Data protection

Data protection
declaration and cookie policy
version 1.0

Tenuta Sanoner Srl Società Agricola, based in I-39046 St. Ulrich, Reziastraße 7
(hereinafter Tenuta Sanoner), always strives to protect the online privacy of
its users. This document has been prepared in accordance with Article 13 of EU
Regulation 2016/679 (hereinafter referred to as the “Regulation”) in order for
you to become acquainted with our privacy policy and to understand how your
personal information will be treated when you use our website and, if
necessary, your To expressly and consciously give consent to the processing of
your personal data (valid only for persons aged at least 16 years). The
information and data provided by you or otherwise acquired by us when using our
services on the website (hereinafter referred to as “Services”) will be
processed in accordance with the provisions of the Regulation and the
confidentiality obligations that affect the activities of the Controller.

In accordance with the provisions of the Regulation, the processing carried out
by Tenuta Sanoner is based on the principles of lawfulness, fair processing,
transparency, purpose limitation, storage limitation, data minimization,
accuracy, integrity and confidentiality.

DIRECTORY1.The controller2.The personal data subject to the
processinga.Navigation datab.Special categories of personal datac.Data
voluntarily provided by the data subject3.Purpose of the processing4.Legal
basis and mandatory or optional nature of the processing5.Recipients of
personal data6.Disclosure of personal data7 .Storage of personal data8.Rights
of data subjects9.Changes1. The person responsible
The person
responsible for the processing carried out on the website is Tenuta Sanoner, as
determined above. For information about the processing of personal data by the
Controller, including the list of processors commissioned to process the data,
please write to the following address:

2. The personal data subject to processing We inform you that,
based on your navigation on the website, the Controller will process personal
data consisting of an identifier such as your name, an identification number,
an online identifier, a postal address, an email address, a telephone number
(landline and/or mobile) or one or more elements of your physical,
physiological, psychological, economic, cultural or social identity in order to
identify or make the data subject identifiable (in the referred to as “personal

The personal data processed through the website are the following:

a. Navigation data

The computer systems and software procedures used to operate the website
collect, during their normal operation, some personal data, the transmission of
which is implicit in the communication protocols of the Internet. This
information is not collected to be associated with identified data subjects,
but due to its nature, may enable users to be identified through processing and
association with third party data. This category of data includes IP addresses
or domain names of computers used by users connecting to the website, the URI
(Uniform Resource Identifier) ​​addresses of the requested resources, the time
of the request, the method by which the request is made is sent to the server,
the size of the file received in response, the numerical code indicating the
status of the server's response (successful, error, etc.) and other parameters
related to the operating system and computing environment. These data are used
exclusively to obtain anonymous statistical information about the use of the
website and to verify its correct functioning, detect anomalies and/or misuse
and are deleted immediately after processing. The data may be used to determine
liability in the event of hypothetical computer crimes against the website or
third parties. Apart from this option, the data collected on the website will
be deleted after a short period of time.

b. Special Categories of Personal Data

If you use our website to submit a job application (or send it to us via email),
there may be a transfer of your personal data that falls under the special
categories of personal data set out in Article 9 of the Regulation, literally
the “ […] personal data revealing racial and ethnic origin, political opinions,
religious or philosophical beliefs or trade union membership, as well as […]
genetic data, biometric data to uniquely identify a natural person, health data
or data relating to sexual life or the sexual orientation of a natural person.”
Please do not publish this data unless absolutely necessary. We expressly
inform you that the Controller cannot be held responsible in relation to the
transmission of special categories of personal data, but in the absence of
express consent to the processing of these data (you are of course allowed to
send a CV). , for whatever reason, may still receive objections of any kind,
since in this case the processing is permitted since it relates to data clearly
made public by the data subject, in accordance with Article 9(1)e of the
Regulation . However, we note that, as mentioned above, it is important to
provide express consent to the processing of special categories of personal
data if you decide to submit this information.

We also inform you that the person responsible can analyze the social profiles
that are freely accessible on the Internet for professional purposes (e.g.
LinkedIn) for the purpose of selecting applicants.

c. Data provided voluntarily by the data subject

When you use certain services on the website (e.g. the inquiry, contact or
reservation form), we may process personal data from third parties that you
send to the data controller. In these cases, you are the data controller who
assumes all legal obligations and liabilities. In this sense, you grant us the
fullest possible indemnity in relation to any reservations, claims, claims for
damages arising from processing, etc. that the Controller may receive from
third parties whose personal data are processed through the use of the
functions of the Website in violation of the current regulations on the
protection of personal data data was processed. If you provide or otherwise
process personal data of third parties in the course of using the Website, you
guarantee in any case that this particular case of processing is based on an appropriate
legal basis in accordance with Article 6 of the Regulation, which legitimizes
the processing of the information in question.

3. Purpose of processing The processing that we intend to
carry out (where necessary) with your express consent has the following

a. To enable the provision of the services you have requested

b. Respond to customer service requests, requests for information, or

c. Analyzing CVs and contacting candidates who have submitted their

d. Comply with all legal, accounting and tax obligations

e. Marketing purposes: The data provided may be used, after prior express and
specific consent, for the sending of advertising and marketing communications,
including the sending of newsletters and market research surveys, using
automated (SMS, MMS, email, push notifications) and non-automated (postal, Call
center) systems are processed. The legal basis for processing your data for
these purposes is Article 6 paragraph 1 letter a) of the Regulation. Consent to
processing for direct marketing is optional and depends on your free choice, so
failure to provide your consent for this purpose will not affect the use of the

f. Marketing purposes with profiling: The data provided may, subject to express
and specific consent, be used for the purpose of commercial profiling and
formulation of personalized offers and targeted advertising based on purchases
made and/or navigation behavior and/or other consumer behavior and/or the data
entered in the forms and/or the answers in market research surveys are
processed. The processing of data for marketing with profiling is optional and
depends on your consent; therefore, failure to provide your consent to
processing for this purpose will not affect the use of the Services.

4. Legal basis and mandatory or optional nature of processing
The legal basis for the processing of personal data for the purposes referred
to in Section 3 (abc) is Article 6(1)(b) of the Regulation (performance of a
contract), since the data processing is for To provide the services or to
respond to requests from the data subject. Providing personal data for these
purposes is optional, but failure to do so would make it impossible to activate
the services provided by the website, process requests or evaluate CVs. With
particular reference to purpose 3.c and the related analysis of social media
profiles of a professional nature made freely accessible on the Internet in
accordance with Section 2.b, Article 6(1)(f) of the Regulation forms the legal
basis for the treatment of the data, i.e. the legitimate interest of the
controller in examining possible risks to the suitability of the applicant to
fill the specific vacancy.

The purpose referred to in section 3.d constitutes a lawful processing of
personal data within the meaning of Article 6(1)(c) of the Regulation
(fulfillment of a legal obligation). Once the personal data have been provided,
the processing is in the Act necessary to fulfill a legal obligation to which
the person responsible is subject.

The legal basis for processing for the purposes set out in Section 3.e is
Article 6(1)(a) of the Regulation (user consent).

The Controller may, without your consent, carry out processing for the same
purposes as the direct sending of advertising material or direct sales or the
carrying out of market research or commercial communications relating to
products or services of the Controller similar to those purchased, E -Use email
addresses and postal addresses in accordance with and within the limits permitted
by Article 130 paragraph 4 of the Data Protection Code and the Order of the
Guarantor of Personal Data Protection of June 19, 2008. The legal basis for
processing your data for this purpose is Article 6(1)(f) of the Regulation
(legitimate interest).

The legal basis for processing for the purposes stated in Section 3.f is
Article 6(1)(a) (user consent).

5. Recipients of personal data Your personal data may be
disclosed for the purposes set out in section 3 to:

a. Subjects typically acting as data processors, that is: i) persons, companies
or office groups that provide assistance and advice to the Controller on
accounting, administrative, legal, tax, financial, collection, marketing and
communication matters relating to the provision of the Services; ii) subjects
with whom collaboration is necessary for the provision of the Services (e.g.
hosting providers); iii) subjects entrusted with carrying out technical
maintenance work (including maintenance of network equipment and electronic
communications networks) (collectively referred to as “Recipients”);

b. Subjects, entities or authorities to whom your personal data must be
communicated due to legal provisions or official orders;

c. Persons authorized by the Controller to process personal data necessary to
carry out activities related to the provision of the Services or for the other
purposes referred to in Section 3 and who have committed themselves to
confidentiality or have an appropriate legal obligation to maintain
confidentiality (e.g. employees of the person responsible).

6. Sharing of personal data Some of your personal data will be
shared with recipients who may be located outside the European Economic Area.
The data controller ensures that the processing of your personal data by these
recipients is carried out in accordance with the Regulation. Indeed, transfers
may be based on an adequacy decision, on the contractual clauses approved by
the European Commission or on any other appropriate legal basis. Further
information can be obtained from the person responsible at the following

7. Retention of personal data Personal data processed for the
purposes set out in Section 3(ab) will be retained for as long as strictly
necessary to achieve those purposes. Since the data processing is carried out
for the provision of services, the data controller will, in any case, process
the personal data until the time provided for by Italian legislation to protect
the interests (art. 2946 et seq. Civil Code). With regard to CVs submitted via
the website or by email in accordance with paragraph 3.c, the personal data
will be kept for a period deemed appropriate for the purpose for which the data
were collected. This applies regardless of the possibility for the controller
to contact the applicant again shortly before the expiry of the specified
deadline for requesting an extension of this retention period.

The personal data processed for the purposes referred to in paragraph 3.d will
be stored until the time provided for by the specific obligation or applicable

Personal data processed for the purposes referred to in paragraphs 3.e and 3.f,
on the other hand, will be retained until the data subject withdraws the
consent or, failing such withdrawal, for a specified maximum period of time deemed
appropriate is considered.

Further information about the retention period of the data and the criteria for
determining this period can be obtained from the person responsible at the
following address:

8. Rights of data subjects In accordance with Article 15 et
seq. of the Regulation, you have the right to ask the controller for access to
your personal data at any time, to request that they rectify or delete them or
to oppose the processing. You have the right to request the restriction of
processing in the cases provided for in Article 18 of the Regulation and, in
the cases provided for in Article 20 of the Regulation, to receive the data
concerning you in a structured, commonly used and machine-readable format.

Every request must be sent in writing to the person responsible at the
following address:

You have the right at any time to lodge a complaint with the relevant
supervisory authority (Guarantee of Personal Data Protection) in accordance
with Article 77 of the Regulation if you consider that the processing of your
personal data violates applicable law.

9. Changes This data protection declaration applies from May
25, 2018. The Controller reserves the right to modify or update the content in
whole or in part, including due to changes in current legislation. Therefore,
the person responsible encourages you to visit this section regularly to find
out about the latest and most up-to-date version of this data protection