INFORMATION ON PRIVACY IN ACCORDANCE WITH ART, 13 OF UE Regulation 2016/679 (GDPR)

LAWS ON SENDER INFORMATION

LAWS ON ADDRESSEE INFORMATION

INFORMATION ON SENDER

Interflora Italia S.p.A., comes into possession of information that was gathered in the execution of its contractual relations, purchases, even verbal, directly or through third parties which are defined as “personal information” and “particular and sensitive information” according to UE Regulation no. 2016/679 (the so-called GDPR). This regulation, first of all, requires that those who process personal and particular/sensitive information is required to inform the subject of interest what information is processed and all the qualifying elements for the processing which, in any case, must be carried out correctly, fairly and transparently, safeguarding confidentiality and the rights of the interested subjects For this purpose and in compliance with art. 13 of the GDPR, we report the following information:

Holder of the processed information – Interflora Italia S.p.A. with registered and operational office at Via Giacomo Dina 36 – 00128 Rome, Italy, in the person of its titular head resident there.

Types of information processed – Interflora Italia S.p.A. processes personal information (name, surname, email address, telephone number - land line and/or mobile - , information of a financial nature for the purpose of billing the subject of the contract), as well as particular information (contained in the ticket/message attached to the gift that is the subject of the contract).

Purpose of the processing – The information indicated above are processed according to the aims of the contract and gathered at the moment of payment of the “order of the gift”. They are processed, managed and stored for administrative, legal and fiscal purposes. In addition, subsequent to the conclusion of the contract:

• the personal data can be processed for commercial purposes if and only if this processing it explicitly authorized (for example: sending an email, post, telephone messages, newsletters, commercial communications and/or advertising of products and services offered by the Title holder as well as telephone contacts for commercial purposes: sent via email, post, telephone messages, newsletters, commercial communications and/or promotions by third parties whether directly or through technical partners);
• particular data on the other hand will be deleted seven days after the conclusion of the contract of delivery of the gift.

Legal basis of the processing – Obligation or option to provide information and consequences of refusal – Without prejudice to the user’s right to allow processing of personal information, as far as the information that Interflora S.p.A. is obliged to know for the purpose of carrying out its obligations required by law, regulations and community standards are concerned, or the provisions issued by Authorities so authorized by law and by Bodies of supervision and control, failure to confirm by the User will bring about the incapacity of establish or finalize the relationship within the limits that such information is necessary for the execution of the same. The User has and holds the full right to withdraw at any time his or her consent for the processing (consent acquired with the signing of the order are per art 6 clause 1 letter b of the GDPR), without prejudicing the legality of the processing of the order contract prior to the withdrawal.

Methods of processing and technologies used - The information is processed with tools and procures that are suitable for ensuring security and confidentiality and will be undertaken through the use of paper means and through auxiliary electronic tools. All Interflora Italia sites use automatic information gathering methods (technical cookies) that are necessary for proper navigation in the above sites that are deleted at the end of or closure of a session. For third party cookies (for example, Google, Facebook, support chats, etc) the site has no direct control on the individual cookies and cannot control them (nor directly install or cancel them). In any case they can be managed by the browser settings. The personal data processed is managed on computer support with remote hosts and protected by suitable security systems (backup, firewall, security certificates, etc.).

Navigation data - Computer systems and programmes used for the operation of the site gather some personal information the use of which is implicit in the Internet communications protocols (i.e. IP addresses or domain names of the computers used by the user to connect to the site, addresses and times of the requests, method of connection to the server, numeric code of the outcome, as well as parametres regarding the user’s operating system). Although this information is not used to gather information to be associated with the interested parties identified, by their nature they could, through processing and associations with information held by third parties, allow the identification of the users. This information is used only for the purpose of gathering statistics (not associated with any information that could identify the user) on the use of the site and to control its proper operation. The information could be used for ascertaining responsibility in the case of hypothetical computer crime at the Site’s expense. Interflora Italia S.p.A. does not use computerized decision making processes, it does not undertake any profiling activity and therefore does not record, store or process information regarding the choices, habits and preferences of acquisition of its clients, nor create profiles (individual and/or aggregated) for the purpose of making targeted offers.

Communication and distribution - The information gathered in this way will not be “distributed”, that is it will not be made known to indeterminate subjects in any way, even through making them available or consultation. On the other hand, the above information could be “communicated”, to one or more determined subjects and identified as follows:

• to subjects within Interflora Italia S.p.A. as managers or charged with the processing and/or system administrators;
• to subjects that can access the information pursuant to the law, community rules and regulations, within the limits of these regulations;
• to subjects who require access to the above information for the purpose of assisting the rapport between the user and Interflora Italia S.p.A., within the limits strictly necessary to carry out the auxiliary tasks entrusted to them (for example, credit institutes, financial and employment advisers, etc.);
• to Interflora Italia S.p.A. consultants, limited to the task given them, subject to the signing the limits of security and confidentiality limits for the processing of information.

Communication and distribution overseas – The personal and particular information gathered in the execution of the contract will be transferred overseas only if this situation is or can become an integral part of the execution of the contract (delivery of gifts outside the country’s borders). In this case the information will be transmitted to the corresponding Interflora in the country of destination and processed by the central information bank Fleurop-Interflora Global Flower Services, S.A. – with registered office in 28006 Madrid, Spain, Calle de Maria de Molina 39 website www.fleurop.com which will transmit them to the Interflora of the country of destination of the gift. The overseas transfer for the execution of a specific contract requires the passage through an internal computer system of the Interflora circuit that is not accessible to outside parties.

Period of storage – The Holder will store the personal information for the time required to carry out the purpose above and in any case no more than 10 years after the execution of the contract for the Purpose of the Service and for no more than 10 years from the collection of consent for Marketing purposes. The particular information (messages included with the gift) will be stored for the purpose of the contract and, in any case, for no longer than 7 days after delivery of the order.

The rights of the User – According to the requirements of the GDPR, it is possible to exercise the following rights in regard to Interflora Italia S.p.A:

• access to personal information (art 15 of the GDPR);
• to obtain correction or deletion (oblivion) of the same or to limit the processing that regards it (art. 16, 17 and 18 of the GDPR);
• to contest the processing (art. 21 of the GDPR);
• the portability of the information (art. 20 of the GDPR);
• to withdraw consent;
• to present a complaint to the control authority (Guarantor of Privacy – www.garanteprivacy.it).

Minors – Interflora Italia’s services are not explicitly directed at anyone less than 16 years of age. Interflora Italia does not intentionally gather personal information in reference to minors. At the user’s request the Holder will delete such information immediately.

Methods of exercising rights – Interested parties will be able to exercise their rights by sending a letter to: Interflora Italia S.p.A.- Via G. Dina 36 – 00128 Roma attention:Ufficio Privacy, or by email to:privacy@interflora.it; or by contacting the call centre and following the instructions of the privacy manager. The interested party will receive a notification of the execution of the request/exercise of rights within 15 days of the request.

Holder, manager and agents - The Holder of the processing is Interflora Italia S.p.A. with registered office at via Giacomo Dina 36 – 00128 Rome, Italy in the person of the legal representative pro tempore resident there. The updated list of the managers and the agents for processing is held at the registered office of the Holder of the processing.

INFORMATION FOR ADDRESS

Interflora Italia S.p.A., comes into possession of information that was gathered in the execution of its contractual relations, purchases, even verbal, directly or through third parties which are defined as “personal information” and “particular and sensitive information” according to UE Regulation no. 2016/679 (the so-called GDPR). This regulation, first of all, requires that those who process personal and particular/sensitive information is required to inform the subject of interest what information is processed and all the qualifying elements for the processing which, in any case, must be carried out correctly, fairly and transparently, safeguarding confidentiality and the rights of the interested subjects For this purpose and in compliance with art. 13 of the GDPR, we report the following information:

Holder of the processed information – Interflora Italia S.p.A. with registered and operational office at Via Giacomo Dina 36 – 00128 Rome, Italy, in the person of its titular head resident there.

Types of information processed – Interflora Italia S.p.A. processes personal information (name, surname, email address, telephone number - land line and/or mobile - , information of a financial nature for the purpose of billing the subject of the contract), as well as particular information (contained in the ticket/message attached to the gift that is the subject of the contract).

Purpose of the processing – The information indicated above are processed according to the aims of the contract and gathered at the moment of payment of the “order of the gift”. They are processed, managed and stored for administrative, legal and fiscal purposes. In addition, subsequent to the conclusion of the contract:

• the personal data can be processed for commercial purposes if and only if this processing it explicitly authorized (for example: sending an email, post, telephone messages, newsletters, commercial communications and/or advertising of products and services offered by the Title holder as well as telephone contacts for commercial purposes: sent via email, post, telephone messages, newsletters, commercial communications and/or promotions by third parties whether directly or through technical partners);
• particular data on the other hand will be deleted seven days after the conclusion of the contract of delivery of the gift.

Legal basis of the processing – Obligation or option to provide information and consequences of refusal – Interflora Italia S.p.A. holds the information for the execution of a delivery order of the gift gathered in the territory by Interflora Italia S.p.A.’s Florists or directly on the Interflora Italia S.p.A. website. The processing of this information is therefore necessary for carrying out its contractual obligations and those required by community law, rules and regulations, or by the provisions of the Authority authorized by law and by supervision and control organs.

Methods of processing and technologies used - The information is processed with tools and procures that are suitable for ensuring security and confidentiality and will be undertaken through the use of paper means and through auxiliary electronic tools. All Interflora Italia sites use automatic information gathering methods (technical cookies) that are necessary for proper navigation in the above sites that are deleted at the end of or closure of a session. For third party cookies (for example, Google, Facebook, support chats, etc) the site has no direct control on the individual cookies and cannot control them (nor directly install or cancel them). In any case they can be managed by the browser settings. The personal data processed is managed on computer support with remote hosts and protected by suitable security systems (backup, firewall, security certificates, etc.).

Navigation data - Computer systems and programmes used for the operation of the site gather some personal information the use of which is implicit in the Internet communications protocols (i.e. IP addresses or domain names of the computers used by the user to connect to the site, addresses and times of the requests, method of connection to the server, numeric code of the outcome, as well as parametres regarding the user’s operating system). Although this information is not used to gather information to be associated with the interested parties identified, by their nature they could, through processing and associations with information held by third parties, allow the identification of the users. This information is used only for the purpose of gathering statistics (not associated with any information that could identify the user) on the use of the site and to control its proper operation. The information could be used for ascertaining responsibility in the case of hypothetical computer crime at the Site’s expense. Interflora Italia S.p.A. does not use computerized decision making processes, it does not undertake any profiling activity and therefore does not record, store or process information regarding the choices, habits and preferences of acquisition of its clients, nor create profiles (individual and/or aggregated) for the purpose of making targeted offers.

Communication and distribution - The information gathered in this way will not be “distributed”, that is it will not be made known to indeterminate subjects in any way, even through making them available or consultation. On the other hand, the above information could be “communicated”, to one or more determined subjects and identified as follows:

• to subjects within Interflora Italia S.p.A. as managers or charged with the processing and/or system administrators;
• to subjects that can access the information pursuant to the law, community rules and regulations, within the limits of these regulations;
• to subjects who require access to the above information for the purpose of assisting the rapport between the user and Interflora Italia S.p.A., within the limits strictly necessary to carry out the auxiliary tasks entrusted to them (for example, credit institutes, financial and employment advisers, etc.);
• to Interflora Italia S.p.A. consultants, limited to the task given them, subject to the signing the limits of security and confidentiality limits for the processing of information.

Communication and distribution overseas – Personal and particular information gathered in the execution of the contract are not subject to transfer overseas.

Period of storage – The Holder will store the personal information for the time required to carry out the purpose above and in any case no more than 10 years after the execution of the contract for the Purpose of the Service and for no more than 10 years from the collection of consent for Marketing purposes. The particular information (messages included with the gift) will be stored for the purpose of the contract and, in any case, for no longer than 7 days after delivery of the order.

The rights of the User – According to the requirements of the GDPR, it is possible to exercise the following rights in regard to Interflora Italia S.p.A:

• access to personal information (art 15 of the GDPR);
• to obtain correction or deletion (oblivion) of the same or to limit the processing that regards it (art. 16, 17 and 18 of the GDPR);
• to contest the processing (art. 21 of the GDPR);
• the portability of the information (art. 20 of the GDPR);
• to present a complaint to the control authority (Guarantor of Privacy – www.garanteprivacy.it).

Minors – Interflora Italia’s services are not explicitly directed at anyone less than 16 years of age. Interflora Italia does not intentionally gather personal information in reference to minors. At the user’s request the Holder will delete such information immediately.

Source of the information – The source of the data is the sender of the order. This subject is the person who is indicated in the signed form in the card/message included with the gift. Interflora Italia S.p.A. is not required to verify neither the presence of the signature nor the identity of the sender of the gift and is not even obliged to gather such information in the case of an order through Florists in the territory. In the case of an anonymous message, no responsibility can be given to Interflora Italia S.p.A. which carried out the delivery exclusively in compliance with the contractual obligation assumed.

Methods of exercising rights – Interested parties will be able to exercise their rights by sending a letter to: Interflora Italia S.p.A.- Via G. Dina 36 – 00128 Roma attention: Ufficio Privacy, or by email to:privacy@interflora.it. The interested party will receive a notification of the execution of the request/exercise of rights within 15 days of the request.

Holder, manager and agents - The Holder of the processing is Interflora Italia S.p.A. with registered office at Via Giacomo Dina 36 – 00128 Rome, Italy in the person of the legal representative pro tempore resident there. The up to date list of the managers and the agents for processing is held at the registered office of the Holder of the processing.