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:
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
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
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:
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:
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:
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":
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 email@example.com 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:
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;
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:
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.