Privacy policy

Our customers expect a high level of quality not only from our products and services related to our high-quality olive oils, but also in the processing of their personal data. This privacy policy is intended to inform our customers and other website visitors about how we process their personal data. 

We, Frantoio del Trasimeno SRL, Loc. Buttinale 73, 06060 Paciano, Italy (hereinafter: BUTTINALE 73, we, us), are responsible for handling your data, which we process in accordance with the requirements of EU data protection laws. Your personal data shall only be processed by us if this is permitted by a legal provision. 

In addition to the above postal address, you can also reach us by email at info@buttinale73.com.

Personal data is all information relating to an identified or identifiable natural person (Art. 4(1) GDPR). This includes, for example, data that you provide to us when using our website or communicating with us, such as your address data, registration data, telecommunications data, order data or financial data, but also data that is automatically collected when you use our website, such as your IP address.

In order to be able to conduct a specialised operation, we have to use various service providers. Our service providers include data centres, postal service providers, forwarding companies, telephone service providers, internet service providers, website service providers, printers, lettershops, document shredders, payment service providers or credit institutions, debt collection companies and tax and legal advisors. To the extent necessary and within the scope of what is legally permitted, they may receive your data within the scope of subsequent data processing as a data processor (Art. 28 GDPR) or as their own data controller (Art. 24 GDPR) (legal basis(s): points (b) and (f) of Art. 6(1) GDPR), depending on the individual case. Please also note the service providers mentioned below.

We take technical and organisational security precautions to protect your personal data against accidental or intentional manipulation, loss, destruction or against access by unauthorised persons and to ensure the protection of your rights and compliance with the applicable data protection regulations. 

The measures taken are intended, among other things, to ensure the confidentiality, integrity, availability and resilience of the systems and services related to the processing of your data on a permanent basis and to restore them quickly in the event of a physical or technical incident. 

Our data processing and security measures are continuously improved in line with technological developments. 

Our employees are, of course, obliged to maintain confidentiality and to comply with the data protection requirements of the GDPR.

If certain data fields are designated as mandatory information or mandatory fields and marked with an asterisk ( * ), the provision of this data is required by law or contract, or is necessary for the conclusion of the contract, the desired service or the stated purpose. Any provision of this is at your discretion. Failure to do so may result in the contract not being performed by us or the requested service not being provided or the stated purpose not being achieved.

We process the data you provide, for example, in telephone calls, via contact forms, email or postal enquiries or correspondence, initially to respond to your enquiries (legal basis(s): points (f) and (b) of Art. 6(1) GDPR). This is usually done with our interest in providing a good service or working reliably. Any information that we designate as mandatory (e.g. in data entry fields) is required in order to be able to contact you or communicate with you about your request. The voluntary provision of further data makes it easier for us to communicate with you. 

We usually store your data that has been processed for these purposes for six months after responding to the general enquiry in case of further enquiries, unless they are documents that we are obliged to retain for a longer period (legal basis: point (c) of Art. 6(1) GDPR) or unless we are obliged or entitled to retain them for a longer period for other reasons (legal basis: points (c) and (f) of Art. 6(1) GDPR, legitimate interest: Defence of our rights).

We process the required registration data as well as the data you provide in this context to set up and use our password-protected online area and its functionalities (legal basis: points (b) and (f) of Art. 6(1) GDPR). Insofar as data is processed on the legal basis of legitimate interest, this is to provide the best possible functionalities. 

You can close your customer account at any time by sending us a short message by email or post (for contact details, see Section 1 above). We store your registration data for your customer account until you cancel your access, provided that there are no other retention periods.

When you place an order, we process your order, address, communication and payment data primarily for the purpose of processing your orders, delivering the goods and processing payments (legal basis(s): points (b) and (f) of Art. 6(1) GDPR) in order to fulfil contracts or provide you with a good service. Insofar as information is marked as mandatory, it is required for the processing or handling of the corresponding contract or for invoicing or payment processing. Orders can also be placed without creating and using a customer account (Section 8.). 

When you place an order, our payment service providers or credit institutions (e.g. PayPal, Visa, Mastercard) receive your data, which are necessary for the processing of the payment. However, these then each act as their own data controller. 

We store your contractual data relevant to the order and the associated documents in accordance with the statutory limitation periods or in accordance with the legal requirements after the conclusion of the contract (legal basis: point (c) of Art. 6(1) GDPR).

a. Customer analyses and mail advertising 
 We process your personal data from orders for shopping basket and target group analyses to determine offers that are as suitable for you as possible and to send you advertising by post about our online shop (legal basis: point (f) of Art. 6(1) GDPR). Data processed for promotional purposes shall be kept as long as the promotional purpose continues or until you object to the processing for promotional purposes. Information on your existing right to object at any time can be found in Section 9.c below.

b. Email advertising (newsletter) 
 With your express consent, which can be revoked at any time for the future, we will inform you by email about advertising within the scope of the consent you have given (legal basis: point (a) of Art. 6(1) GDPR). We process the mandatory information you provide when you give your consent in order to send you promotional messages and to address you personally. 

In order to obtain your consent to email advertising, we use the double opt-in procedure online to avoid sending advertising messages to email addresses of people who have not requested them. For this purpose, after consent has been granted, an email will be sent with a request to confirm the granting of consent. You are only registered to receive email advertisements after your confirmation. Your IP address is also recorded and stored for documentation purposes. (Legal basis: Art. 7(1), point (c) of Art. 6(1) GDPR). 

Data processed for promotional purposes shall be kept as long as the promotional purpose continues or until you object to the processing for promotional purposes or withdraw your consent. Information on your existing right to object and right of cancellation at any time can be found in Section 9.c below.

c. Right of objection/cancellation in relation to advertising 
If you wish to withdraw your consent or object to the processing of your personal data for advertising purposes or on the basis of your particular situation, simply send a message at any time to the contact details given above (Section 1.). Your data shall then no longer be processed for the advertising purposes covered by the consent or objection. The legality of the processing carried out until the objection remains unaffected by this. 

After you have objected to the processing of your personal data for advertising purposes, the contact data required for this purpose shall be included in an internal advertising blacklist and permanently stored (blocked) - for this purpose only - and used for comparison with our future advertising files (legal basis: Art. 21(3), point (b) of Art. 17(3), point (c) of Art. 6(1) GDPR). This ensures that your advertising objection is permanently respected.

When you access our website, you transmit data to our web server (out of technical necessity) via your internet browser. The following data is processed during an ongoing session to enable communication between your internet browser and our web server (legal basis: point (f) of Art. 6(1) GDPR): 
  •  Content of the request (page, name of the requested file, etc.), 
  •  Date and time of the request, 
  •  Data volume transferred, 
  •  Access status (file transferred, file not found, etc.), 
  •  Time zone difference to Greenwich Mean Time (GMT), 
  •  Source/reference from which you came to the page, 
  •  Web browser(s) and operating system used, 
  •  IP address. 

Temporary storage or processing of this server log data is necessary to ensure the functionality and technical security of the website, in particular to prevent and defend against attempts to attack or damage the website, and is carried out in our legitimate interest (legal basis: point (f) of Art. 6(1) GDPR). 

The data shall no longer be processed on a personal basis (i.e. shall be anonymised) as soon as they are no longer necessary to achieve the purpose for which they were collected. In principle, data is anonymised or deleted by shortening the IP address unless it has to be retained for longer for documentation purposes (e.g. to document consent given, see Section 9 above, legal basis: point (c) of Art. 6(1), Art. 5(2), Art. 7(1) GDPR).

a. Cookies 
 Cookies are small text files that are transferred to your end device (e.g. PC, tablet, smartphone) via your web browser or other programs. These are stored locally on your end device and kept ready for later retrieval. Other technical measures are HTML storage, Pixel or tags such as web beacons, iframes, images or scripts. The cookies and technical measures, which we refer to collectively as "cookies" below, may be used on our website for the purposes described below. Personal data such as your IP address may be processed in the process (see below).

On this website, cookies may be used or read, among other things, and data may be processed in the process, 
  •  that are absolutely necessary to enable the functions of our website and to be able to offer them securely (necessary) (points (b) and (f) of Art. 6(1) GDPR, for Germany: § 25 para. 2 no. 2 TTDSG), 
  •  in order to provide extended functionalities (necessary) (point (f) of Art. 6(1) GDPR, for Germany: § 25 para. 1 TTDSG), 
  •  in order to evaluate visits to our website (performance), to make our website more user-friendly and to better adapt it to your needs or to measure the success of our external advertisements and to track pages of origin (referrers) (point (a) of Art. 6(1) GDPR, for Germany: § 25 para. 1 TTDSG), 
  •  in order to evaluate visits to our website so that we can display the most interesting offers possible to you on websites and in apps in associated advertising cooperations (advertising) (point (a) of Art. 6(1) GDPR, for Germany: § 25 para. 1 TTDSG), 
  •  in order to identify objections to the use of certain cookies and technologies ("opt-out" cookies) (point (f) of Art. 6(1) GDPR, for Germany: § 25 para. 2 no. 2 TTDSG) and 
  •  in order to identify the granting and refusal of consent ("opt-in" cookie) (point (f) of Art. 6(1) GDPR, for Germany: § 25 para. 2 no. 2 TTDSG). Under certain conditions, cookies from third-party providers may also be used and read (legal basis: point (a) of Art. 6(1) GDPR). In particular, the third-party providers want to be able to identify your end device on other websites and offer you suitable advertisements. 

The cookies and other technical measures may originate from us, our service providers and external third party providers and may also be used by them - if applicable - for their own purposes (see also Section 12 below and the corresponding data processing). In our Consent Management Tool you will find further details on the cookies used, such as their duration and specific purposes of use. You also have the option of managing your cookie settings here. 

For the management of cookies, we use the Consent Management Tool of our service provider Digital Data Solutions B.V. (CookieFirst), Plantage Middenlaan 42a, 1018DH, Amsterdam, The Netherlands ("CookieFirst"), primarily to obtain your consent or refusal to the storage of certain cookies and other technical measures on your end device and to document this in accordance with data protection law (points (b) and (f) of Art. 6(1) GDPR, for Germany: § 25 para. 2 no. 2 TTDSG). When you visit our website, the following personal data is transmitted to CookieFirst for technically necessary reasons: Your consent status, your anonymised IP address, time of consent, user agent, URL where consent was given and a random and encrypted key value. During this process, necessary cookies for saving the consent status can also be saved. We have concluded a data processing contract with our service provider CookieFirst in accordance with Art. 28 GDPR. 

Insofar as data processing takes place on the basis of a legitimate interest, this shall be to provide an interesting and secure website or to facilitate compliance with applicable data protection regulations.

c. Granting and revoking consent / settings via the browser 
(1) You can give your consent via our Consent Management Tool (see above, accessible via the "Cookies" link in the footer) or revoke it at any time, in each case also partially. 

Your consent also includes the processing of data outside the European Economic Area (point (a) of Art.49(1) GDPR), where there may not be a comparable level of data protection, e.g. in the USA. With regard to the USA, there is a particular risk that your data may be processed by American authorities for surveillance purposes, possibly also without enforceability of your rights and corresponding legal remedies. Insofar as data processing is also planned in a third country (USA) for the tools used on our website, this shall be indicated in the Consent Management Tool or below (Section 12). 

(2) You can also set your web browser so that it notifies you when cookies are set, generally rejects cookies, restricts their setting or deletes them. However, if you refuse or restrict the setting of cookies using your browser, you will no longer be able to use various functions on our website. You can delete stored cookies at any time using your web browser, even automatically. 
 
By deleting the cookies, you can also revoke your consent as described above. 
 
Use the following links to find out about the setting options for the most common browsers:

Depending on the service provider, data may be transferred to third countries. If there is no European Commission adequacy decision for these countries, we have concluded standard contractual clauses with the respective service provider as suitable guarantees in accordance with Art. 46 GDPR. 


 a. Performance 

 (1) Google Analytics This website uses Google Analytics, a web analytics service provided by our service provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Analytics uses cookies that allow us to evaluate your visits to our website and to generate reports about our online advertising campaigns. The information generated by the cookies about your use of our website may be transmitted to a Google server in the USA and stored there. Further information on cookies, their functions and their duration (max. one week) can be found here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage 


Through the IP anonymisation activated on our website, your IP address will be shortened and thus anonymised by Google beforehand within the Member States of the European Union or other signatories to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. 


On our behalf, Google uses this information to evaluate your visits to our website, to compile reports on website activity and to provide us with other services relating to website activity and internet usage in order to make our website more user-friendly and better meet your needs. Google Analytics is only used on our website with your express consent, which can be revoked at any time (point (a) of Art. 6(1) GDPR, for Germany: § 25 para. 1 TTDSG). 


You can individually prevent the collection of the data generated by the cookie and related to your use of the website (including your shortened IP address) as well as the processing of this data by Google - regardless of whether you have given your consent in the Consent Management Tool - by downloading and installing the browser add-on available at the following link https://tools.google.com/dlpage/gaoptout. Alternatively, it is of course generally possible at any time not to give your consent or to revoke any consent you have given via our Cookie Management Tool as described above (Section 11.c.) (this applies in particular to end devices that do not permit installation of the browser add-on, e.g. smartphones).


(2) Google Ads 

This website also uses "Google Ads", a tool provided by our service provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). With the help of advertisements (graphics, texts) on external websites or in Google's search engines, we want to draw attention to our offers. The ads are delivered by Google. If you click on any such advertisement (and thereby reach our website), a cookie originating from Google (AdSense cookie) will be placed on your end device, which will then be read and analysed for us with your consent – given on our website. This is intended to measure the success of a specific advertisement. We can assess this on the basis of corresponding statistics, which are provided for us by Google for this purpose (point (a) of Art. 6(1) GDPR, for Germany: § 25 para. 1 TTDSG). 


You can find more information on data protection at Google and how Google handles your data at https://policies.google.com/privacy and https://policies.google.com/technologies/ads, including possible data processing in the USA. 

 

When you visit a particular page of our website, we are able to recognise that you have clicked on a particular Google ad or have been redirected to our website for the duration of the cookie's validity. However, this does not allow us to directly identify you personally. If you click on several ads, several cookies can of course be set accordingly. 


If you no longer wish to use these tools, namely the described evaluations/measurements, on our website after you have given your consent, you can revoke any consent you have given via our Consent Management Tool at any time as described above (Section 11.c.) or also delete the above-mentioned cookie accordingly. You can adjust your advertising settings on Google at https://adssettings.google.com.


(3) Google Tag Manager 

This website also uses "Google Tag Manager", a tool provided by our service provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). 


Google Tag Manager is a control and management tool for our website tags (performance and advertising tools). Cookies may also be used for this purpose for the respective function (point (a) of Art. 6(1) GDPR, for Germany: § 25 para. 1 TTDSG). You can find more information on this in our Cookie Management Tool and at https://support.google.com/tagmanager/answer/7157428?hl=de. You can find information on data protection at Google and how Google handles your data at https://policies.google.com/privacy, including possible data processing in the USA. 


If you no longer wish to use these tools on our website after you have given your consent, you can revoke any consent you have given via our Consent Management Tool at any time as described above (Section 11.c.) or delete the cookies accordingly. 

 

b. Advertising (retargeting) 

The use of our website is evaluated with your consent, which can be revoked at any time for the future, in order to use the "Custom Audience" function of our service provider Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Meta") (point (a) of Art. 6(1) GDPR, for Germany: § 25 para. 1 TTDSG). This allows a direct connection to be established between your browser and Meta's servers via the Facebook Pixel, and Meta thereby receives the information that you have visited our site with your IP address. This means that Meta can later also assign the visit to our website to a Meta product. 


Pixels are a section of code that is implemented on our website. Cookies may also be used for this purpose for the respective function. Personal details (name, email address, etc.) will never be transmitted by us under any circumstances. You can find more information on this in our Cookie Management Tool. 

 

You can revoke any consent you have given via our Cookie Management Tool at any time as described above (Section 11.c.). 


For further information, in particular on data processing by Meta, please refer to Meta's privacy policy at https://www.facebook.com/privacy/policy 


The following link will provide you with information on how to change your settings for personalised advertising on Facebook: https://de-de.facebook.com/help/1075880512458213/?helpref=hc_fnav 


Alternatively, you may also deactivate the technologies on the Digital Advertising Alliance website at the following link: www.aboutads.info/choices/ 

If you have any questions about the processing of your personal data by us, we would of course be happy to provide you with information about the data concerning you (Art. 15 GDPR). In addition, you have the right to rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and objection (Art. 21 GDPR) if the legal requirements are met. You also have the right to data portability (Art. 20 GDPR) 

 

In any of these cases, please contact us at the above-mentioned communication addresses (Section 1). 


Lastly, you also have the right to lodge a complaint with the competent data protection authority (Art. 77 GDPR).

From time to time, it is necessary to adjust the content of this privacy notice. We therefore reserve the right to change it at any time in the future. We will also publish the amended version of the privacy policy here. When you visit us again, you should therefore read the privacy policy again. 

Dated: March 2022