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Privacy Policy

Bros s.r.l. complies with the privacy protection policies contained in the General Data Protection Regulation 2016/679 concerning the protection of individuals with regard to the processing of personal data in addition to the cautions and procedures that the Guarantor has specified in the document on the published Privacy Policy on the official website of the Authority. On the Website, among others, the indications contained in Recommendation n. 2/2001 that the European authorities for the protection of personal data, gathered in the Group established by the art. 29 of the directive n. 95/46 / CE, adopted May 17, 2001 to identify some minimum requirements for the collection of personal data online, and, in particular, the methods, timing and nature of the information that the data controllers must provide to Users when they connect to web pages, regardless of the purpose of the connection. Bros s.r.l. complies with the provision n. 229 of 8 May 2014 “Identification of simplified procedures for information and acquisition of consent for the use of cookies”. The purpose of this document is to describe in general the methods for managing the processing of personal data acquired from the Website www.brosrestaurant.it (hereinafter “Site”). The document does not include the treatments carried out on other websites that may be consulted by the User through links on the Website. This document intentionally takes over the contents of the Privacy Policy applied by the Authority for the protection of personal data with reference to the processing of personal data of Users, published on the official website www.garanteprivacy.it. Use of this Site implies full acceptance of this Privacy Policy. The points covered in this document are thus specifications:

THE HOLDER OF THE TREATMENT Following consultation of this Site, data relating to identified or identifiable persons may be processed. The data controller is Bros S.r.l. with registered and administrative office in Via degli Acaya 2, 73100 Lecce (LE).

RESPONSIBLE FOR THE PROTECTION OF PERSONAL DATA

Contact details of the Data Protection Officer. The Company has appointed Andrea Buccoliero as the Data Protection Officer. You can be contacted by writing to: amministrazione@pellegrinobrothers.it

PLACE OF DATA PROCESSING

The processing operations connected to the web services of this Site take place at the administrative and tax office of the company Bros s.r.l., or in via degli Acaya 2, 73100 Lecce (LE).

OPTIONAL PROVISION OF DATA

The User is free to provide the personal data necessary in order to execute his specific requests. Personal data means any information relating to a person that allows the identification of such a person, such as his name, telephone number, e-mail and postal address, etc. Failure to provide such data may make it impossible to obtain what is requested.

TYPE OF DATA PROCESSED AND PURPOSE OF THE TREATMENT

Navigation data The computer systems and software procedures used to operate this Website 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 interested parties, but by their very nature could, through processing and association with data held by third parties, allow Users to be identified. This category of data includes the IP addresses or domain names of the computers used by the Users who connect to the Site, the URI (Uniform Resource Identifier) ​​addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters due to the operating system and the User’s computer environment. By monitoring the user’s navigation on our site, integrated with the use of cookies, Bros can collect specific information. They are presented in the dedicated section “COOKIES”. Data provided voluntarily by the User. The explicit and voluntary sending of the User’s personal data on this Site entails the subsequent acquisition by Bros, necessary to respond to the User’s requests. In this way, Bros becomes the Data Controller of the information released. Personal data will be processed for commercial purposes, direct sales, marketing and commercial, promotional, statistical and for the detection of consumer preferences, by processing with electronic and paper means and for any communications to third parties always for direct marketing purposes . For the User of the Site, it is necessary to provide data such as surname, name and e-mail address, in order to register on the Site itself and to enter the “MyBV” Reserved Site area and obtain from Brosl execution of sales assistance activities, as a service to verify / overcome any technical difficulties also of the User. With the consent of the User, the aforementioned data will also allow Bros to send its newsletters. The provision of data relating to the personal details of the interested party (name, surname and complete postal address) is necessary:

a) in order to allow Bros to fulfill its contractual obligations, in the event of a purchase order being made;

b) for post-sales assistance;

c) other personal data requested are optional (such as a landline phone number, mobile phone number, etc.) but if provided, they will allow the interested party to be contacted for service communications related to his order, to verify his satisfaction with the products, or, with your consent, will allow you to propose commercial offers, also based on the detection of your personal consumption preferences, commercial information on the products and news of Bros, promotional offers, also through marketing activities carried out in automated mode, by ordinary mail , via SMS / MMS, by landline and / or mobile and also to the e-mail address provided.

The data of third parties

In the area of ​​the Site dedicated to the purchase of Bros products, the User can be given the possibility to send the purchased products to third parties; in this case the User is required to indicate the personal details and the complete postal address of the recipient, to whom the chosen products should be sent.

Bros uses this data only to process the request for sending the parcel of the User, without making any further use. Publicly available information If our site offers chat room services, virtual bulletin boards, newsgroups, etc., please note that the information disclosed will be collected. This information will be used in accordance with this Privacy Policy. Bros is not responsible for the use that third parties can make of the information you disclose on our sites through chat rooms, virtual message boards, newsgroups, etc. Regarding the use of our chat rooms or virtual bulletin boards, we advise against the provision of sensitive data concerning the User or concerning other subjects, or data relating to race, political, religious or philosophical opinions, or belonging to any person political party, trade union and / or philosophical association, political or trade union, including personal data that may reveal health status, activities or sexual preferences. If you become aware of the fact that sensitive data have been provided, they will be deleted and / or made anonymous.

Data storage and access

The personal data processed are also processed through the creation of a centralized database, with IT and electronic tools. The database, containing the personal data of the interested parties, is accessible only by the authorized parties. Individuals specifically appointed as employees or other collaborators may become aware of the data in the treatments necessary or connected to the sending of advertising material and to the execution of the order and, if necessary, third-party suppliers of services strictly functional to the execution of the contractual relationship, such as: a) data entry, personalization and mailing company;

b) call center;

c) carriers for the delivery of the package;

d) companies that provide payment services;

e) central offices of supervisory institutions.

Specific instructions regarding the processing of data are given to each respionsible. Bros s.r.l. confirmation that any personal data communicated by the interested party is not intended for purposes other than those indicated here.

Data retention period based on purpose The personal data of each interested party are kept for the time strictly necessary to carry out those processing operations carried out in relation to each interested party, depending on his choices, preferences and indications. The storage of personal data for the purposes of direct marketing purposes relates to a maximum period of 24 months.

The personal data, subject to profiling treatment, for this purpose are used for 12 months. Personal data related to contractual relationships with Bros.’s customers are kept in accordance with the law for civil, fiscal, accounting, administrative purposes, to make possible means of proof in the event of litigation and to meet specific requests by the competent Authority.

General treatment

Bros uses user data, in accordance with their free consent only in the presence of an express authorization from the User, Bros proceeds to use its data. It clarifies that user data is controlled by the User, through communication and public communication techniques for sending advertising material, for carrying out direct sales activities, marketing research or commercial communication. Exactly like, an exit front of the User, Bros you can send to the User customized offers based on his consumption habits. The data have been communicated to the sector companies: home and office furniture, textiles, clothing, cosmetics and wellness, floriculture, publishing, hobby and generalists for marketing purpose.

From the applicability of the GDPR. The legal basis of the processing is constituted by the obligations arising towards the Interested party as part of the contractual relationship of sale (“treatment necessary for the execution of a contract” – GDPR Article 6, paragraph 1, letter b)); for treatments for direct marketing purposes, the legal basis is the legitimate interest of the company (“treatment necessary to pursue a legitimate interest of the data controller” GDPR art. 6, paragraph 1, letter f) and “Can be considered legitimate interest to process personal data for direct marketing purposes “Cons. n. 47); for all other treatments performed by the Data Controller, the legal basis is the consent of the interested party (RGPD art. 6, paragraph 1, letter a)).

Users’ data are never disclosed, with the exception of those that the User voluntarily makes available on any publicly accessible areas of the site. Bros invites Users not to provide special categories of personal data (ex sensitive data) within the site, reserving the right to delete such data or make it anonymous according to the protection directives contained in art. 9 of the GDPR 2017/679. The data can, finally, be communicated to the public authority in the presence of a legitimate order given by the same and eventually could be used to ascertain responsibility in case of hypothetical information crimes against the Site. SAFETY

Security is the fundamental technical element for the protection of the right to the protection of personal data, it is clear that the setting of security measures must be considered as an obligation for the Data Controller.

Specific security measures are observed to prevent the loss of data, illicit use, unauthorized access or processing that is not permitted or does not comply with the purposes of collection.

UNDERAGE USERS

Bros is aware that the Site and the Services could interest a minor public. Bros encourages parents to monitor their children’s use of the Internet, for safe and filtered use of its contents, including through the use of parental control tools. In addition to guaranteeing an online environment suitable for minors, these tools can prevent the disclosure of personal data by children or young people who do not have the consent of their parents. For children under 18 years. Are you a minor but are you already 16? Bros, starting from May 25th 2018, will be happy to accept your orders made on the Site. Your personal data collected in this way (name, surname, address, date of birth) will be processed only for all purposes related to the order fulfillment product delivery; will not be communicated to other companies nor will any profiling treatment be done. The newsletter will be sent to you if you have requested it and other commercial communications as well, but you can unsubscribe at any time through the relative function. For any clarification on the processing of your data, do not hesitate to contact us: amministrazione@pellegrinobrothers.it.

RIGHTS OF THE INTERESTED PARTIES

All changes to the Website Policy will be published in this document.