PRIVACY AND COOKIES POLICY

For AEB S.p.A. the protection of personal data is of primary importance and guarantees that the processing of personal data carried out in the performance of its activities is carried out in compliance with the rights of the person concerned, with particular reference to confidentiality, the protection of personal identity and the right to protection of personal data.

AEB S.p.A. undertakes to follow the following general principles:

• all data are processed in a lawful, correct and transparent manner towards the person concerned, in compliance with the principles set out in EU Regulation 2016/679 (hereinafter GDPR) and current legislation on the protection of personal data;
• personal data are processed only for the purposes indicated in this Policy;
• we aim to collect, process and use as little personal data as possible;
• if the personal data we collect is no longer necessary for any purpose and we are not required to retain it by law, we will do everything possible to delete, destroy or anonymize it;
• specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access;
• personal data will not be shared, sold, made available or communicated to parties other than those indicated in the Information.

This Policy describes the methods of processing personal data of:

• Visitors/users of the website www.aeb-group.com, acquired - independently or through third parties - through the website itself;
• Candidates for positions through applications collected on this website or through other channels;
• Customers of AEB Group in the context of existing business relations;
• Suppliers of AEB Group in the context of existing contractual relations.

The Data Controller is AEB S.p.A., with registered office in San Polo, Brescia, via Arici 104 (VAT no. 04015140967) and can be contacted at the following addresses: Tel: +3903023071, Fax: +390302307281, email: privacy@aeb-group.com where you can contact for any question relating to this Policy or the processing of personal data, and to exercise all rights under the GDPR.

3. PROCESSING OF PERSONAL DATA OF VISITORS AND USERS OF THE WEBSITE

The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of data includes IP addresses or domain names of computers and terminals used by users, URI/URL addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters relating to the operating system and computer environment.

These data, necessary for the use of web services, are also processed for the purpose of:

• obtain statistical information on the use of the services (most visited pages, number of visitors per time slot or day, geographical areas of origin, etc.);
• check the correct functioning of the services offered.

The navigation data do not persist for a time exceeding the needs of operation and are deleted immediately after their aggregation, except for any need to ascertain crimes by the judicial authority.

Some personal data, provided voluntarily, may be collected using special forms on the site:

• From the Contact us form we collect personal contact data, for the purpose of responding to requests for information about our products, requests for commercial information, administrative, transparency, or to respond to a complaint.

   

• From the Work with us form we collect personal contact information, and additional data contained in the curriculum of the candidate.

• From the Newsletter form, which allows you to subscribe to the newsletter that offers news, initiatives and events of the AEB Group. Registration is subject to specific, free and informed consent. The data are kept until the possible unsubscription of the newsletter service, freely available at any time through the link at the bottom of every message sent. These data may be used to send the user communications, including commercial ones, relating to the AEB Group Services and Products to which the user has expressed interest.

The data are kept for a period of time compatible with the purpose of the collection.

The User may or may not provide personal data in the above forms or by sending a request for information to the Site by e-mail. Refusal to provide the data will make it impossible to obtain the requested service. The data are kept for a time compatible with the purpose of collection.

In order to make its services as efficient and simple as possible to use, this Site makes use of cookies. Therefore, when you visit the Site, a minimum amount of information is entered into your device, in the form of small text files called "cookies", which are stored in the directory of your web browser. There are different types of cookies, but basically the main purpose of a cookie is to make the Site work more effectively and to enable certain features.

Cookie Settings

This Website uses Cookies to save your browsing preferences and optimise your browsing experience.

These cookies include, for example, those for setting the language or for managing statistics by the Site Owner.

This website uses Google Analytics

to collect information about your use of the website.

To consult the privacy policy of the company Google, relating to the service Google Analytics, please visit https://www.google.com/intl/en/analytics/privacyoverview.html

To learn more about Google's privacy policy, please visit https://policies.google.com/privacy?hl=en

You can disable Google Analytics cookies by downloading a specific browser plug-in at the following URL: https://tools.google.com/dlpage/gaoptout?hl=en

This type of service allows you to interact with live chat platforms, operated by third parties, directly from the pages of this Website. This allows the User to contact AEB staff to request more information about products or services, or AEB staff to contact the User while browsing the pages of this website.

If a service of interaction with live chat platforms is installed, it is possible that, even if the Users do not use the service, the same collects Usage Data relating to the pages in which it is installed. In addition, live chat conversations may be recorded.

Widget di Tawk.to (tawk.to ltd.)

The Tawk.to widget is an interaction service with the Tawk.to live chat platform, provided by tawk.to ltd.

Personal Data Collected: Cookies and Usage Data.

Place of processing: United Kingdom – Privacy Policy

By registering for the mailing list or newsletter, the User's email address is automatically included in a list of contacts to which email messages containing information, including commercial and promotional information relating to this Web Site, may be transmitted.

The User's email address is collected through the Mailchimp service.

This type of service allows to manage a database of email contacts, telephone contacts or any other type of contact used to communicate with the User.

These services may also allow to collect data relating to the date and time of display of messages by the User, as well as the User's interaction with them, such as information on clicks on links in messages.

Mailchimp (The Rocket Science Group, LLC.)

Mailchimp is an email address and message management service provided by The Rocket Science Group, LLC.

Personal Data Collected: Last Name; Email; First Name.

Place of Processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.

This type of service enables this Web Site and its partners to communicate, optimize and serve advertisements based on the User's past use of this Web Site.

This activity is carried out through the tracking of Usage Data and the use of Cookies, information that is transferred to partners to whom the activity of remarketing and behavioural targeting is linked.

In addition to the opt-out options offered by the following services, you may opt out of receiving cookies relating to a third-party service by visiting the opt-out page of the Network Advertising Initiative.

Remarketing Google Ads (Google LLC)

Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google LLC that links the activity of this Website with the advertising network Google Ads and the DoubleClick Cookie. Users may choose not to use Google cookies for ad customization by visiting Google Ads Settings.

Personal Data Collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

You can oppose the registration of cookies on your hard disk by configuring your browser (Internet Explorer, Mozilla Firefox, Opera, Safari etc. ...) to disable cookies.

After this operation, however, some functions of the web pages may not be performed correctly.

The provision of data is mandatory for all that is required by legal and contractual obligations and therefore any refusal to provide them in whole or in part may make it impossible to provide the services requested. The company processes users' optional data on the basis of their consent, i.e. through the explicit approval of this privacy policy and in relation to the methods and purposes described above.

The Holder shall take appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data. The processing is carried out by computer and/or telematic means, with organizational methods and with logic strictly related to the purposes indicated.

The data are processed at the operating sites according to which the Company is organized, and at companies appointed and duly appointed as data processors. The data will not be transferred outside the European Union. In any case, it is understood that the Owner, if necessary, will have the right to move the location of the servers in non-EU countries. In this case, the Data Controller hereby guarantees that the data will be transferred in accordance with the applicable legal provisions and, if necessary, enters into agreements guaranteeing an adequate level of protection.

The data treatment will be processed for the time strictly necessary to achieve the purposes referred to above, without prejudice to any periods of retention provided for by law.

The collected personal data of the Users may be communicated to companies that provide the services available on the Site. Some data may be communicated anonymously and aggregated to companies of the group or third parties for statistical purposes. Personal data may also be shared when required by law and/or government authorities. Except in cases explicitly permitted by law, or provided for in this Policy, personal data will not be communicated or shared without the consent of the user concerned.

4. PROCESSING OF PERSONAL DATA OF CANDIDATES FOR THE ESTABLISHMENT OF EMPLOYMENT RELATIONSHIPS

AEB S.p.A. processes personal data of candidates for the establishment of employment relationships, provided voluntarily, which can be collected through the Work with us Form from the website www.aeb-group.com, or through direct communications, by e-mail, regular mail or other channels.

AEB S.p.A. processes the data provided by the candidates in order to establish a working relationship. The personal data processed are identification data (such as name, surname, gender, date and place of birth and residence, citizenship, tax code, photo and activity) and contact data (such as address, telephone numbers, e-mail), as well as any other information contained in the curriculum or that the candidate communicates to AEB Group for the purposes mentioned above.

This processing of such personal data is for the purpose of evaluating the candidate in view of the possible establishment of an employment relationship with AEB Group In the absence of such data, this evaluation cannot be carried out and, therefore, any employment relationship cannot be established.

The applications collected in the Internship section of the website www.aeb-group.com

allow the candidate looking for an internship in the wine, beer and food & beverage sector, to get in touch with the companies that propose them, through the publication of his/her profile.

AEB S.p.A. processes the personal contact data and the data contained in the curricula provided spontaneously by the candidates in order to put them in contact with companies looking for collaborators.

The candidate who sends his/her curriculum vitae to submit his/her professional application is solely responsible for the relevance and accuracy of the data sent.

The legal basis of the treatment is the need to meet the request for examination of the application that the person concerned manifests, even implicitly through the simple sending of his/her curriculum vitae and/or letter of presentation or other communication of similar content, for the purpose of the possible establishment of an employment relationship. In addition, once the application has been received, this processing and the storage of personal data referred to in the application may take place in order to pursue the legitimate interest of the data controller in the performance of subsequent selection activities, or activities relating to the proposal of internships also by companies of the AEB Group or its customers.

The Data Controller shall take appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of personal data. The processing is carried out by means of computer, telematic and paper tools, with organizational methods and with logic strictly related to the purposes indicated.

The data are processed at the operating sites according to which the Company is organized, and at companies appointed and duly appointed as data processors. The data will not be transferred outside the European Union. In any case, it is understood that the Owner, if necessary, will have the right to move the location of the servers in non-EU countries. In this case, the Data Controller hereby guarantees that the data will be transferred in accordance with the applicable legal provisions and, if necessary, enters into agreements guaranteeing an adequate level of protection.

The data will be processed for the time strictly necessary to achieve the above purposes.

The collected personal data of the Users may be communicated to companies of the AEB Group, to companies that are customers of AEB Group that offer internships in the 'Internship' section of the AEB website, companies that provide services related to the purposes of processing. Personal data may also be shared when required by law and/or government authorities. Except in cases explicitly permitted by law, or provided for in this Policy, personal data will not be communicated or shared without the consent of the user concerned.

5. PROCESSING OF CUSTOMERS' PERSONAL DATA

AEB S.p.A. may process personal data of customers for the purpose of providing the products and services requested. The personal data processed are identification and contact data (such as address, telephone numbers, e-mail).

This processing of such personal data is for the purpose of fulfilling contractual obligations and the law and is therefore necessary for the provision of the services requested.

AEB S.p.A. may also process the data indicated above for the performance of customer satisfaction surveys and for direct marketing purposes addressed to its customers, who are guaranteed the right to object to such processing at any time and free of charge. In case of opposition, the customer's personal data will no longer be processed for these purposes.

The legal basis for the treatment itself is therefore::

• the fulfilment of legal obligations, for the purposes of the performance of a contract as well as for the purposes of meeting the requests of the person concerned;
• the legitimate interest of the data controller in carrying out customer satisfaction surveys and direct marketing initiatives towards its customers, in view of the relationship established with them and the protection of the rights and fundamental freedoms of the same also guaranteed through the right of opposition mentioned above.

The Data Controller shall take appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of personal data. The processing is carried out by means of computer, telematic and paper tools, with organizational methods and with logic strictly related to the purposes indicated.

The data are processed at the operating sites according to which the Company is organized, and at companies appointed and duly appointed as data processors. The data will not be transferred outside the European Union. In any case, it is understood that the Owner, if necessary, will have the right to move the location of the servers in non-EU countries. In this case, the Data Controller hereby guarantees that the data will be transferred in accordance with the applicable legal provisions and, if necessary, enters into agreements guaranteeing an adequate level of protection.

The data will be processed for the time strictly necessary to achieve the above purposes

The collected personal data of the Users may be communicated to companies of the AEB Group and to companies that provide services related to the purposes of processing. Personal data may also be shared when required by law and/or government authorities. Except in cases explicitly permitted by law, or provided for in this Policy, personal data will not be communicated or shared without the consent of the user concerned.

6. PROCESSING OF PERSONAL DATA OF SUPPLIERS

AEB S.p.A. may process certain personal data concerning the supplier, if a natural person, and/or the workers and collaborators of the supplier himself (in the latter case even if the supplier is a legal person) for the purpose of concluding and executing contracts with the suppliers themselves.

AEB S.p.A. makes every effort to make this information known to each interested natural person indicated above, primarily through the publication of this document on its website. However, it should be noted that the communication of the information in question to all interested parties and, in particular, to each worker and collaborator of each of its suppliers in relation to whom it receives or collects personal data, would imply a disproportionate effort for AEB S.p.A. or, in some cases, could even be impossible. In view of the above, the supplier of AEB Group communicates and disseminates this information to any interested parties involved in the processing described above, i.e. to its Workers and Collaborators (however called, including in the definition also all natural persons whose data may still be communicated to AEB Group. or known by it for the stipulation and execution of the supply contract) with all appropriate means.

The personal data processed are the identification and contact data (such as address, telephone numbers, e-mail) concerning the supplier and/or its Workers and Collaborators and which they may communicate to AEB Group as part of the normal activities that characterise the supply relationships that have been or are intended to be established.

The processing of such personal data has the purpose of stipulating or executing supply contracts and is functional to the achievement of the same. In the absence of such data, it may not be possible to establish or execute the contracts correctly.

The legal basis for the processing itself is, therefore, the conduct of pre-contractual negotiations in agreement with the supplier or the fulfilment of the supply contract with the same or legal obligations.

The legal basis for the processing itself is, therefore, the conduct of pre-contractual negotiations in agreement with the supplier or the performance of the supply contract with the same or legal obligations.

The Data Controller shall take appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of personal data. The processing is carried out by means of computer, telematic and paper tools, with organizational methods and with logic strictly related to the purposes indicated.

The data are processed at the operating sites according to which the Company is organized, and at companies appointed and duly appointed as data processors. The data will not be transferred outside the European Union. In any case, it is understood that the Owner, if necessary, will have the right to move the location of the servers in non-EU countries. In this case, the Data Controller hereby guarantees that the data will be transferred in accordance with the applicable legal provisions and, if necessary, enters into agreements guaranteeing an adequate level of protection.

The data will be processed for the time strictly necessary to achieve the above purposes.

The collected personal data of the suppliers may be communicated to companies of the AEB Group and to companies that provide services related to the purposes of processing. Personal data may also be shared when required by law and/or government authorities. Except in cases explicitly permitted by law, or provided for in this Policy, personal data will not be communicated or shared without the consent of the user concerned.

The data subject, i.e. the natural person to whom the personal data refer, has the right to request from the Data Controller access to his/her personal data, rectification or erasure thereof, as well as to request limitation or object to their processing. The data subject also has the right to data portability. To exercise these rights, please refer to the contacts indicated in this information sheet.

All requests received will be processed and verified in accordance with the applicable regulations, also with reference to the actual existence of the conditions for their acceptance. In the absence of such existence, the Data Controller may not comply with the requests. The Data Controller shall make every effort to respond to legitimate and well-founded requests within one month of their receipt. Depending on the complexity and number of requests, as well as the above, this period may be extended by two months. Once the request has been processed and the request has been rejected, the data subject may lodge a complaint with the supervisory authority at https://www.garanteprivacy.it/home_en and lodge an appeal with the courts.

This Information Notice was updated on 12/11/2019, and may be subject to periodic review, in relation to changes relating to the treatments made and to the legislation and jurisprudence of reference.