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Data privacy notice pursuant to article 13 GDPR
(General data protection regulation) 2016/679

Dear User of the App,

Frescofrigo S.r.l., in its capacity as data controller, wishes to inform you, pursuant to article 13 of the Regulation UE 2016/679, that your data will be processed in the manner and for the purposes set forth here below.

The data controller for these purposes is the company Frescofrigo S.r.l. whose registered office is in Verona (37126) , at Via Quattro Novembre n. 24, with tax identification and VAT number and Registration on the Verona Companies Register IT04585380233, and with certified email address frescofrigosrl@legalmail.it.

Data processed, the purposes of their use and the legal basis for the use of the data

As part of the activities carried out by Frescofrigo, personal identification data, such as name and surname, e-mail address, telephone number, date of birth, gender, application crash data, user ID (unique identification code), and application interaction data, are processed for the following purposes:

1. purposes related to the operation and security of the App Frescofrigo: creation of the personal profile, performance of the purchase stages for food products (unlocking the door of the refrigerator, loading the product taken), the association of the user's identity to the payment of the fee by encrypted electronic means;
2. statistical purposes: processing of aggregate data, which do not permit identification of the User, for the improvement of the service, of the contents of the App and of the assortment of food products by the refrigerator managers;
3. commercial purposes: offer of additional services, improvement of the assortment of products in the refrigerators by the managers of the sales service;
4. direct marketing purposes: sending emails and newsletters to promote the service;
5. profiling purposes: determination of purchasing preferences to improve the User's experience.

The processing operations are those indicated by the GDPR: namely the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of data. Appropriate filing and search procedures have been adopted to ensure the traceability of all data processing.

The legal basis that legitimizes the processing of data is the consent freely given by the User at the time of registration with Frescofrigo App.

The credit card details of the User for the payment of purchased food products are encrypted and stored exclusively by the operator of the payment system.

App usage data 

The Frescofrigo App automatically acquires, during the User’s usage, some personal data whose transmission is implicit in the use of Internet communication protocols. This includes information such as IP addresses of devices used by users, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters relating to the operating system of the User. In addition to the operation and security of the App, this data is used to obtain statistical information. Access data could also be used to ascertain responsibility in case of possible computer crimes.

Data obtained while using the App 

Frescofrigo collects personal data (e.g. IP address) relating to Users through the installation and use of cookies and similar technologies to be able to perform specific activities.

1. Session data

Frescofrigo uses its own session data, which are essential for using the app and to allow functions such as authentication, validation, and monitoring of a usage session, as well as fraud prevention.

2. Technical data

Frescofrigo uses performance data or technical or analytical cookies, which do not require consent, for statistical purposes and in order to provide a fast and secure digital experience, for example, by allowing you to maintain a connection to the secure area while browsing; to store or identify the pages you visit, and to prevent them from being repeated.

The pages may also contain particular images that make it possible to determine whether or not a certain page has been viewed and, if so, to count the number of users who have viewed it.

3. Duration of data

Some cookies (session cookies) remain active only until the browser is closed or the logout command is carried out. Other cookies "survive" when the browser is closed and are available on subsequent visits by the User. These cookies are called persistent and their duration is fixed by the server when they are created. In some cases an expiry date is set, in others the duration is unlimited.

Persons who may process the data

Your data may be processed by our employees and internal collaborators, who will be designated as authorized parties and will be provided with specific and detailed instructions so that the data is processed in full compliance with the GDPR and current legislation.

Without prejudice to the communications and disclosures made in execution of legal obligations, the data may be communicated - for reasons strictly related to contractual relations - to the following categories of third parties:

• professionals and consultants providing services required for the above purposes;
• credit institutions that provide services required for the above purposes;
• persons who process data in order to fulfil specific legal obligations;
• judicial or administrative authorities, for the fulfilment of legal obligations.

In any case, the User's personal data shall not be generally divulged.

The nature of the assent

Failure to consent to the processing of data will prevent you from registering on the App or using the service.

The data are acquired exclusively by electronic, telematic and automated means.

Transfer of data to a third country or international organization

There are no plans to transfer User data to third countries outside the EU or to international organizations.

The length of time the data are kept

The Users' data are stored for the entire period of use of the App and for 10 (ten) years after the last access or such longer period as may be provided for in applicable civil, accounting and tax law.

Your rights as user

In relation to the data processing described in this notice, the User may exercise the rights set out in Articles 7, 15 to 21 and 77 of the GDPR and, in particular:

• right of access - Article 15 GDPR: the right to obtain confirmation as to whether or not personal data concerning the User are being processed and, if so, to obtain access to such personal data and a copy thereof;
• right of rectification - Article 16 GDPR: right to obtain, without undue delay, rectification of inaccurate personal data concerning the User and/or supplementation of incomplete personal data;
• right to erasure (right to be forgotten) - Article 17 GDPR: right to obtain, without undue delay, the erasure of personal data concerning the User;
• the right to restrict the processing of the data - Article 18 GDPR: the right to obtain restriction of processing, if: the interested party contests the accuracy of his personal data, for the period necessary for the Data Controller to verify the accuracy of such data; if the processing is unlawful and the interested party objects to the erasure of personal data and requests instead that their use be restricted; if the personal data are necessary for the interested party to ascertain, exercise or defend a right in court; if the interested party has objected to the processing pursuant to Art. 21 GDPR, during the period pending verification of whether the legitimate rights of the Data Controller prevail over those of the person concerned;
• the right to data portability - Article 20 GDPR: the right to receive, in a structured, commonly used and machine-readable format, the personal data concerning the User provided to the Data Controller and the right to transmit them to another data controller without hindrance, where the processing is based on consent and is carried out by automated means. In addition, the right to have the User's personal data transmitted directly to another controller if this is technically feasible;
• the right to object - Article 21 GDPR: the right to object, at any time, on grounds relating to a particular situation, to the processing of personal data concerning the User based on the lawful condition of legitimate interest or performance of a task carried out in the public interest or in the exercise of official authority, including profiling, unless there are legitimate grounds for the Controller to continue the processing which override the interests, rights and freedoms of the Interested party or for the establishment, exercise or defense of legal claims. In addition, the right to object at any time to the processing if personal data are processed for direct marketing purposes, including profiling, insofar as it is related to such direct marketing;
• the right of revocation - Article 7 GDPR: the User has the right to revoke their consent at any time. Withdrawal of consent shall not affect the lawfulness of the processing based on the consent before withdrawal;
• the right to complain - Article 77 GDPR: the User has the right to lodge a complaint with the Italian Data Protection Authority, Piazza Venezia 11, 00187, Rome (RM).

The User may exercise their rights at any time by sending a registered letter with advice of receipt to Frescofrigo S.r.l., Via Quattro Novembre n. 24, 37126 Verona, or a certified e-mail message to frescofrigosrl@legalmail.it.

The exercise of these rights is free of charge pursuant to Article 12 GDPR. However, in the case of requests that are manifestly unfounded or excessive, including due to their repetitiveness, the Data Controller may charge the data subject a reasonable expense contribution in light of the administrative costs incurred in handling the request or deny satisfaction of the request.

ACKNOWLEDGEMENT AND CONSENT

By closing this message, scrolling down this page or clicking on any of its elements you declare:

• that you have read the content of the notification provided by Frescofrigo S.r.l.
• that you give your express consent to the processing of data for the following purposes:

1. service delivery, management and security of the Frescofrigo App;
2. statistical processing;
3. the exercise of the rights of the Data Controller, including the right of defense in Court.

• that you consent to the transfer of the data collected in favor of the entities that carry out the sale of food products or manage automated refrigerators.