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Subject Matter and Objectives

1.1 Oro Caffè S.r.l. (hereinafter, "Oro Caffè" or "Data Controller") recognizes the importance of the protection and of the correct use of your Personal Data (as defined below in the following Paragraph 3 of this Privacy Policy - hereinafter, the "Privacy Policy"), that you entrusted to Oro Caffè by visiting and consulting the websites and (hereinafter, collectively, the "Websites"), and undertakes constantly to guarantee their full respect.

1.2 This Privacy Policy, therefore, describes activities and means of Personal Data Processing (as defined below in the following Paragraph 2) fulfilled by Oro Caffè as owner of the Websites and as Data Controller, whenever you, as well as any other user and/or visitor, browse the Websites and use the services and features therein (hereinafter, collectively, the "Services").

1.3 This Privacy Policy represents information concerning Personal Data Processing provided by Oro Caffè in compliance with Articles 12 and 13 of the General Data Protection Regulation EU 2016/679 (hereafter, the "GDPR") and, as far as is still in force, with the Legislative Decree n. 196/2003 (hereinafter, the "Privacy Code").

1.4 Oro Caffè invites you to read carefully this Privacy Policy before providing any type of Personal Data, filling in any form or using any features on the Websites, with the express warning that using this website and sending your Data, where a formal consent is not required in accordance to GDPR, determines acceptance of the terms and of the conditions set forth in this Privacy Policy and consent to Data Processing (In any case, in order to better protect the confidentiality of your Data, a specific referral to this Privacy Policy is present in the sections of the Websites set up for particular Services where your Data are requested.)

1.5 This Privacy Policy is not made with reference to other websites, which may be browsed through links carried out by third parties, with respect to which Oro Caffè invites you to refer to the respective information/policies and assumes no responsibility in relation to the contents or procedures adopted by those third parties.

1.6 Specific privacy policies provided by the Controller on or off Oro Caffè sites or through different IT channels from the Websites will remain in place.

Lawfulness and duration of the Processing

2.1 Oro Caffè will process your Personal Data (hereinafter, the "Data Processing") in full compliance with Articles 6, 7 and 8 of the GDPR and, in particular, with the principles of fairness, lawfulness, transparency and protection of confidentiality.

2.2 Your Personal Data will be processed in accordance with Article 4.2 of the GDPR and specifically by: collection, recording, organization, storage, consultation, disclosure by transmission, dissemination, erasure and destruction of your Data.

2.3 Personal Data Processing will take place both manually and by means of electronic devices, computerized, telematic and/or automated instruments, in accordance to the purposes and in compliance with the principles stated within the GDPR. The Data Processing will always be carried out through appropriate technical and organizational measures to guarantee the protection, security and confidentiality of your Personal Data. These measures have been specifically implemented by Oro Caffè to prevent losses or destructions of data, unauthorized accesses, processing that are not allowed or not in accordance with the purposes for which Personal Data were collected.

2.4 Your Personal Data will be stored for a period of time not exceeding the period of time necessary to achieve the Purposes (as defined in Paragraph 4.1 below) for which they have been collected and in full compliance with the provisions of GDPR. In particular, Personal Data processed by Oro Caffè in order to fulfill the accounting obligations and the general rules, relating to the ordinary prescription terms of contractual actions, will be stored for the period required by local regulations in force from time to time.

2.5 Personal Data processed for newsletter and marketing purposes (as defined in Paragraph 4.2 below) will be stored until Oro Caffè shall have received a specific request to change your preferences in relation to Personal Data Processing for the aforementioned Purposes.

Browsing Data and cookies; Data provided voluntarily by the user

3. As you browse on the Websites, Oro Caffè may acquire different types of information (hereafter, collectively, "Personal Data"), such as:
(i) Navigation data and cookies: computer systems and software normally acquire some navigation data, which are implicitly transmitted by using Internet communication protocols. Oro Caffè does not directly track navigation data; however, the identification of the user may occur since navigation data may be processed by third-party cookies present on the Websites. For further information, you can refer to the Cookie Policy by clicking;
(ii) Data voluntarily provided by the interested party by filling in the mandatory fields for the provision of any of the Services: you can choose to use one or more Services available on the Websites. In such cases, before activating or using a specific Service, or forwarding a specific request, you - after having read and understood and, if necessary, provided your consent - have to provide mandatory Personal Data in order to use requested Services. Requested data may differ depending on the specific form used. For instance, Personal Data that may be requested are: name and surname, e-mail address, postal address, telephone number, credit card number, gender, date of birth, preferences on products; and
(iii) Data voluntarily provided by the interested party by filling in non-mandatory fields.

Data Processing Purposes

Your Personal Data will be used for the following purposes (hereinafter, collectively, the "Purposes"):

4.1 Your Personal Data will be used even without your express consent:
(i) to guarantee the correct execution of contractual relationships with you in place, as well as related or connected and/or complementary obligations or services, such as, but not limited to, operational management, i.e. the performance of all functional activities to satisfy your online requests, both in the pre-contractual phase and in the contractual phase, and
(ii) to fulfill the legislative and regulatory obligations to which Oro Caffè is subject.

4.2 Your Personal Data will be used only and exclusively upon your express consent:
(i) for newsletter purposes: i.e. for mailing list subscription and to receive commercial and promotional messages concerning Oro Caffè Services;
(ii) for marketing purposes, i.e. for sending advertising material, direct sales, commercial communication, for carrying out market research, surveys for satisfaction and statistical analysis with aggregate data for commercial purposes. This can be done either through traditional methods, such as sending paper mail, or through automated methods, such as sending e-mails (also of a periodic nature in the form of a Newsletter), messages like MMS (Multimedia Messaging Service) or SMS (Short Message Service) or other; and
(iii) for profiling purposes, i.e. for the identification of preferences, tastes, habits, needs and consumption choices, in order to help Oro Caffè to improve the effectiveness of the activities foreseen by previous points (i) and (ii).

4.3 The consent provided for the aforementioned Purposes in the previous Paragraph 4.2 may be at any time withdrawn and the Processing for those Purposes will stop. The withdrawal of consent shall be communicated to Oro Caffè as set forth in Paragraph 7 below. The withdrawal of consent is presumed to be completed but you may in any event choose to continue using the Services in part.

4.4 Your Personal Data may be crossed with other Personal Data in lawful possession of Oro Caffè (such as those you provided through other IT channels other than the Websites or through paper forms).

Personal Data Granting

5.1 Personal Data, as defined herein in Paragraph 3, point (i), are granted through access to the Websites (hereinafter, “Data Granting”).

5.2 Personal Data Granting for the Purposes foreseen by Paragraph 4.1 above is optional. In the event of non-submission of Personal Data qualified as “mandatory", in accordance with Paragraph 3, point (ii) above, in the specific forms, you will not be able to use the Services of the Websites. The non-submission of Personal Data qualified as “non-mandatory”, as defined in Paragraph 3, point (iii) above, instead, will allow you to use such Services with reduced functionality.

5.3 Personal Data Granting for newsletter and marketing purposes, as set forth in the preceding Paragraph 4.2, points (i) and (ii), is always free and optional but is necessary to ensure you a high performance while using the Services offered from the Websites. The non-submission of those Personal Data will, in fact, prevent Oro Caffè from providing you such Services.

5.4 On the contrary Personal Data granting for the profiling purposes set forth in Paragraph 4.2, point (iii) above, is needed for a better use of the Services foreseen by Paragraph 4.2, points (i) and (ii) above, whereby the withdrawal of consent will not affect the provision of the latter.

Personal Data Disclosure

6.1 Your Personal Data may be processed only by parties that - in accordance with the provisions of GDPR - have appointed as Processor(s) (hereinafter “Data Processor(s)”).

6.2 Your Personal Data may also be disclosed to third parties, acting on behalf of Oro Caffè under specific contractual obligations and, in any case, appointed as entrusted persons (hereinafter, “Data Entrusted”) or External Managers of Data Processing, as well as distributors.

6.3 Personal Data processed by Oro Caffè are stored on servers established in countries that are members of the European Union. Oro Caffè, in case of need, will have the right to move servers in countries that are non UE Members. In such cases, Oro Caffè hereby ensures you that the transfer of Personal Data in non-EU servers will take place in accordance with the applicable legal provisions, and with the standard contractual clauses to be adopted by European Commission.

6.4 Your Personal Data may be disclosed to third parties in compliance with legal obligations or orders from public authorities or in order to enforce a right in court.

6.5 The cases foreseen in the previous Paragraphs are mandatory. Consequently, Personal Data processed by Oro Caffè will not be disclosed but for the cases foreseen by previous Paragraphs.

User’s Right

7.1 Oro Caffè informs you that you have the right to:
(i) obtain confirmation of whether or not a Data Processing concerning your Personal Data is taking place and, if so, to obtain access to Personal Data and to all information provided for in Article 15 of the GDPR, possibly obtaining a copy in a structured format, where it does not prejudice the rights and freedoms of others (rights foreseen by Article 15 of the GDPR);
(ii) obtain the amendment of inaccurate Personal Data without undue delay and to obtain the integration of incomplete Personal Data, also by providing an additional declaration (rights set forth by Article 16 of the GDPR);
(iii) obtain the erasure of your Personal Data without undue delay (right set forth by Article 17 of the GDPR);
(iv) obtain the restriction of Data Processing when any of those cases set forth by Article 18 of the GDPR occurs (right set forth by Article 18 of the GDPR);
(v) request the portability of Personal Data, or to receive, in a structured, commonly used and machine-readable format, your Personal Data provided to Oro Caffè (rights set forth by Article 20 of the GDPR);
(vi) object to the use of your Personal Data in the forms and methods set forth by in Article 21 of the GDPR;
(vii) not (to) be subjected to a decision based solely on Automated Processing, which produces legal effects that affect you or your person. This right does not apply in the cases set forth by Article 22, Paragraph 2 of the GDPR.

7.2 You can send Oro Caffè an email to the privacy address, to the attention of the person in charge as Personal Data Processor in order to enforce the rights mentioned above, as well as to submit any request and/or communication concerning the protection of your right to privacy foreseen by this Privacy Policy.

Data Controller, Data Processor and Data Entruster(s)

8.1 The Data Controller is Oro Caffè S.r.l., represented by the managing director in charge from time to time and with registered office in Via Perugia, n. 6, 33010 Tavagnacco (UD).

8.2 Moreover, the interested party can send an email to Oro Caffè Data Processor attention to the address, in order to know the full list of Data Processor(s) and Data Entruster(s), or to have any further information concerning privacy issue.

Updates and changes

This Privacy Policy is subject to changes and updates, which are communicated via publication on Websites. The version currently in force is the one published on Websites. Please periodically check the Privacy Policy to be properly informed and to be sure to share and accept future eventual changes.


Data Processing shall be governed by additional provisions of the GDPR not mentioned herein and, as still in force, by those of the Privacy Code.

Last update: 03/05/2019