pursuant to art. 13 of EU Regulation 679/2016 (“GDPR” or “Regulation”) and Legislative Decree no. 196/2003, as amended by Legislative Decree no. 101/2018 ("Privacy Code")

 

PREMISE

This disclosure is aimed at natural persons who make a purchase (with or without simultaneous registration) or who browse the Nudo S.r.l. website. ("Website"), even only in consultation ("Data Subjects" or "Users"), activities which presuppose the processing of the personal data of the Data Subjects ("Personal Data").

The processing of Personal Data will be based on principles of correctness, lawfulness, transparency, limitation of purposes and conservation, minimization and accuracy, integrity and confidentiality, in compliance with the provisions of the GDPR.

The interested parties are made aware that the Personal Data will be entered into the system by the interested parties themselves through the use of appropriate forms during registration.

In the following information, the different purposes of the processing and the methods of use and storage of Personal Data will be illustrated.
 

1. DATA PROCESSING OWNER

The owner of the processing of Personal Data is Nudo S.r.l. ("Nudo") (Tax Code16065981009), with registered office in Rome, Via Ugo Bartolomei 18, in the person of its pro tempore legal representative (hereinafter, "Nudo" or "Owner") and can be contacted at email ciao@nudokopiroasters.com

 

2. PERSONAL DATA PROCESSED

Nudo receives, collects and stores all the information that the interested party enters on the Website or provides in any other way. In particular, the Personal Data processed are:

– personal data (such as name, surname, date of birth, age, gender, etc.);

– contact details (email, address, telephone number);

– geo-location data (including “IP” addresses):

– Internet browsing data collected through cookies installed on your computer or mobile device (for more information see the Cookie Policy);

– bank data (including credit card information), necessary for the management of the contractual relationship;

– photographic images and/or video footage, collected on the occasion of participation in promotions, contests, events and installations in general (subject to consent, in the cases provided for by law);

– data directly provided by the User (the so-called "Contributions") and shared on the social network pages dedicated to Nudo (Instagram, Facebook, etc.) ("Social Network"), for the management of which refer to third parties parties that provide such services. Among the data collected through the Social networks there are, for example, likes, comments, images and in general any content and information that may be published by Users on the Social Network pages dedicated to products of the various Nudo brands;

– data relating to the User's interactions with the Website and/or intelligent coffee machines (eg participation in questionnaires, initiatives, contests, promotions, events also through our social channels).
 

3. PURPOSE AND LEGAL BASIS OF THE DIFFERENT PROCESSING ACTIVITIES

The purposes for which the Personal Data are processed by the Data Controller and the legal basis on which the Processing is based are listed below:
 

Purpose Legal basis

Guarantee a series of exclusive services to Users who decide to register via the Website. Execution of pre-contractual measures

Management of orders and payments by Users, execution of the consequent administrative-accounting obligations and sending of any communications relating to the purchases themselves (for example information on the progress of the orders). The provision of Personal Data is necessary to complete the purchase order. Performance of the Contract

 

Management of requests sent via e-mail, Website and/or Social Networks. Execution of pre-contractual / contract measures

Allow booking for participation in events, competitions and prize-winning events. Execution of pre-contractual measures

Use the data of the interested party to provide technical and operational support. Execution of the contract

Guarantee access to the Website and the correct use of the services, protect the security of the recorded data and compliance with the terms and conditions of the service. Execution of the contract

Use the contact details to send communications relating to the Nudo system, to inform Users of new extensions of the services offered by Nudo. Execution of the contract / Legitimate interest of the Owner

Fulfill the tax obligations and the assessments by the judicial authorities in relation to the contractual relationships with the interested parties. Legal obligation

Carry out security checks for the management of the Nudo system and any actions for legal disputes. Legitimate interest of the Owner

Check the correct functioning of the Website and related products and services, as well as keep registrations of members. Legitimate interest of the Owner

Analyze and improve the services offered, evaluate the effectiveness of the activities and initiatives promoted by Nudo and conduct statistical analyzes on the composition of the database itself through the anonymous processing of Personal Data. Legitimate interest of the Owner

Marketing activities (e.g. commercial communications, promotional initiatives, subscription to the newsletter). Consent of the interested party (revoked at any time)
 

4. NATURE OF THE PROVISION

4.1 The provision of Personal Data may be optional or mandatory. In cases where the conferment is mandatory, failure to communicate Personal Data could jeopardize the possibility of using some services (e.g. to place orders and purchases, to participate in competitions and prize operations, etc.).

4.2 The mandatory or optional nature of the provision will be indicated from time to time explicitly or through the use of symbols (e.g. "*") placed alongside the information whose provision is mandatory to pursue the respective purpose.

 

5. METHODS OF TREATMENT

5.1 Personal Data will be processed in compliance with the provisions of the GDPR and the Privacy Code, mainly using IT tools, but also possibly paper ones, with logic strictly related to the purposes of the processing, using databases, electronic platforms managed by Nudo or by third parties (appointed Data Processors), the integrated computer systems of Nudo and of the aforementioned third parties, and/or the Website.

5.2 The Personal Data collected is processed in ways that guarantee adequate security measures to ensure maximum confidentiality and to prevent data loss, illicit or incorrect use and unauthorized access.

5.3 Personal Data is mainly processed at the offices of the Data Controller and in the places where the Data Processors are located.

 

6. RESPONSIBLE FOR TREATMENT AND OTHER RECIPIENTS OF PERSONAL DATA

6.1 Personal Data may be transferred to companies controlled by, or connected to, Nudo and/or to companies linked to it by a contractual relationship, located in the EU or outside it, which will act as data controllers ("Responsible").

6.2 The list of Managers, constantly updated, may be made available to you by contacting the Data Controller at the e-mail address ciao@nudokopiroasters.com

6.3 Personal Data may be made accessible, for the aforementioned purposes, to employees and collaborators of Nudo ("Data Processors"), who are adequately trained in their treatment.

6.4 Finally, Personal Data may be transmitted to the Judicial Authority, where necessary and in the cases provided for by law.
 

7. DATA RETENTION PERIOD

7.1 The Personal Data provided directly by the User are kept for the entire duration of the registration (or, failing that, for the entire duration of the navigation), for the fulfillment of the inherent and consequent obligations, for compliance with legal obligations , contractual and applicable regulations (and, in any case for the fulfillment of the purposes referred to in point 3 of this information) and, in any case, are stored in the Nudo database for a period of time proportional to the purpose of the treatment, after which the data will be canceled or anonymised.

7.2 Without prejudice to defensive needs that may make retention necessary for a further period, such as, by way of example but not limited to, definition of pre-litigation and/or litigation initiated before the expiry of the retention period and compliance with requests from public authorities received/ notify the Owner before the expiry of the retention period.

7.3 The navigation data of Users who access the Website are stored by the hosting provider without the Company having control over storage times.

 

8. DATA OF MINORS

8.1 Nudo does not intend to collect Personal Data from minors, nor intentionally establish communication with them. For this reason, we encourage parents to actively monitor the online activities of their children under the age of 18 (eighteen).

8.2 Nonetheless, in the event that Nudo should process data of a minor under the age of 18, the consent of the parents, of those exercising parental authority or whoever takes their place will be required.
 

9. RIGHTS OF THE INTERESTED PARTY

9.1 Each interested party may at any time exercise the rights provided for by the articles against the Data Controller 15-22 of the GDPR, including:

a) the right to obtain access, rectification, cancellation, limitation of processing and portability of personal data (e.g. personal data);

b) the right to revoke the consent given in relation to the purposes of the processing at any time;

c) the right to oppose the treatment at any time.

9.2 Requests made for the exercise of rights must be sent to the e-mail address of the Data Controller ciao@nudokopiroasters.com

9.3 If you believe that the processing of data concerning you does not comply with the provisions in force or if the response to a request with which you exercise one or more of the rights provided for by articles 15-22 of the GDPR does not arrive within the indicated times or is not satisfactory , the interested party can contact the judicial authority or the Guarantor for the protection of personal data, in the latter case through a complaint pursuant to article art. 77 of the GDPR in the manner described on the Authority's website: https://www.garanteprivacy.it/.

 

Information updated on 21.03.2023