Privacy notice

Preamble

 

We, the Il Salotto SRL (hereinafter referred to as "the company", "we" or "us"), take the protection of your personal data very seriously. On this page, we want to let you know about the efforts that our company has undertaken to protect it.

The passage of the General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter referred to as "GDPR") has added additional obligations to our data protection responsibilities in order to guarantee that the personal data of a person whose data is being processed (as the data subject, we will hereinafter also refer to you as "customer", "user", "you", or "data subject") securely.

If we have to make decisions regarding data processing purposes and tools, either alone or together with third parties, they primarily encompass the obligation to transparently notify you of the type, scope, purpose, duration and legal basis of the processing (ct. Art. 13 and 14 GDPR). With this declaration (hereinafter referred to as "privacy notice") we notify you of how we process your personal data.

Our privacy notice has a modular structure. It consists of a general part that covers any processing of personal data as well as processing situations that arise whenever a website is visited (a. General information), and a special section, whose content only refers to specified processing situations complete with the designation of the respective offer or product, and in particular the more detailed description of what happens when you visit websites (b. Visit of websites).

 

A. General information

 

 1. Definitions of terms

Based on Article 4 of GDPR, this privacy notice uses the following definitions:

  1. "Personal data" (Art. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The identifiability can also occur when this type of information is connected or through supplementary knowledge. The origin, type or embodiment of the information is not relevant (photos, video or audio recordings may also contain personal information).
  2. "Processing" (Art. 4 No. 2 GDPR) 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 (i.e. process supported by technology). In particular, this includes the collection (i.e. the procurement), 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 of personal data, as well as changing the target or purpose on which the processing of the data was originally based.
  3. "Controller" (Art. 4 No. 7 GDPR) means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  4. "Third party" (Art. 4 No. 10 GDPR) means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data. This includes other legal persons that are affiliated with the company.
  5. "Processor" (Art. 4 No. 8 GDPR) means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, especially pursuant to their instructions (e.g. IT service provider). In a legal sense related to data protection, a processor is not considered a third party.
  6. "Consent" (Art. 4 No. 11 GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

2. Name and address or the controller responsible for processing

In terms of Art. 4, No. 7 GDPR, we are the responsible body for processing your personal data:

Il Salotto SRL, Principal Office

Hohenstrasse 17, 78183 Hüfingen, Germany

Tel: +49 771 158979-150

info@ilsalotto.info

You can find additional information on our company in the information contained in the imprint of this website https://www.ilsalotto.info/en/imprint.

 

3. Contact information of the data protection officer

For any questions related to data protection and as a point of contact on the issue, our data protection officer is always available to you.  His contact information is:

Il Salotto SRL, Principal Office
Data protection officer: Thomas Schröter
Hohenstrasse 17, 78183 Hüfingen, Germany
Tel: +49 771 158979-150
info@ilsalotto.info

 

4. Legal basis for the processing of data

By law, any processing of personal data is principally prohibited. It is only allowed when the processing of data falls into one of the following justification categories:

  1. 6 (1) clause 1 point (a) GDPR ("Consent"): When the data subject has voluntarily, based on sound information and unambiguously indicated, either through a declaration or another affirming action, that they consent to the processing of the respective personal data for one or multiple defined purposes.
  2. 6 (1) clause 1 point (b) GDPR: When processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
  3. 6 (1) clause 1 point (c) GDPR: When processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a statutory retention obligation);
  4. 6 (1) clause 1 point (d) GDPR: When processing is necessary in order to protect the vital interests of the data subject or of another natural person;
  5. 6 (1) clause 1 point (e) GDPR: When processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or
  6. 6 (1) clause 1 point (f) GDPR ("Legitimate interests"): When processing is necessary for the purposes of the legitimate (in particular legal and economic) interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

We will always provide the applicable legal basis for the processing operations we perform. A processing operation can also have multiple legal bases.

 

5. Data erasure and storage period

For the processing operations we perform, we will always provide information on how long we will store the data and when the data will be erased or blocked. If we do not expressly specify a storage period, then your personal data will be erased or blocked as soon as the purpose or the legal basis for the storage of the data lapses.  We will generally only store your data in our servers in Germany, subject to a possible transfer pursuant to the provisions from A(7) and A(8).

However, the data may be stored beyond the specified time in case of a (looming) legal dispute involving you or another legal process or when the storage of the data is subject to other legal provisions that we are subject to as controller (e.g.  257 HGB, § 147 AO). When the legally mandated retention period lapses, the personal data will be blocked or erased unless the continued retention is required and there is a legal basis for it.

 

6. Data security

We are using suitable technical and organisational security measures to protect your data from accidental or deliberate manipulation, partial or complete loss, destruction or unauthorised third-party access (e.g. TLS encryption of our website). These measures take into account the state of technology, implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its likelihood and consequences) for the data subject. We are continuously improving our security measures in accordance with technological developments.

Upon request, we will gladly provide you with additional information on this subject. Please contact our data protection officer (see A.(3)).

 

7. Working with processors

Like all large companies, we are also using external service providers, both domestic and international, to conduct our business (e.g. in the areas of IT, logistics, telecommunications, sales and marketing).  These will only act in accordance with our instructions and are contractually obligated, pursuant to Art. 28 GDPR, to comply with legal provisions related to data protection.

If your personal data is transmitted from us to our subsidiaries or from our subsidiaries to us (e.g. for commercial purposes), then this is done based on existing job processing relationships.

 

 8. Requirements for the transmission of personal data to third countries

As part of our business relationships, your personal data may be transmitted or disclosed to third companies. These may be located outside of the European Economic Area (EEA), i.e. in third countries.  This type of processing will solely be done to fulfil contractual and business obligations and to maintain your business relationship with us. We will inform you of the respective details of such a transmission below in the relevant sections.

With so-called adequacy decisions, the European Commission has certified that certain third countries have a level of data protection that is comparable to the EEA standard (you can find a list of the countries and a copy of adequacy decisions here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html). However, in other third countries to which personal data may be transmitted, there may not be a consistently high level of data protection as a result of lacking legal provisions. If that is the case, we will ensure that the level of data protection is sufficient. This can be achieved through binding company rules, standard contractual terms of the European Commission for the protection of personal data, certificates, recognised codes of conduct or a self-certification via the EU-US-Privacy Shield (you can find information on it here: https://www.privacyshield.gov/welcome). Please contact our data protection officer (see A (3)), for additional information on this subject.

 

9. No automated decision-making (including profiling)

We do not intend to use the personal data collected from you for a process of automated decision-making (including profiling).

 

10. No obligation for the provision of personal data

We will not make the conclusion of contracts contingent on whether you have provided your personal data to us. For you as a customer, there is generally no legal or contractual obligation to provide your personal data. However, it may be possible that we will be unable or only somewhat able to provide certain services to you if you do not make the required personal information available to us. If that is the case for one of the products that we offer and that are described in detail elsewhere, then we will separately point this out to you.

 

11. Legal obligation for the transmission of certain data

In certain circumstances, we may be subject to special statutory or legal obligations to make legally processed personal data available to third parties, especially public authorities (Art. 6 (1) clause 1 point (c) GDPR).

 

12. Your rights

At any time, you can assert your rights as a data subject with regard to your processed personal data by using the contact data specified in A. (2). As a data subject you have the following rights:

  1. In accordance with Art. 15 GDPR, you have the right to access your personal data that we have processed. You have the right to be informed about the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed, the envisaged period for which the personal data will be stored, the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing, the right to lodge a complaint with a supervisory authority, the origin of the data if we did not collect them, and the existence of automated decision-making, including profiling, and possibly, meaningful information about their specifics;
  2. In accordance with Art. 16 GDPR, you have the right to immediately demand the rectification of inaccurate personal data that we have stored or the completion of such data;
  3. In accordance with Art. 17 GDPR, you have the right to demand the erasure of your personal data as long as the processing is not required for exercising the right of freedom of expression and information; for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims.
  4. In accordance with Art. 18 GDPR, you have the right to demand the restriction of the processing of your data if you contest the accuracy of the data or if its processing is unlawful;
  5. In accordance with Art. 20 GDPR, you have the right to receive the personal data you made available to us in a structured, commonly used and machine-readable format or to demand the transmission to another controller ("data portability");
  6. In accordance with Art. 21 GDPR, you have the right to object to the processing of your data if it is being processed in accordance with Art. 6 (1) clause 1 point (e) or (f) GDPR. This is especially the case if the processing is not required for fulfilling a contract with you. Unless it is an objection to direct marketing, we kindly ask that, when you exercise your right to object, you provide the reasons for why you do not want us to process your data in this manner. If it is a justified objection, we will examine the situation and will either stop the data processing, adapt it or will demonstrate legitimate grounds that compel us to continue the processing;
  7. In accordance with Art. 7 (3) GDPR, your consent (also before the validity of GDPR, i.e. before 25/05/2018), i.e. your voluntary, based on sound information and unambiguously indicated consent – through a declaration or another affirming action – that you agree to the processing of the respective personal data for one or multiple defined purposes, can be revoked at any time (this also applies even if you gave your consent prior to the enactment of GDPR). The result is that the we can no longer engage in the type of data processing that was based on this consent and,
  8. in accordance with Art. 77 GDPR, you have the right to lodge a complaint regarding our processing of your personal data, e.g. with the responsible data protection supervisory authority: [Responsible data protection supervisory authority], [address], e-mail: [e-mail address].

 

13. Changes to the privacy notice

As data protection laws evolve, and in light of technological and organisational changes, we will periodically examine our privacy notice to determine whether we need to amend it or add to it. We will notify you about changes, in particular on our German website at [website address of the company]. This privacy notice was last updated on [month and year of the publication of the privacy notice].

 

B. Visiting websites

 

1. Explanation of the function

In particular, you can find information on our company and the services we offer at  [address of the company website] and all associated sub-pages (hereinafter jointly referred to as  "websites"). When you visit the websites, your personal data may be processed.

 

2. Processed personal data

When you are using our websites for informational purposes, then we will collect, save and process the following categories of personal data:

  1. "Log data": When you visit our websites, a temporary and anonymised log record (so-called server logfiles) will be saved on our servers. It consists of:
    1. The page from which our website was requested (the so-called referrer URL)
    2. The name and URL of the requested page
    3. The time and date when the page was accessed
    4. The type, language and version of the web browser that was used
    5. The IP address of the requesting computer, which is shortened so that it is no longer possible to assign it to a person
    6. The amount of transmitted data
    7. The operating system
    8. The notification of whether the page was accessed successfully (access status(http status code)
    9. The time zone difference to GMT
  2. "Contact form data": When using contact forms, the provided data will be processed (e.g. gender, last name and first name, address, company, e-mail address and the time of the transmission).

In addition to using our website for purely informational purposes, we also offer a subscription to our newsletter, in which we will notify you of current developments in business law and events. If you subscribe to our newsletter, then we will collect, store and process the following "newsletter data":

  1. The page from which our website was requested (the so-called referrer URL)
  2. The time and date when the page was accessed
  3. The description of the type of web browser used
  4. The IP address of the requesting computer, which is shortened so that it is no longer possible to assign it to a person
  5. The e-mail address
  6. The time and date of the registration and the confirmation

We note that we will analyse your user behaviour when we send you the newsletter. For the purposes of this analysis, the e-mails we send will contain so-called web beacons or tracking pixels, which are single-pixel image files that are saved on our website. For our analysis, we will link the aforementioned data and the web beacons with your e-mail address and an individual ID. Links included in the newsletter also contain this ID The data is solely collected in an anonymised manner, i.e. the IDs will not be linked to your other personal data and it is impossible to use this information to identify a specific person.

 

3. Purpose and legal basis for the processing of data

We only process the personal data, which we identified in greater detail above, in accordance with the provisions of GDPR, other relevant data protection regulations and only to the extent necessary. If the processing of the personal data is based on Art. 6 (1) clause 1 point (f) GDPR, then the stated purpose also constitutes our legitimate interests.

The processing of log data serves statistical purposes and the improvement of the quality of our website, especially its stability and the security of the connection (the legal basis is Art. 6 (1) clause 1 point (f) GDPR).

The processing of contact form data is used for processing customer inquiries (the legal basis is Art. 6 (1) clause 1 point (b) or (f) GDPR).

The processing of newsletter data serves the purpose of sending out the newsletter. As part of your newsletter registration, you agree to the processing of your personal data (the legal basis is Art. 6 (1) point (a) GDPR). We are using the so-called "double-opt-in process" for our newsletter registration. This means that, after you register, we will send an e-mail to the e-mail address you provided. In this e-mail, we ask you to confirm that you want to receive the newsletter. The purpose of this process is to verify your registration and to determine a possible misuse of your personal data. You can revoke your consent for receiving the newsletter at any time and unsubscribe.  You can revoke your consent by clicking on the link included in each e-mail containing the newsletter by sending an e-mail to info@ilsalotto.info or by sending a message to the contact information provided in the imprint.

 

4. Duration of the data processing

Your data will only be processed for as long as it takes to achieve the aforementioned processing purposes; the legal bases provided for the respective processing purposes apply. With regard to the use and storage period of cookies, please note point A.(5) as well as the cookie guideline.

Third-parties working with us will store the data on their systems for as long as it is required in the context of the services they are tasked with providing for us for the respective assignment.

You will find additional information under A.(5) and the cookie guideline.

 

5. Transmission of personal data to third parties; basis of justification

The following categories of recipients, which are generally processors (see also A.(7)), may be granted access to your personal data:

  1. Service providers tasked with operating our website and processing the data stored or transmitted by the system (e.g. for data processing centre services, payment processing, IT security). The legal basis for this type of transmission in this case is Art. 6 (1) clause 1 point (b) or (f) GDPR unless it is a processor;
  2. Government agencies, if required for meeting legal obligations. The legal basis for this type of transmission in this case is Art. 6 (1) clause 1 point (c) GDPR;
  3. Persons tasked with conducting our business operations (e.g. auditors, banks, insurance companies, legal advisers, supervisory authorities, stakeholders involved in acquiring companies or founding joint ventures). The legal basis for this type of transmission in this case is Art. 6 (1) clause 1 point (b) or (f) GDPR;

To ensure an appropriate level of data protection when transmitting data to third countries, see A.(8).

Furthermore, we will only transmit your personal data to third parties if you have expressly consented in accordance with Art. 6 (1) clause 1 point (a) GDPR;

 

6. Use of cookies, plugins and other services on our website

a) Cookie

We use cookies on our websites. Cookies are small text files that are assigned to the browser you use through a characteristic sequence of characters and saved on your hard drive. The entity that places the cookie then receives certain information. Cookies cannot execute programs or infect your computer with viruses and therefore can do no damage. Their purpose is to make the website more user-friendly and effective, i.e. more convenient for you.

Cookies may contain data that allow the device you are using to be recognised. In some cases, cookies only contain information on certain settings that cannot be linked to a person. Cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies that are saved beyond the end of a session. With regard to their function, a further distinction can be made between:

  1. Technical cookies: These are absolutely necessary for you to navigate the website, to use basic functions and to guarantee the security of the website; they neither collect information about you for marketing purposes nor do they save which websites you have visited.
  2. Performance cookies: They collect information on how you use the website, which pages you visit and whether there were any errors when you used the website. They do not collect information that can be used to identify you. All collected information is anonymous and is only used to improve our website and to find out what our users find interesting.
  3. Advertising cookies, targeting cookies: These serve to offer users of the website targeted advertisements on the website or third-party offers and to measure the effectiveness of these offers. Advertising and targeting cookies are stored for no more than 13 months.
  4. Sharing cookies: These serve to improve the interactivity of our website with other services (e.g. social networks). Sharing cookies are stored for no more than 13 months.

Any use of cookies that is not absolutely technologically necessary is a type of data processing that is only permitted with your expressed and active consent in accordance with Art. 6 (1) clause 1 point (a) GDPR. In particular, this applies to the use of advertising, targeting or sharing cookies. Furthermore, we will only transmit your personal data that was processed by cookies to third parties if you have expressly consented in accordance with Art. 6 (1) clause 1 point (a) GDPR;

b) Cookie guideline

You can find additional information on which cookies we use as well as how you can manage your cookie settings and deactivate certain types of tracking in our cookie guideline.

c) Social media plugins

We do not use social media plugins on our websites. When our websites contain the symbols of social media providers (e.g. [name of social media providers with symbols on the company website]), then we solely use them to passively link to the pages of the respective provider.