority;

e) whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;

f) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2.    Contents of the privacy policy

2.1. Your privacy is important to us

Your privacy and the security of your personal data are very important to Foodbrand S.P.A. (“Foodbrand”). This is why we collect and manage your personal data with the utmost care and take all necessary security measures.

Below you will find information on how we process personal data obtained from browsing or the use of services we offer. For detailed information on how Foodbrand manages your personal data, please read this privacy policy in its entirety.

Some services may be subject to different legal terms. We will provide all the relevant information in such cases.

2.2.Controller

The controller of personal data processing is Foodbrand S.P.A., with registered office at Via Giovanni Antonio Amadeo 59, 20134 Milan (MI), Italy, VAT and Tax ID No. 09069350966(“Foodbrand”).

Contact: privacy@foodbrand.com

Foodbrand is the controller of activities performed by the following group companies:

• BOVE LOVER S.r.l.
• BREWERY DM S.r.l
• Doppio Malto S.p.A.

This privacy policy applies to the following websites:

• https://www.doppiomalto.co.uk/en/
• https://www.bovelover.com/
• https://www.foodbrand.com/it/

2.3.Processor

Where processing is to be carried out on behalf of Foodbrand, Foodbrand shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of this Regulation and ensure the protection of the rights of the data subject.

2.4.Processor of processing

Foodbrand collects and processes your personal data for the following purposes:

• To conclude and execute the purchase contract for the products offered on Foodbrand Group websites. When you conclude your purchase, we ask for the personal data necessary for the execution of the contract, such as payment, invoicing, product shipment and management of any returns.
• registration on the Foodbrand Group websites and use of the services offered to registered users. It is possible to register by entering some personal information, which is necessary to ensure your identification and the fulfilment of services offered to registered users.
• provision of the services offered on Foodbrand Group websites. To this end, for each service and its characteristics, Foodbrand needs to collect the personal data necessary for the provision of the service you request.
• Handling requests to our offices, which use the personal information you provide to process your inquiries and service requests.
• the sending of CVs. If you send us your CV to be considered for a job application, we will use the information in your CV solely for that purpose. Your CV will be stored for a maximum of eighteen months, after which it will be deleted. Naturally if you wish, you can send us a new, updated version.
• analysis and statistical surveys. We use some information on your use of Foodbrand Group sites for statistical analysis and research in order to improve our service provision;
• the sending of commercial and promotional communications following the purchase of one of our products; so-called ‘soft spam’. Following the purchase of our product on Foodbrand Group websites, we will send you communications on commercial proposals for related products and services to the email address you provided.
• With your express consent, we may use your contact details for commercial communications regarding our products and services, to update you on new products, new arrivals, exclusive products, or our offers and promotions. Also, again subject to your prior consent, we may use your contacts as part for market research and customer satisfaction surveys to improve our services and relations with users. These communications will be made exclusively by the methods you have chosen (by email, SMS, telephone, post, instant messaging).
• only with your consent will Foodbrand be able to personalise your experience as a registered user on Foodbrand Group websites, proposing offers in advance and in line with your tastes and sending you personalised commercial communications according to your interests. These communications will be made only in the manner you have chosen (by e-mail, SMS, telephone, post or instant messaging). Communications are customised by analysing your previous purchases and the other information described above in the paragraph entitled “Personal data collected” . For more information on this data and how it is processed, see the paragraph entitled “Your Foodbrand account”.
• If you wish to authorise the activities described in the above points but subsequently do not wish to receive further communications from Foodbrand, or wish to limit the methods by which you may be contacted, you can at any time cancel these communications by simply clicking on the relevant Foodbrand Group “unsubscribe” link at the bottom of each communication, or by sending an email with “privacy” as the subject.
• Please note that you may receive further communications from us even after your unsubscribe request has been submitted, as some despatches may have already been scheduled and our systems may take some time to process your request.
• In all the activities indicated above, your personal data will be processed mainly by computerised and electronic means, in full compliance with applicable legislation.

2.5. Data processed

The categories of personal data that Foodbrand collects and processes when you browse or purchase on Foodbrand are as follows:

• we collect the personal data necessary to conclude and execute your purchase on Foodbrand Group websites, such as your name, email address, shipping address, billing address, telephone and payment details;
• we collect your email address when you sign up for our newsletter service;
• we process the personal data you provide to us when you contact our offices, in order to provide you with the requested information;
• with your consent, we collect and use your personal data for marketing purposes;
• we collect your email address and password in order to register your account on Foodbrand.it. If you are a registered user, we collect information on your access to the restricted area of the Foodbrand Group Websites. With your express consent, through analysis of your personal data, we can process information on your interests and preferences with respect to our products and services, in order to present you proposals and offers in line with your tastes. If the Foodbrand.it account is authenticated through external social networks, we collect from these third parties the data necessary for registration/authentication through Facebook and through Google. We also collect information concerning you from third parties, in particular from Facebook. This information includes the following categories of data: email address.
• With your consent, we collect information on your browsing of Foodbrand Group websites, such as the pages you visit and how you interact with each page. We save this information on our servers.
• If you provide third party personal data to Foodbrand, for example if you decide to purchase a product for delivery to a friend, or as a gift, Foodbrand will ensure that the third party receives the privacy statement with the first communication. You are reminded that the use of the personal data of third parties is subject to legislation on the protection of personal data.

Please note that Foodbrand does not process personal data concerning minors. If you access Foodbrand.it and use the services offered by Foodbrand, you declare that you are of legal age.

2.6. Cookies

We use cookies on Foodbrand Group websites to ensure the proper technical functioning of web pages and to conduct user traffic analysis. In order to give users the option to withdraw or modify their consent, the table below lists the cookies used on the sites of the Foodbrand Group.

The categories of personal data that Foodbrand S.p.A. collects and processes when browsing or purchasing on Foodbrand are as follows:

2.7.Legal basis for processing

Foodbrand processes personal data on the following legal bases:

• Consent of the data subject for marketing and business development purposes.
• Conclusion of product sales and/or distribution agreements.
• Conclusion of staff recruitment contracts.
• Pursuit of the legitimate interests of the controller to safeguard the security of company assets (e.g. video surveillance, anti-fraud).

2.8.Recipients of data

Personal data collected by Foodbrand may be disclosed to legal entities or natural persons who are designated as external processors in accordance with Article 28 of the European Regulation. The data may be disclosed to the following categories of external processors:

• Companies of the Foodbrand Group;
• Companies that provide processing services in support of Foodbrand.
• External entities responsible for the management of information systems;
• Competent authorities, for the fulfilment of legal obligations, on specific request.

No provision is made for the transfer of personal data outside the EU.

2.9.Retention period of personal data

Data processing may be performed automatically or manually, using methods and tools designed to ensure security and confidentiality.

In compliance with the provisions of Article 5, paragraph 1, letter e) of REGULATION (EU) 2016/679, personal data collected will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

Your personal data is stored according to the terms and criteria specified below:

• data collected to conclude and execute contracts for the purchase of goods on Foodbrand.it: until administrative and accounting formalities have been completed. Billing data will be kept for ten years from the date of invoice;
• Registered User data: the data will be retained until you request the deletion of your Foodbrand account;
• payment data: until payment is certified and the relevant administrative/accounting formalities have been concluded following expiry of the right of withdrawal and the terms applied to dispute payment;
• data collected in the context of use of services offered on Foodbrand.it: this data is stored until the service ceases to be provided or the User cancels registration with the service;
• data on user requests to our offices: data that is used to assist you will be retained until your request is processed;
• CV: for eighteen months from receipt;
• data used for commercial communication activities for users who purchase products on Foodbrand Group websites: this data is kept until the service is terminated or the user exerts his/her right to object by unsubscribing;
• data provided for commercial communications, market surveys and research: until the user’s request to cease such activity and in all cases within 1 year of the user’s last interaction with Foodbrand;
• data used to personalise the website and to show personalised commercial offers: until the user requests cessation and in all cases within 1 year of the user’s last interaction with Foodbrand;
• data used to conduct market research and satisfaction surveys: until the User requests cessation.

In all cases, for technical reasons, the cessation of processing and the consequent definitive deletion or irreversible anonymisation of the relevant personal data will take place within thirty days of the deadlines indicated above.

2.10.  Rights of data subjects

Article 15-22 of the General Data Protection Regulation (“EU Regulation 679/2016”) grants Data Subjects the following powers:

• The right of access: the right to know what personal data is in the possession of the Data Controller and how it is used;
• The right to object to the processing of personal data;
• The right to update inaccurate personal information;
• The right to erasure of data that is no longer necessary, processed unlawfully, for which authorisation for processing has been withdrawn, or to which the data subject has objected;
• The right to restrict the processing of personal data that is inaccurate, processed unlawfully, data which the data controller is no longer authorised to process but which is necessary in legal proceedings;
• The right to portability of personal data.

To exercise the rights listed above, data subjects should contact Foodbrand at Via G. A. Amadeo 59, Email: privacy@foodbrand.com.

2.11.   Right of complaint

Data subjects who believe that Foodbrand has processed their personal data in violation of the provisions of the Regulation have the right to lodge a complaint with the Italian Data Protection Authority. The contact details of the Italian Data Protection Authority are available on the Foodbrand Group website at http://www.garanteprivacy.it/