Privacy Policy

Information on the processing of personal data pursuant to articles 13-14 of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1. Premise.
This document contains information on the processing of data collected from the website www.primeur.com (hereinafter also referred to as the “Website”).
Specific information regarding cookies is also reported hereinafter (the so-called Cookie Policy).
We hereby represent that this information is provided by Primeur Italy Srl only in relation to the Website and not to any other third-party internet websites which may be consulted by the Website user through any link therein contained.

2. Purpose of this document.
The purpose of this document is to provide users of the Website with the following information regarding the processing of data collected from the Website:

– what does processing mean;
– who is the data controller;
– which data are processed;
– which are the purposes and methods of processing;
– which is the timing of the data retention;
– which are the legal basis of processing;
– which is the nature (compulsory or optional) of the processing;
– who are the subjects and the categories of subjects to which the data could be communicated by Primeur and the scope of dissemination of such data;
– which are the rights of the Website user, in its quality of data subject;
– if the treatment involves automated decision-making processes (such as profiling);
– which kind of cookies are conveyed by the Website;
– which are the hyperlinks to the privacy policies of third parties;
– which are the methods available for disabling cookies.

3. Processing of data – definition.

Pursuant to art. 4 of the GDPR, the term “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Controller.

Data controller of the data collected from the Website is PRIMEUR ITALY SRL, with registered office in Via Uberto Visconti di Modrone 11 – 20122 Milano (MI) – ITALY – CF and VAT no. 07615530966 (hereinafter lso referred to as “Primeur”), in the person of its legal representative. The e-mail address for contacting Primeur for the protection of personal data is: privacy@primeur.com .
Processors: pursuant to art. 4 GDPR, Primeur may appoint third parties as data processors, whether they process personal data on behalf of the controller.

5. Data processed.

If the Website user wish to interact with Primeur in order to send specific requests or download documents available for consultation, the following data will be requested and collected: Name and / or Surname, professional e-mail address, country, telephone number, company.This data will be collected by Primeur through the MailChimp® service provided by The Rocket Science Group LLC, based in 675 Ponce de Leon, Avenue NE, Suite 5000, Atlanta, Georgia 30308 (USA), third part supplier of Primeur.

Sending an e-mail to the addresses shown on this Website entails the subsequent  acquisition of the sender’s e-mail address, necessary to answer to requests, as well as any other personal data included in the message. Furthermore, the computer systems and software procedures applied to operate the Website automatically acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected to be associated with identified interested parties, but which, by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of technical data includes IP addresses or domain names of the computers used by users who connect to the Website, the type of browser, information on the terminal from which you connect to the Website, data on the position (approximate) of the terminal that is used, addresses in URL notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters related to the operating system and the user’s computer environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning and are deleted immediately after processing. The Website collects Cookies as well (technical, analytical and advertising in social networks), referred to below in this statement (within the so-called Cookie Policy).

6. Purposes and methods of processing.

Primeur collects and processes the data of the Website users for the following purposes:
a) sending messages for marketing purposes, as well as in order to respond to requests sent to Primeur by means of the contact form on the Website;
b) profilation by third parties, according to the origin (language and country) of the users and subsequent delivery of customised advertisement, in line with their own tastes and preferences. This profiling is part of the so-called automated decisions, for which the user can refuse or revoke his consent, with the methods that will be described below (within
the so-called Cookie Policy).
c) possible transmission of data to public authorities, if required under current legislation.

7. Processing time – data retention.

Personal data collected by Primeur through the Website will be stored on paper and / or electronic / IT format and for the time strictly necessary to satisfy the aforementioned purposes, in compliance with current regulations.For direct marketing and profiling purposes, Primeur shall keep users’ data for a maximum period of 24 months.

In case of express request by the user to delete personal data processed by the controller (exercise of the so-called right to be forgotten), such data will be stored, in a protected form and with restricted access, solely for purposes of investigation and prosecution of offenses, for a period not exceeding 12 months from the date of the request and subsequently will be erased securely or anonymised irreversibly.

8. Basis of the processing.

Pursuant to art. 6 of the GDPR, processing is to be considered lawful only if and to the extent that at least one of the following legal basis applies: consent, performance of a contract, fulfillment of a legal obligation, pursuit of a legitimate interest of the controller or of a third party, protection of the vital interests of the data subject or of another natural person, performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The processing of personal data provided by users of the Website is made by virtue of the following legal basis:
a) The user’s consent, provided in relation to the following data:

  • Name and / or Surname, professional e-mail address, country, telephone number,
    company (such consent is mandatory for sending requests to Primeur) .
  • non-technical cookies. This consent is not compulsory (and may therefore be rejected in the manner indicated below), as the processing is aimed at profiling and marketing purposes.

b) The fulfilment of any legal obligation applicable to Primeur, for the purpose of transmitting data to public bodies and authorities, should they be required in compliance with the regulations in force.

9. Recipients of the collected data.

Personal data collected by the Website may be accessed by other subsidiaries of the Primeur Group, in addition to suppliers providing hosting services, direct marketing services, advertising services, development of web application at Primeur, detailed below:
a) Ovh S.r.l., con sede in Via Leopoldo Cicognara, 7 – 20129, Milano – C.F. e Partita IVA 06157670966 – Registro Imprese di Milano n° 06157670966 – REA n° 1873458.
b) The Rocket Science Group LLC (Mailchimp®), con sede in 675 Ponce de Leon, Avenue NE, Suite 5000, Atlanta, Georgia 30308 – Stati Uniti;
c) Survey Monkey Inc, con sede in 101 Lytton Avenue, Palo Alto, CA 94301 – Stati Uniti
d) Google LLC, con sede a 1600 Amphitheatre Parkway, Mountain View, CA 94043 – StatiUniti
e) Linkedin Ireland, con sede in 70 Sir John Rogerson’s Quay – Dublin 2 – Irlanda.
f) Facebook Ireland Ltd., con sede in 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.
g) Microsoft S.R.L., con sede in Viale Pasubio 21, 20154 MILANO, C.F. 08106710158.
h) Twitter International Company, con sede in 42 Pearse St, dublin 2 Dublin, IRELAND.
i) S.C. SKILLATI SOFTWARE Srl, con sede a Com Valeni, via Ioan Stircea, numero 17, prov Neamt (Romania), registrata all’Ufficio del Registro del Commercio J 27-167, C.F./P.IVA RO-32939264.
j) Atos Italia S.p.A., con sede in Caldera Business Park, Via Caldera, 21/C/1, 20153 Milano.
k) PERFORMEDIA S.R.L. con socio unico, con sede legale in Milano, Viale Vittorio Veneto n. 22, Partita IVA 13004860154, Numero di REA MI – 1607024

All the intellectual property rights of third parties relating to logos, names, company names and names of products listed above and elsewhere in this statement are reserved.

In accordance with the GDPR, Primeur provides for the appointment of its suppliers as data processors, if they process personal data collected through the Website, with the aim of guarantee adequate protection of the users and of the rights connected to them.

Personal data collected may be transferred outside the European Union to be processed by third parties providing services to Primeur. In such case, Primeur would ensure that this transfer takes place in compliance with current legislation and that an adequate level of protection of personal data is guaranteed, basing on the mechanisms envisaged for this purpose by the GDPR (such as adequacy decision adopted by the EU Commission, EU standard contractual clauses adopted by the Commission or by the competent supervisory authority, or Binding Corporate Rules).

Personal data collected may be reported to competent authorities, if and when required by law.

10. Rights of the data subject.

Any user of the Website is entitled to:
a) obtain from the controller, at any time, information about the existence of its personal
data, the origin of the same, the purposes and methods of processing and, if existing, to obtain access to personal data and information referred to in Article 15 of the GDPR;
b) request the updating, rectification, integration, deletion, limitation of data processing if
one of the conditions provided for in Article 18 of the GDPR occurs, the transformation into anonymous form or blocking of personal data, processed in violation by law, including those that do not need to be kept for the purposes for which the data were collected and / or subsequently processed;
c) oppose, in whole or in part, for legitimate reasons, to the processing of data, even if appropriate to the purpose of collection and processing of personal data provided for commercial information purposes or sending advertising material or direct selling or for the fulfilment of market research or commercial communication. Each user also has the right to revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation;
d) receive its personal data, previously provided knowingly and actively or through the use of the service, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without impediments;
e) propose a complaint to the relevant Authority for the protection of personal data
(http://www.garanteprivacy.it/ ).

In case of request for elimination, limitation or opposition to the treatment, Primeur may keep some personal data within the limits of the current legislation and for the intended purposes (for example to exercise the contractual rights provided for or the right to defence).

For the purposes of exercising the above rights, a natural person who is a user of the Website may ask Primeur, via the contact details below, providing the information necessary to fulfil its own request:

  • by e-mail, at the address: privacy@primeur.com
  • by mail, at the following address:
    Primeur Italy S.r.l.
    Via Imperia 21/A
    20142 MILANO
    ITALY

11. Cookie policy. 

Cookie

Cookies are data files that are sent from the Website to the internet browser of the user and are stored by this, only to be passed to the Website the next visit. They can be used for different purposes, for example to monitor sessions, to authenticate a user so that he can access the Website without typing name and password each time, to memorize preferences, to store information on specific configurations concerning the users accessing the server, etc.
There are many categories of cookies, classified in various ways: for technical aspects, duration, origin, purpose, etc. The very purpose of the cookie is of the greatest importance. In this regard, we represent that the Website sends technical cookies, advertising cookies, analytics cookies, media management cookies, navigation cookies, cookies of performance / networking, social network cookies, survey cookies and profiling cookies.

 

Technical cookies
They are necessary for the transmission of electronic communications network or for delivering the service requested by the user and are used for navigation and to facilitate access to and use of the Website by the user.
The use of technical cookies allows the safe and efficient use of the Website. Without the use of these cookies, some operations could not be completed or would be more complex and / or less secure. They are therefore not used for other purposes and are installed directly by the owner of the Website. Technical cookies have a minimum degree of invasiveness, and for this reason they are exempt from consent.

Third-party cookies
In relation to the origin, it is possible to classify cookies sent to the browser directly from the Website, from those of third parties sent to the computer from other websites. Browsing on the Website will be installed third-party cookies, both analytical and profiling, as detailed below. They are sent from the domains of the aforementioned third parties, external to the Website.

  • third-party analytical cookies are used to detect information on the behaviour of users of the Website. The examination takes place in order to monitor performance and improve the usability of the Website.
  • third-party profiling cookies are used to create profiles related to users, in order to propose advertising messages in line with the choices expressed by the users themselves.

The use of these cookies is governed by the rules set by the third parties themselves, therefore, Primeur invites Website users to read the privacy policies and instructions to manage or disable individual cookies, published on their respective web pages, as detailed below.

The Website uses the following cookies and third-party services:

Supplier Privacy Policy and Consent Form How to disable
Google Analytics (Google Inc.) https://www.google.com/intl/it
_ALL/analytics/learn/privacy.htm
l
https://support.google.com/anal
ytics/answer/181881?hl=it
GOOGLE TAG MANAGER (GOOGLE
INC.)
https://www.google.com/intl/p
olicies/policies/privacy/
https://www.google.com/intl/p
olicies/policies/privacy/
AppNexus https://www.appnexus.com/en/
company/platform-privacypolicy
https://www.appnexus.com/en/
company/platform-privacypolicy#
choices
Adform https://site.adform.com/privacycenter/
platform-privacy/
https://site.adform.com/privacycenter/
platform-privacy/optout/
Google Adwords (Google Inc.) http://www.google.it/intl/it/pol
icies/technologies/ads/
https://policies.google.com/tech
nologies/cookies?hl=it
Sizmek https://www.sizmek.com/privac
y-policy/
https://www.sizmek.com/privac
y-policy/optedin/
Google DoubleClick https://support.google.com/bid
manager/answer/2839090?hl=it
https://adssettings.google.com/
authenticated
Google AdSense https://www.google.com/adsen
se/start/
https://policies.google.com/priv
acy?hl=en
Google Conversion Tracking https://support.google.com/adw
ords/answer/1722054?hl=en
https://policies.google.com/priv
acy?hl=en
Microsoft BING https://privacy.microsoft.com/itit/
privacystatement
https://privacy.microsoft.com/itit/
privacystatement
Facebook Social Plugins (Facebook
Inc)
https://www.facebook.com/full
_data_use_policy
https://www.facebook.com/poli
cies/cookies/
Google+ (Google Inc.) https://policies.google.com/priv
acy?hl=it
https://policies.google.com/priv
acy?hl=it
Twitter https://twitter.com/privacy https://help.twitter.com/it/rulesand-
policies/twitter-cookies
Linkedin https://www.linkedin.com/legal
/cookie-policy
https://www.linkedin.com/legal
/cookie-policy

Consent to the installation of cookies.
The installation of cookies (excepted for technical ones) is up to the will of the user, who may decide to continue browsing the Website after reading the disclaimer contained in the
appropriate banners. The user can therefore avoid the installation of non-technical (or
assimilated) cookies by keeping the banner (refraining from closing it by selecting the “OK” button), as well as through the special functions available on its browser. Alternatively, browsing may be interrupted.

Registration of consent for the storage of cookies
To keep track of the consent to the installation of cookies, that may be issued by the user of the Website, Primeur uses a special technical cookie, a system that is not particularly invasive and that does not require further consent.

How to disable cookies.

Users can adjust the settings of their browser or use special programs developed for the management of cookies. The browser settings usually show a list of all stored cookies, in order to offer a general view and, if necessary, to delete unwanted cookies. Generally, it is possible to accept to save cookies from visited websites or from those third parties affiliated to the aforementioned websites and is it also possible to choose to receive an alert every time a new cookie is stored.

Browsers normally saves cookies in a specific hard disk folder, so that they can also be examined in more detail. Please keep in mind that disabling cookies may result in the Website not working properly or otherwise to the best of its possibilities (e.g. users may need to start a new session on each new visit).

For information purposes only, the following is an indication of how to set options for some browsers currently available on the market. Please keep in mind that these procedures may change at any time and that the descriptions provided may not be updated, as this information is beyond the control of Primeur. All trademarks mentioned are to be considered the exclusive property of their respective owners.

a) Management of cookies in Google Chrome

How to delete cookies:

  • Go to Preferences – Settings in the browser menu.
  • Click on Show advanced settings.
  • Click on Clear browsing data.
  • Select the amount of time you want to delete information from using the drop-down
    menu at the top. If you want to delete all cookies on your browser, select All.
  • Select Cookies and other website and plug-in data.
  • Click on Clear browsing data.
  • Close the window.

How to prevent cookies from being stored in the browser:

  •   Go to Preferences – Settings in the browser menu
  • Click on Show advanced settings and then click on Content settings.
  • In Cookies, select the option you prefer. If you want to prevent all cookies from being archived, click on Prevent websites to set data.
  • Click on Finish.
  • Close the window.

b) Management of cookies in Safari

How to delete cookies:

  • Choose Preferences from the browser menu.
  • Select the Privacy tab.
  • Click Remove all website data and then click Remove now to delete all cookies.
  • Close the window.

How to prevent cookies from being stored in the browser:

  • Choose Preferences from the browser menu.
  • Select the Privacy tab.
  • In Cookies and website data select the option you prefer. If you want to prevent all
    cookies from being archived, click on Always block.
  • Close the window.

c)Management of cookies in Firefox

How to delete cookies:

  • Choose Preferences from the browser menu.
  •  Select the Privacy tab.
  • In History Settings, click Use custom settings.
  • Click on Show Cookies.
  • Select the cookies you want to delete and click Remove selected. Click on Remove all
    cookies if you wish to delete all cookies from the browser.
  • Close the window. Any changes you have made will be saved automatically.

How to prevent cookies from being stored in the browser:

  • Choose Preferences from the browser menu.
  • Select the Privacy tab.
  • In History Settings, click Use custom settings
  • Select the options you prefer in Allow cookies from websites. If you want to prevent
    all cookies from being archived, disable the Accept cookies from websites check box.
  • Close the window. Any changes you have made will be saved automatically.

d) Management of cookies in Internet Explorer

How to delete cookies:

  • Go to Tools (gear wheel icon) in the browser menu.
  • Click on Internet Properties.
  • In the General tab – Browsing history, click on Delete.
  • Be sure to check the Cookies and website data box.
  • Click on Delete.
  • Click on OK.

How to prevent cookies from being stored in the browser:

  • Go to Tools (gear wheel icon) in the browser menu.
  • Click on Internet Options and then click on the Privacy tab.
  • Move the scroll bar to the desired level. If you want to prevent all cookies from being
    archived, select the Block all cookies level.
  • Click on OK.

e) Cookie management in Opera

How to delete cookies:

  • Go to Preferences in the browser menu.
  • Select the Privacy and Security tab.
  • Click on Cookies and then click on All cookies and website data.
  • Select the cookies you want to delete and click on Delete. Click on Delete all if youse want to delete all cookies from your browser.
  • Click on Done.
  • Close the window.

How to prevent cookies from being stored in the browser:

  • Go to Preferences in the browser menu.
  • Select the Privacy and Security tab.
  • In Cookies, select the option you prefer. If you want to prevent all cookies from being stored click on Do not allow website data to be saved.
  • Close the window.

12. Security of data provided.

The security and confidentiality of data collected through the Website is assured by Primeur pursuant to art. 32 of the GDPR, by means of the procedures and of the technical and organizational measures taken.

13. Changes to this document.

This document, published at the URL www.primeur.com/privacy constitutes the privacy policy of the Primeur Group. It may be subject to changes or updates. In case of significant changes and updates, these may be notified with appropriate notifications to users.

This privacy policy was updated on May 25th, 2018 to comply with the relevant regulatory
provisions. It has been translated from the Italian version, please refer to Italian version for any doubt.