Pursuant to Article 13 of the Privacy Code (Legislative Decree No. 196/03) and Article 13 of EU Regulation No. 2016/679 (hereinafter, the “GDPR”), we hereby inform you that the company that owns the Pellegrino Srl website, as indicated at the bottom of the website, is the data controller (hereinafter the “Data Controller”) . In accordance with the aforementioned legislation, such processing will be based on the principles of fairness, lawfulness, and transparency, as well as the protection of your privacy and your rights.

1. Purpose of the Processing
The Data Controller processes the personal data—both identifying and non-sensitive (specifically, first name, last name, tax identification number, VAT number, email address, and phone number—hereinafter referred to as “personal data” or simply “data”)—that you provide when registering on the Data Controller’s website and/or when subscribing to the newsletter service offered by the Data Controller.

2. Purposes of the Processing
Your personal data is processed:
A) without your express consent (Art. 24(a), (b), and (c) of the Privacy Code and Art. 6(b) and (e) of the GDPR), for the following Service Purposes:
– allow you to register on the website;
– manage and maintain the website;
– to allow you to subscribe to the newsletter service provided by the Data Controller and any additional services you may request;
– to fulfill pre-contractual, contractual, and tax obligations arising from our existing relationship with you;
– to comply with obligations established by law, regulations, EU legislation, or an order from the Authority;
– to prevent or detect fraudulent activities or abuses that are harmful to the website;
– to exercise the Data Controller’s rights, such as the right to defend itself in court.
B) Only with your specific and separate consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following marketing purposes:
– to send you, via email, newsletters, commercial communications, and/or advertising material regarding products or services offered by the Data Controller
Please note that if you are already a customer of ours, we may send you commercial communications regarding the Data Controller’s services and products similar to those you have already used, unless you object (Article 130(4) of the Privacy Code).

3. Methods of Processing
The processing of your personal data is carried out through the operations indicated in Article 4 of the Privacy Code and Article 4(2) of the GDPR, specifically: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, disclosure, erasure, and destruction of data. Your personal data is processed both in paper form and electronically and/or automatically.
The Data Controller will process personal data for the time necessary to fulfill the purposes set forth above and, in any case, for no longer than 10 years from the termination of the relationship for Service Purposes and for no longer than 2 years from the collection of the data for Marketing Purposes.

4. Access to Data
Your data may be made available for the purposes set forth in Articles 2.A) and 2.B):
– to employees and contractors of the Data Controller, in their capacity as persons in charge of processing and/or internal data processors and/or system administrators;
– to the company of which the Data Controller is a part (for example, for support activities related to the feasibility study of the client’s project, for technical project management, for the storage of personal data, etc.) or to third parties (for example, providers responsible for the management and maintenance of the website, suppliers, financial institutions, professional firms, etc.) that perform outsourced activities on behalf of the Data Controller, in their capacity as external data processors.

5. Disclosure of Data
Without your express consent (pursuant to Art. 24(a), (b), and (d) of the Privacy Code and Art. 6(b) and (c) of the GDPR), the Data Controller may disclose your data for the purposes set forth in Art. 2.A) to supervisory bodies, judicial authorities, and all other parties to whom disclosure is required by law for the fulfillment of said purposes. Your data will not be disclosed.

6. Data Transfer
Personal data will be processed and stored on servers located within the European Union belonging to the Data Controller and/or third-party companies that have been appointed and duly designated as Data Processors. Currently, the servers are located in the Netherlands. It is understood, however, that the Data Controller, should it become necessary, shall have the right to relocate the servers to Italy and/or the European Union and/or countries outside the EU. In such a case, the Data Controller hereby guarantees that the transfer of data outside the EU will take place in accordance with applicable legal provisions by entering into, if necessary, agreements that ensure an adequate level of protection and/or by adopting the standard contractual clauses provided by the European Commission.

7. Nature of Data Provision and Consequences of Refusal to Provide Data
The provision of data for the purposes set forth in Article 2.A) is mandatory. Without such data, we will not be able to guarantee your registration on the site or the Services described in Article 2.A).
Providing data for the purposes set forth in Article 2.B) is, however, optional. You may therefore choose not to provide any data or subsequently withdraw your consent to the processing of data you have already provided: in that case, you will not be able to receive newsletters, commercial communications, or advertising material related to the Services offered by the Data Controller. In any case, you will continue to be entitled to the Services referred to in Article 2.A).

8. Rights of the Data Subject
As a data subject, you have the rights set forth in Article 7 of the Privacy Code and Article 15 of the GDPR, specifically the rights to:
i. obtain confirmation as to whether or not personal data concerning you exist, even if not yet recorded, and to have such data communicated to you in an intelligible form;
ii. to obtain information regarding: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic tools; d) the identifying details of the data controller, data processors, and the designated representative pursuant to Article 5, paragraph 2, of the Privacy Code and Article 3, paragraph 1, of the GDPR; e) the subjects or categories of subjects to whom the personal data may be disclosed or who may become aware of it in their capacity as designated representative within the territory of the State, data processors, or persons in charge of processing;
iii. to obtain: a) the updating, rectification, or, where you have an interest, the supplementation of the data; b) the erasure, anonymization, or blocking of data processed in violation of the law, including data that no longer needs to be retained for the purposes for which it was collected or subsequently processed; c) confirmation that the operations referred to in subparagraphs a) and b) have been brought to the attention—including with regard to their content—of those to whom the data have been disclosed or disseminated, except where this proves impossible or involves an effort manifestly disproportionate to the right being protected;
iv. to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even if such data is relevant to the purpose of collection; b) to the processing of personal data concerning you for the purposes of sending advertising or direct sales material, or for conducting market research or commercial communications, through the use of automated calling systems without operator intervention, via email, and/or through traditional marketing methods such as telephone and/or postal mail. Please note that the data subject’s right to object, as set forth in point b) above, regarding direct marketing via automated means extends to traditional methods as well, and that in any case, the data subject retains the right to exercise this right to object even only in part. Therefore, the data subject may choose to receive only communications via traditional methods, or only automated communications, or neither type of communication.
Where applicable, you also have the rights set forth in Articles 16–21 of the GDPR (right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Data Protection Authority.

9. How to Exercise Your Rights
You may exercise your rights at any time by sending:
– a certified letter to Pellegrino S.r.l., Via Fossombrone 2 – Ravenna 48124;
– an email to [email protected]

10. Minors
This Site and the Data Controller’s Services are not intended for individuals under the age of 18, and the Data Controller does not intentionally collect personal information relating to minors. In the event that information about minors is inadvertently collected, the Data Controller will delete it promptly upon request from users.

11. Data Controller, Data Processors, and Persons Authorized to Process Data
The Data Controller is listed at the bottom of the website.
The updated list of Data Processors and persons authorized to process data is kept at the Data Controller’s headquarters.

12. Changes to This Privacy Policy
This Privacy Policy is subject to change. We therefore recommend that you review this Privacy Policy regularly and refer to the most up-to-date version.