Privacy policy: single integrated registration profile for ILLY LOVERS program and My Machine

Privacy policy pursuant to Regulation (EU) 2016/679 (GDPR) and national legislation in force in Italy (D.Lgs.196/03)

1.    General information
illycaffè S.p.A. (hereinafter also referred to as the "Company" or "illycaffè") hereby informs you that it will process the data you have provided in the form or after filling your form for the purposes listed in the following paragraphs. illycaffè may only require and process data which are instrumental to achieve the aims of this privacy policy.

2.    Purposes and legal basis
illycaffè may process data for the following purposes:

A.    to grant you access to all the services, including interactive ones, of the illycaffè websites described in the Terms and Conditions and in any Purchase Conditions contained in various sections of the website of illycaffè (also belonging to other business group companies) All the services of the illycaffè websites can be accessed with the same credentials. In some cases, you may be required to provide further data that will be processed with your consent where necessary; the services include, among others, Facebook’s “Custom Audiences” feature (for further information please refer to: https://www.facebook.com/help/381385302004628. The processing is based on the following legal basis: consent;

B.    to carry out, only with your consent, advertising communications/information on products-services-initiatives of illycaffè and its partners and market research and/or interviews for the evaluation of product-services of illycaffè, all by illycaffè to the addresses that you provided in the form or other contact details provided later (please note that the sending of SMS/MMS and e-mail will also be in electronically with the help of automated tools); ); the consent will  be possibly requested at further stage also on the registration pages of subsidiaries or affiliates companies . The activities in this point will not be carried out without your consent. The processing is based on the following legal basis: consent;

C.    to be compliant with the requirements pursuant to the legislation in force, regulations or EU regulations and for legitimate interests such as to assert or defend the rights of the Company. The processing is based on the following legal bases: the fulfillment of legal obligations and the pursuit of legitimate interests.

3.    Mandatory nature of the provision
Provision of data for the purposes described in point 2 (A) of this privacy policy is optional and failure to provide them makes impossible to access and enjoy the services of illycaffè websites (including the impossibility of buying in the shop) with the same credentials. The consent for the purposes described in point 2 (A) of this privacy policy is always not mandatory, but the lack of it makes impossible to access and possibly enjoy the services of the illycaffè websites (including the impossibility of buying in the shop) with the same credentials.  Provision of data for the purposes described point 2 (B) of this privacy policy and the relative consent are not mandatory; failure to provide such data and the consent will have not consequences, except that you won’t receive any information (without any consequence on other purposes). Additionally, if you agreed to the data processing for the purposes described in point 2 (B) of this privacy policy, you may cancel you consent at any time and without having to justify your decision (to unsubscribe) by sending a notice to the Data Controller.
Data provision for the purposes described in point 2 (C) of this privacy policy is necessary; should data not be provided, your request may not be fulfilled and relations may be truncated.

4.    Data recipient categories
Data, collected and processed for the purposes described in point 2 (A) of this privacy policy will not be disclosed unless provision is made for special services, submitted to specific conditions and for which your explicit consent will be required where necessary. For the purposes indicated in point 2 (B) of this information, the data will not be disclosed. For the purposes of point 2 (C) of this privacy policy, illycaffè may disclose data to lawyers, solicitors, public authorities, the judiciary, the police, the post office (as the address is visible when sending any written material). illycaffè will only disclose data which are essential for the achievement of each of the aims of the privacy policy. The data may be disclosed on behalf of illycaffè, each for own role, to all subjects delegated by illycaffè (legal staff also external to the Company, marketing staff also external to the Company, staff in charge of the website also external to the Company - such as legal advisors, IT experts that may also perform the role of system administrators, and appointed as such, quality service staff and staff in charge of the administration of the website – IT system staff which may also be system administrators, and which are appointed as such, external relations staff also external to the Company, staff in charge of mailing and enveloping also external to the Company, internal auditors, trainees, staff of internal and external data processors) and to internal and external data processors (such as enveloping and shipping companies, IT outsourcers, marketing companies and more in general consultants performing instrumental activities such as legal and communication advisors). The list of Data Processors is always available by contacting the Data Controller.

5.    Data retention
Data will be retained by illycaffè for the entire period necessary for the pursuit of the purposes contained in this information. The data retention period is as follows:

• for legal obligations, regulations and community regulations, data may be retained for the periods imposed by these regulatory sources;
• for the purposes described in point 2 (A) of this policy, the data can be retained until the withdrawal of consent or request for cancellation;
• for the purposes described in point 2 (B) of this policy, the data can be retained until the withdrawal of consent or request for cancellation without prejudice to the conservation in accordance with the law to prove the consent previously given;

in any case, all data may be retained for a period necessary to assert or defend a company right according to Italian and European regulations.
 

6.    Data Controller and Data Protection Officer
The Data Controller is illycaffè S.p.A., having its registered office in via Flavia 110, Trieste, phone number +39.040.3890.111, fax number +39.040.3890.490, e-mail: infoprivacy@illy.com. There is also a Data Protection Officer available at the email address dpo@illy.com and at the addresses of the Company.

7.    Rights
We inform you that the GDPR provides the possibility for the data subject to ask the Data Controller (at the above addresses) to access personal data and to correct or cancel them or limit their processing or to oppose their processing, in addition to exercising the right to data, as well as other rights contained in Chapter 3 of the GDPR including the revocation of consent, where provided: the withdrawal of consent does not affect the lawfulness of the processing based on consent given before revocation.

8.    Complaints
The data subject can always lodge a complaint with the Italian Data Protection Authority, whose references can be found on the website www.garanteprivacy.it.

9.    Processing procedures
Data may be processed on paper, manually, with IT and electronic means (therefore, illycaffè may file data both on paper and IT support). illycaffè has implemented safety measures to prevent any data loss, illegal use of data, misuse or unauthorised access. Data will be retained and processed by illycaffè in compliance with its confidentiality requirements and with the applicable local provisions (i.e. in compliance with the principles of fairness, lawfulness, transparency, and protection of the confidentiality and the rights of those concerned) strictly in line with the aims set forth in this privacy policy. Data will be processed by illycaffè exclusively to achieve the aims described in this privacy policy. Data will be filed at illycaffè S.p.A. offices in Europe and at the appointed data processors (as well as third parties who receive data as independent data controllers as described in point 4 of this privacy policy). Data will be entered in databases, including IT databases.
We remind you that only for technical assistance needs data may be sent to companies outside the European community who are specifically designated as data processors by committing to comply with all the requirements of European legislation, also by signing the appropriate Contractual Clauses indicated by the Data Protection Authority; the data are only a copy of those contained in the European servers and the copy of the same is always available at illycaffè S.p.A..

N.B. The consent can only be given by persons over 14 years, if the subject is under 14, he cannot use what is provided for in the purposes for which consent is required (e.g. receiving commercial communication, targeting., ...).

This privacy policy is updated as at 04/24/2020.