PERSONAL DATA PROTECTION NOTICE PURSUANT TO ART. 14 OF EU REGULATION 2016/679 (“GDPR”)

CONTROLLER OF THE DATA PROCESSING

The Data Controller is Fratelli Carli S.p.A. ("Carli SpA", or “we”) with registered offices in Italy - Via Garessio 11 - 18100 Imperia. Since Carli SpA is an Italian company, it shall comply with the EU General Data Protection Regulation 2016/679 (“GDPR”) and the Italian legislation on personal data processing (Legislative Decree no. 196/2003).

The Data Protection Officer of Carli SpA can be contacted at: dpo@fratellicarli.com.

CATEGORIES OF PERSONAL DATA CONCERNED

Through its Customer Relationship management system (“CRM”) Carli SpA may access the personal data which you insert in your account on oliocarli.us (if you have one) or which you provide when making telephone, online or ordinary mail orders to Fratelli Carli USA Inc. (“Carli USA) In particular, Carli SpA then processes certain data concerning your purchases (first name, last name, mobile number, telephone number, e-mail, shipping address, etc…) for the purposes indicated below.

SOURCE OF DATA

We receive your personal data from Carli USA, which inputs them in Carli SpA’s CRM.

PURPOSES OF THE PROCESSING

We make an analysis of Carli USA’s customers purchasing behaviours and preferences, to allow planning targeted promotions and commercial offers and evaluate their performance and the overall appreciation of Carli’s SpA brand in the US. The processing includes associating automatically the information about your purchase orders (frequency of orders, preferred items, etc.) with information originating from orders of similar groups of Carli USA’s customers. No other personal data of yours undergo profiling. Carli SpA makes use of business intelligence systems to automatically elaborate on parameters.

LEGAL BASIS FOR THE PROCESSING

The legal basis for the processing is the legitimate interest of Carli SpA -  being it the owner of “Fratelli Carli” trademarks and producing its branded products -  to have Carli USA offer on the US market targeted and possibly most performing commercial opportunities concerning Carli SpA’s products, that US customers choose because of their Italian origin, and for the accuracy of our selected specialties.

RECIPIENTS OF THE PERSONAL DATA

In the execution of the contract that binds them to Fratelli Carli S.p.A. some external suppliers who provide platforms (e.g. CRM) and services may have access to personal data. In this case, they are appointed as Data Processors through a specific Data Protection Agreement. Carli SpA allows Carli USA’s personnel to access the output of the above-mentioned analysis to allow Carli USA to send targeted commercial offers and promotions. Carli S.p.A. may share the e-mail address of customers with social networks and Google in order to distinguish online ads for people who are already customers and those who are not (audience services).

DURATION OF THE DATA PROCESSING

The profiling of your our data by Carli SpA shall last for a time proportionate to the above-mentioned legitimate interest and anyway by ensuring adequate protection of your rights and of your privacy from any risk.

EXTRA EU DATA TRANSFER

Our policy aims at minimizing transfers outside EU of personal data of customers, even if they are established outside the EU. Besides letting Carli USA access your personal data further to profiling and in relation to some specific technical or assistance services (for instance, for maintenance of the CRM software) your personal data can be transferred outside EU - mainly to the U.S. – only in compliance with the EU General Data Protection Regulation 2016/679.

YOUR RIGHTS

You have the right to request from Carli SpA access to and rectification or erasure of your personal data (by inserting your contact addresses in a black list), the restriction of the processing, and in particular to object to our processing, by contacting our Data Protection Officer (DPO) at the e-mail address indicated above. In particular, if you wish to opt-out from the profiling processing, you can also express your choice in the section “My choices” on www.oliocarli.us website, if you have your account. By opting-out, your purchasing behaviours will no longer be analysed, and you will consequently no longer receive customized offers and promotions from Carli USA, but only their general offers and promotions. If you wish instead to receive no offers and promotions at all from Carli USA, please contact them at customer.service.us@fratellicarli.us, or again select “no” where indicated in the section “My choices” on www.oliocarli.us website relating to Carli USA.

Our DPO is in any case available to all data subjects for any information or clarification concerning our processing of your personal data.

You have the right to lodge a complaint with the Italian Data Protection Supervisory Authority (“Garante per la protezione dei dati personali”) at protocollo@gpdp.it, or with the judicial authority.