Privacy policy

Privacy Policy

The purpose of this document (hereinafter “Privacy Policy”) is to inform Users about personal data, understood as any information that allows the identification of a natural person (hereinafter “Personal Data”), collected by the website (hereinafter “Application”).

The Title holder, as identified below, may amend or simply update all or part of this Policy by informing Users. The amendments and updates will be binding as soon as they are published on the Application. The User is therefore invited to read the Privacy Policy each time the Application is accessed.

In the event that you do not accept the changes made to the Privacy Policy, the User must cease using this Application and may request the Title holder to remove his/her Personal Data.

  1. Personal Data collected by the Application

    The Title holder collects the following types of Personal Data:

    1. Content and information provided voluntarily by the User
      • Contact data and content: are those Personal Data that the User voluntarily provides to the Application during its use, such as personal data, contact details, credentials for accessing the services and/or products provided, personal interests and preferences and other personal content, etc.
      • Sensitive data: Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, Data concerning a person's health or sexual life or sexual orientation.

      Failure on the part of the User to provide Personal Data, for which there is a legal or contractual obligation or if they are a necessary requirement for the use of the service or for the conclusion of the contract, will result in the impossibility for the Title holder to provide all or part of its services.

      The User who communicates to the Title holder Personal Data of third parties is directly and exclusively responsible for their origin, collection, processing, communication or dissemination.

    2. Data and content acquired automatically while using the Application:
      • Technical Data: The computer systems and software procedures used to operate this Application may acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified Users, but by its very nature could, through processing and association with Data held by third parties, allow Users to be identified. This category includes IP addresses, or the domain names used by Users connecting to the Application, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained, etc.
      • Usage Data: Personal Data relating to the use of the Application by the User may also be collected, such as the pages visited, the actions performed, the features and services used.
      • Geolocation Data: the Application may collect Personal Data about the User's location, which may be GNSS (Global Navigation Satellite System) data, such as GPS data, as well as data identifying the nearest cell tower, Wi-Fi and Bluetooth hotspots, communicated when enabling location-based products or features.
    3. Personal data collected via cookies or similar technologies:

      The Application uses cookies, web beacons, unique identifiers and other similar technologies to collect Personal Data about the pages, links visited and other actions performed when using our services. They are stored and then retransmitted the next time the same User visits.

      The User can view the full Cookie Policy at the following address:

  2. Purposes

    The Personal Data collected may be used for the performance of contractual and pre-contractual obligations and for legal obligations, as well as for the following purposes:

    • Advertising targeting and remarketing: to show advertisements that are more relevant to the User based on his/her browsing behaviour and preferences.

      Personal Data are communicated to

    • Support and contact with the user: to answer the User's requests and help him/her in case of problems.
    • Statistics only with anonymous data: to carry out statistical analyses based on aggregated data or data that do not allow the User to be identified.

      Personal Data are communicated to

    • Advertising targeting and remarketing: to show advertisements that are more relevant to the User based on his/her browsing behaviour and preferences.
    • Own market research and surveys: to do market research and surveys in-house.
  3. Treatment methods

    The processing of Personal Data is carried out by means of computer and/or telematic tools, with organisational methods and logics strictly related to the stated purposes.

    In some cases, subjects involved in the organisation of the Title holder (such as, for example, personnel management staff, sales staff, system administrators, etc.) or external subjects (such as IT companies, service providers, postal couriers, hosting providers, etc.) may also have access to Personal Data. These parties may be appointed as Data Supervisors by the Title holder, as well as have access to the Personal Data of the Users whenever necessary and will be contractually obliged to keep the Personal Data confidential.

    The updated list of Responsible Persons can be requested by e-mail at

  4. Legal basis of processing

    The processing of Personal Data relating to the User is based on the following legal bases:

    • the consent given by the User for one or more specific purposes;
    • the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures
    • the processing is necessary to fulfil a legal obligation to which the Title holder is subject
    • the processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the Title holder
    • the processing is necessary for the pursuit of the legitimate interest of the Title holder or of third parties
    • the processing is necessary for the pursuit of a vital interest of the Title holder or a third party.

    However, it is always possible to ask the Title holder to clarify the legal basis of each processing operation by writing to

  5. Place

    Personal Data are processed at the Title holder's premises and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller at the following email address or at the following postal address S.P. 45 bis km 12, San Giovanni Rotondo 71013 Italy.

  6. Security Measures

    The Processing is carried out according to methods and with instruments that guarantee the security and confidentiality of Personal Data, the Title holdet having adopted appropriate technical and organisational measures that guarantee, and allow it to be demonstrated, that the Processing is carried out in compliance with the reference legislation.

  7. Data retention period

    Personal Data will be kept for the period of time necessary to fulfil the purposes for which they were collected.

    In particular, Personal Data will be retained for the entire duration of the contractual relationship, for the performance of the inherent and consequent fulfilments thereof, for compliance with applicable legal and regulatory obligations, as well as for its own or third party defence purposes.

    Where the processing of Personal Data is based on the User's consent, the Title holder may retain the Personal Data until the consent is revoked.

    Personal Data may be kept for a longer period if required to fulfil a legal obligation or by order of an authority.

    All Personal Data will be deleted or stored in a form that does not allow the User to be identified within 30 days of the end of the storage period. At the end of this period, the right of access, cancellation, rectification and the right to portability of Personal Data can no longer be exercised.

  8. Automated decision-making processes

    All Personal Data collected shall not be subject to any automated decision-making process, including profiling, which may produce legal effects for the individual or which may significantly affect the individual.

  9. User's Rights

    Users may exercise certain rights with regard to Personal Data processed by the Title holder. In particular, the User has the right to:

    • withdraw consent at any time;
    • oppose the processing of his or her Personal Data;
    • access his or her Personal Data;
    • verify and request rectification;
    • obtain restriction of processing;
    • obtain the deletion of his or her Personal Data;
    • receive his/her Personal Data or have it transferred to another Title holder;
    • file a complaint with the Data Protection Supervisory Authority and/or take legal action.

    To exercise their rights, Users may address a request to the Title holder's contact details indicated in this document. Requests are made free of charge and processed by the Title holder as quickly as possible, in any case within 30 days.

  10. Title holder

    The Title holder is Sottolestelle Distribuzione s.r.l., with registered office in SP 45bis Km 12, Tax Code/VAT No. 03905890715, REA 24065, e-mail address, CEM address

Last updated: 01/01/2021