The data protection is important for the Poli Family and we want to guarantee maximum openness and transparency regarding the processing of personal data of users who browse our website. For this reason, the below document shows how the personal data of our users are elaborated and protected.

According to the EU regulation 2016/679 titled “General Data Protection Regulation” (GDPR), we inform our users that the personal data input on the site are treated with the methods and purposes here described.

For processing of personal data according to the law, we mean any operation or set of more operations, performed with our without the aid of electronic or automated means, concerning the collection, registration, organization, storage, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, deletion and distribution of data.

In compliance with the provisions of the new regulation on personal data protection, we inform you that:

1. Holder of the treatment

The holders of the processing of your personal data are as follows:

- Poli Distillerie Srl, con sede in Via G. Marconi, 46 - 36060 Schiavon (VI)

- Poli Museo della Grappa Srlu, con sede legale in Bassano del Grappa via Gamba, 6 - 36061 Vicenza

In other words, both the Poli Distillery Srl and the Poli Grappa Museum Srlu (in agreement “Us”), are the processing Co-holders. This means that we regulated together and we are both responsible for the processing and protection of your personal data.

2. Object of treatment

The personal data collected are supplied by the users when sending a contact request (“Contacts” form) and/or sending a request to view the contents of the Library of the Spirits (“Library” form) and/or while signing up for the newsletter service (“Newsletter” form).

3. Purpose of the treatment

The personal data are processed for purposes connected to or related to the Co-holders’ activities, such as storage in its own databases or conducting direct e-mail marketing activities.
In detail, data are collected through the consent expressed by the interested parties for:
- Receiving a message sent via the "Contact" form
- Completing the "Library" form
- Subscription to the newsletter service

While filling in the forms the personal data are requested, with which the user will be identified later in order to send him a reply at the email address indicated by him or to insert him in the mailing list.

4. Method of the treatment

The personal data are subjected to treatment based on principles of correctness, lawfulness and transparency. The co-holder users ensure that the data processing is performed with or without the aid of electronic or automated means. It will take place through appropriate tools, to ensure the security and confidentiality of the user concerned, by appropriate procedures that avoid any risk of loss, unauthorized access, illicit use and dissemination, in compliance with the limits and conditions set by the Regulation (EU) 2016/679 of the European Parliament.

The personal data are subjected to both paper and electronic and/or automated processing.

The data are processed by our staff, where engaged in the execution of the assignment given to us.

5. Access to the data

The parties who are allowed to become aware of the personal data of the user as managers or agents (according to Article 13 Paragraph 1 of the GDPR) are:

The co-holder users
The staff of the joint controllers, for the fulfilment of the user's requests (reply to a request for information and / or response to the request, visit and / or download photo visits, subscription to the newsletter)

The personal data will not be disclosed to third parties.

6. Data communication

The data may be communicated to supervisory entities, judicial authorities and other third parties to whom the communication is mandatory by law, including the environment of prevention/repression of any illegal activity related to the website and/or a sent request.

7. Data transfer

The management and storage of personal data takes place on servers located in Italy owned by the Co-holders and / or third-party companies and appointed as Data Processors.
The data will not be transferred to outside the European Union.

8. Data retention period

The personal data of the website users, who send a request for information via the contact form and/or who submit a request for a visit and/or forward a request for downloading a photo through the form "Photos Visits", will be kept for the time strictly necessary for the request fulfilment, for the purposes described in the point 3.

The data collected for the activities of newsletter subscription and for the access to the contents of the Library will be included in the company database and kept for the service duration; afterwards they will be cancelled or made anonymous within the time established by law.

In case of consent withdrawal of the specific treatment by the interested party, the data will be deleted or made anonymous within 72 hours from the receipt of the revocation.

9. Rights of the interested party

The users can always exercise the rights specified in the articles 13 (Comma 2), 15, 18, 19 and 21 of the GDPR, summarized here in the following points:

The interested party has the right to obtain confirmation of the existence of any data concerning him, even if not yet communicated, and to have their communication in an intelligible form;
The interested party has the right to ask the treatment Holder to access personal data, to integrate them, to correct them, to delete them or limit the processing concerning them, or to oppose their processing, in addition to the data portability right;
The interested party has the right to lodge a complaint to the Warrantor for the personal data protection, following the procedures and indications published on the official Authority’s website on: www.garanteprivacy.it;

The exercise of rights is not subject to any form bonds and is free.

From the moment you received this informative communication, we will consider for granted the consent to the processing of personal data as explained in points above.

10. Terms of rights’ exercise

The users may exercise their rights at any time by sending an e-mail to: info@grappa.com, or by writing a letter to: Poli Museo della Grappa Srlu, via Gamba, 6 - 36061 Bassano del Grappa (VI).

11. Cookies

A cookie is a small text file that is saved and, during subsequent visits, retrieved from the user's system or mobile device. If the user wishes to use our services, he implicitly accepts the use of these cookies.

How do we use cookies?

We make use of cookies in order to provide our customers with a browsing experience tailored as much as possible their preferences. Through the cookies we make sure that each time our website is visited, it is not necessary to enter the same information.

Third party cookies allow you to collect statistical data and user data in aggregate and individual form for analysis tools, in order to optimize the site and present the most relevant marketing material to the user.

Some third-party cookies are set for services that appear on our pages, but are not controlled by us. Social media providers such as Twitter, Facebook and YouTube set them instead and they concern the possibility for the user to share the website’s content as indicated by the respective icon.

Who can access the personal data?

The data transferred to third parties are used exclusively to supply the services above mentioned, for analysis purposes, in order to collect statistics data aimed to optimize the website and provide the user with the relevant material.

What is the legal base for the personal data processing?

The personal data processing to develop and improve our services and products is based on our own legitimate interest.

How long are the personal data stored for?

This website does not store the personal data. The cookies may be easily removed from the system or the mobile device using the browser. For management and removing instructions, visit the guide section of the used browser. It is also possible to disable the cookies or receive a notification any time a new cookie is sent to your own system or mobile device. In case the cookies are disabled, it will not be possible to use all the functions on our website.

12. Updates to our Privacy Policy

Some updates to our Privacy Policy might be necessary. The most updated Policy is always available on our website. The users will be notified of any material changes to the Privacy Statement, for example the personal data’s elaboration aim, the Holder’s identity or the users’ rights.

Bassano del Grappa (VI), 24^th May 2018

Manzoni America