PRIVACY POLICY

Information notice

This information notice is issued pursuant to art. 13 of Italian Legislative Decree (D.Lgs.) no. 196/2003 (Personal Data Protection Code – hereinafter referred to as the “Code”) to anyone using the web services of S.r.l. (“”), accessible at the address www.drink.com (“Website”) and concerns all personal data collected and retained by concerning its users and their accounts. It does not apply to any data collected by other websites which may be consulted by users via links to external third party pages.

“Personal Data” refers to any information concerning an identified or identifiable physical person, even indirectly, by reference to any other information (art 4., lett. b of the Code).

may amend, integrate or periodically update this Information Notice, also in consideration of any amendments to the applicable laws or orders issued by the Data Protection Authority. Amendments or updates to the Information Notice shall be applied and notified to the persons concerned as soon as they are adopted, via a link to the link to the Privacy Policy in the Website footer. Consequently, all users concerned are invited to regularly access the Website to check the updated version of the Information Notice.

Personal data processed

The personal data processed by (“Data Processing”) is data (i) provided directly by the person concerned; (ii) provided by third parties; (iii) collected automatically.

i) The data provided directly by the person concerned is any personal data entered in the Website (to surf the site, purchase items on-line or for any other reason) or in any case provided to in any means. All persons concerned, within legal limits, can decide to not consent to the processing of all or part of their data, even though such exclusion could limit or exclude the use of part of the services provided by Memento. Examples of data provided directly by the persons concerned include: name; address and telephone number; credit card data (processed exclusively for the time required for the purchase transaction); the names of the order recipients, where not the purchaser. More generally, all data provided for the purposes of purchasing on-line, product searches on the Website, filling in and using a profile on the Website, facilitation of deliveries through the provision of contact data (e.g. telephone, e-mail, addresses), etc.

ii) Data provided by third parties refers to all personal data collected by from other sources (postal services, couriers, data entry companies, etc.) in order to provide its services. Also in this case, all persons concerned, within legal limits, can decide to not consent to the processing of all or part of their data, even though such exclusion could limit or exclude the use of part of the services provided by Memento. Examples of data provided by third parties refer to data concerning updates or corrections received following deliveries by couriers or shipping partners or third parties, data on the web pages visited which we may receive from other commercial operators with which Memento may collaborate for certain initiatives, etc.

iii) Data collected automatically is navigation data and/or so-called “cookies”. During normal operation, the computer systems and software procedures for the operation of this Website acquire some personal data which is implicitly transmitted in the use of Inter communication protocols. Generally, this information is not collected in order to be associated to the identified persons, but which by its very nature could, if processed and associated to data held by third parties, lead to the identification of the users. This category of data includes the IP addresses or domain names of the computers used by users connecting to the Website, the URI

(Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the state of the reply given by the server (OK, error, etc.) and other parameters concerning the user’s operating system and computer environment. This data is used principally to gather statistical information on the use of the website and to check that it is working correctly. Data may be used to ascertain responsibility in the case of hypothetical data processing crimes to the detriment of the website.

COOKIES

A cookie is a small text file sent by a website and stored in the user’s browser while using a Website. Cookies may be stored only for the time spent using a given website (session cookies) or for a longer period, independently from the session (persistent cookies). Cookies work in combination with the website contents and are normally used to improve the usability and navigation experience on the web. They allow Memento to know the contents viewed, the choices made and every use of the website by the users. This function also allows Memento to provide more useful and targeted advertising for each user. Memento may also collaborate with third party companies, using tracking technologies to provide advertising on the Inter. These companies may collect anonymous information on the visits to our Website.

To pursue the above-mentioned purposes, or for other purposes, the cookies collect and record navigation information, although the Memento policy leaves users the choice of whether to use these cookies or not. Consequently, if the users blocks or prevents the use of cookies, some Website functions may be blocked or slowed down or in any case may not be efficient.

In addition to ensuring the smooth use of the Website, Memento uses cookies for other purposes, including:
(i) identify users when logging on to the Website; (ii) store the products saved in the cart ready for purchasing; (iii) prevent the fraudulent use of accounts or payments; (iv) where authorised, support user profiling and therefore provide information on products of interest or other customised contents and offers; (v) where authorised, provide promotions, contents, advertising, linked to users and their preferences and to remind them of such preferences; (vi) perform market research; (vii) improve the Website, the Memento product range and marketing, etc.

Currently, the Website uses the following types of cookies with the functions indicated below, which users can enable or disable in the “Cookie settings“ section at the bottom of every page of the Website.

TECHNICAL COOKIES

These cookies are required for navigation as they ensure the correct use and full functionality of the Website. They include cookies used for creating a customised account, logging in, viewing contents in the chosen language on each access, recognising the country from which the user connects to the Website (and remembering these settings for future accesses) and managing orders. These cookies are strictly necessary for the operation of the Website and if disabled may compromise the navigation experience and results.
This category includes analytical cookies, which through computer systems ensure the statistical analysis of users’ navigation of the Website, solely to understand how users use the Website. They include for example cookies recording the number of clicks on a page of the Website and the number of pages visited by users. These analyses are performed on aggregated, anonymous data solely for statistical purposes. They are not indispensable for the operation of the Website but as they are processed anonymously they do not prejudice the interests of the data owners.

NON-TECHNICAL COOKIES

This category includes the following types of cookies:

Cookies functional to the use of the website: they allow Memento to facilitate and improve the use of the Website by users. They are used to recognise users each time they access the Website (where users have so requested by enabling the “Recognise me next time” function), avoiding the need to re-enter data for each new navigation session or remembering (for a set time) goods placed in the cart on previous accesses if the purchasing process was not completed on that occasion. They are not indispensable for navigation but aim to facilitate and speed up the use of the Website.

Third party cookies for marketing/retargeting: third party cookies used to collect information on the user to offer more specific and/or customised promotions to users. They include cookies relating to the insertion of advertising banners of third party companies, products chosen or viewed by users, or similar products, on the Website. These cookies do not necessarily require the processing of personal data and can be disabled without impeding the correct navigation of the Website, however by disabling them users may receive promotional messages that are of no interest to them.

How can I disable the cookies?

Generally, in the browser settings almost all computers can inform users when a cookie is sent, thus allowing all cookies to be disabled. Please note that by fully disabling the cookies you may block many functions and not be able to correctly navigate or view the Website or other web pages.

PLACE AND METHODS OF DATA PROCESSING AND PARTIES TO WHOM THE DATA MAY BE DISCLOSED

The Data is generally processed at the registered office of Memento S.r.l.

Personal data is processed by Memento and/or by third parties who have been carefully selected for their reliability and competence, to whom such data may be disclosed where necessary and appropriate for performing even instrumental or accessory activities relating to the purposes of the Data Processing indicated in this Information Notice, mainly consisting in the supply of goods and services requested by the persons concerned (e.g.: postal services, couriers, data entry companies, etc.). In all other cases, unless required by law, the personal data will not be transferred and/or disclosed to third parties.

The personal data is collected in compliance with the obligations and guarantees provided for in the Code and are processed, mainly, using automated electronic and telematic tools, for the time strictly required to achieve the purposes for which it was collected. Specific security measures are taken to prevent the loss of data, unlawful or improper use and unauthorised access.

As soon as the personal data is no longer required for the purposes for which it was collected, Memento eliminates the data, unless obliged by law to store the data or if the user has consented to processing and storing the data for a longer time.
RIGHTS OF THE PARTIES CONCERNED

Pursuant to art. 7 of the Code, all users have the right to obtain confirmation of the existence or otherwise of their personal data, even if it has not yet been recorded, and its communication in an intelligible form.

In particular, all users have the right to obtain from Memento all information concerning: (i) the origin of their personal data; (ii) the purposes and methods of processing; (iii) the methods by which the electronic/computer instruments process the data; (iv) the details of the data controller and any appointed data processors; (v) the details of the parties and categories of parties to whom the data may be disclosed.

Moreover all users have the right to obtain from Memento the updating, correction and/or integration of their personal data and the cancellation of such data in the event of unlawful processing and/or in all other cases permitted by law, blocking the data processed in breach of the law.

Finally, all users have the right to oppose, fully or partly, the processing of their personal data, even where pertinent to the purpose for which it was collected, for legitimate reasons and for the purposes of sending advertising materials, direct sales and for market research purposes.

Requests concerning the previous points shall be sent by registered letter with advice of receipt or by e-mail to the Data Processor indicated in the following paragraph.

PROCESSING OF PERSONAL DATA ON MEMENTO

Requests concerning the previous points shall be sent by registered letter with advice of receipt or by e-mail to the Data Processor indicated in the following paragraph.

DATA CONTROLLER AND DATA PROCESSOR

The Data Controller is Memento S.r.l., with registered office in MILANO via Lodovico Muratori 46/9, 20135, Tax ID code / VAT Reg. No.: 09939940962.
The updated list of the Data Processors (where appointed) is available at the above-indicated registered office of Memento .

PURPOSES OF PROCESSING – OBLIGATORY OR OPTIONAL NATURE AND CONSEQUENCES OF ANY REFUSAL

The data is processed exclusively for the purposes for which it was collected, as described below. Memento mainly uses the data provided by the parties concerned to:

process orders and perform the connected activities (e.g.: communications with customers concerning the status of the order, responding to requests for information, managing payments, etc.);
manage the accounts of users registered with the Website in order to provide the relative services;
allow subscription to other specific services, such as newsletters for sending information on promotional offers and other information services, or to perform statistical activities and/or market research.

For all the above purposes, Memento may appoint external suppliers, who are provided only the data strictly necessary to perform the contracted services.

The provision of data for the purposes listed in points 1 and 2 above, which is necessary to be able to complete the sale and deliver the products and services purchased on the Website or to register with the Website, is obligatory

and any refusal to provide consent to Processing shall make it impossible to perform the services requested for the purchase of goods and services on the Website or to register with the Website.

The provision of data for the purposes described in point 3 (newsletter for promotional, information and research purposes) is optional and refusal to provide consent to such Processing will not in any case hinder any contractual relations with Memento for the provision of the services listed in points 1 and 2 above, but will make it impossible to update users on commercial initiatives and/or promotional campaigns, send offers or other promotional literature and/or send users customised offers. If such consent is given by selecting the “Subscribe to the Newsletter” box, Memento may send users advertising and promotional messages, using all contact details provided, in the limits of the provisions of the Code and without prejudice to the user’s right to deny consent to such use at any time, even in relation to only some of the contact details provided (opt‐out). You can opt out of receiving any marketing communications from us by using the unsubscribe-function at the end of the marketing e-mail.