Privacy Policy

Data ultimo aggiornamento: 16/02/2023

Data protection is a very serious matter for us, and we would like to inform you about the methods by which data is processed and the rights you can exercise under the current data protection regulations, in particular the EU Regulation 2016/679 (hereinafter referred to as “GDPR”). To view the cookies and any other tracking tools used by the Data Controller, please check the appropriate Cookie Policy in the website footer.

1. Data Controller

So.Di.Co. S.r.l.
Registered Office: Via Mascheroni Lorenzo n. 31, 20145, Milano (MI)
Operational Office: Via Foce Cesano 4/9, 60019, Senigallia (AN)
Email contact: privacy@sodico.it

2. Categories of processed data

The categories of “personal data” (as defined in Article 4.1 of the GDPR) processed by the Data Controller may include, but are not limited to: • Personal and identification data (such as name, surname, etc.); • Contact information (such as address, email address, telephone number, social media accounts, etc.); • Data related to any services provided, such as responses to inquiries about the products offered by the Data Controller.

3. Purposes and legal bases for the processing of personal data

3.1 urposes covered by the data subject’s consent (according to Article 6, paragraph 1 (a) of the GDPR)

Personal data may also be processed for specific purposes for which the data subject has given consent.

a. Responding to requests or inquiries made through the contact information provided on the website regarding the products, brands, and services provided by the Data Controller;

b. Carrying out advertising or promotional activities in the broadest sense (such as newsletters via email, SMS, various messaging systems, including instant messaging and internet, also to mobile phones);

c. Communication to other companies within the So.Di.Co. Group, operating in the personal care and well-being sectors (such as fragrances, dietary supplements, and cosmetics), for their respective marketing and promotional purposes, including the sending of advertising materials through automated contact methods (such as email, SMS, various messaging systems, including instant messaging and internet, also to mobile phones);

d. Profiling activities by the Group to which the Data Controller belongs (So.Di.Co. Group) operating in the personal care and well-being sectors (such as fragrances, dietary supplements, and cosmetics) to analyze or predict aspects related to the personal preferences, interests, behaviors, and commercial habits of the data subject, as well as market research and surveys in general. The retention period for personal data, regarding the purposes mentioned in this section, is: For purpose a: until the request is processed; For purposes b, c, d: 24 months from the collection of the last consent, unless revoked.

4. Recipients or categories of recipients of personal data (according to Article 13, paragraph 1 (e) of the GDPR)*

In the context of the aforementioned purposes, the Data Controller may disclose your data to:

• Offices and internal functions of the Data Controller itself;

• Companies belonging to the So.Di.Co. Group, affiliated or controlled;

• Companies and professional operators providing IT services, including electronic data processing, software management, website management, and IT consulting;

• Companies, agencies, and professionals in the field of communication and marketing;

* Public administrations, agencies, and public entities in the performance of their institutional tasks. More information about the Recipients (according to Article 4.9 of the GDPR) is available from the Data Controller at the above-mentioned contact details.

5. Recipients or categories of recipients of personal data (according to Article 13, paragraph 1 (f) of the GDPR) and transfer of data to non-EU countries

The Data Controller informs you that they have no intention to transfer your data to countries outside the EU and the EEA for the aforementioned purposes.

6. Rights of the data subject

Regarding the personal data subject to this Privacy Policy, the data subject has the right to exercise the rights provided by the EU Regulation as listed below:

• Right of access of the data subject [Article 15 of the EU Regulation] (which allows the data subject to be informed about the processing of their personal data and to obtain a copy of the data if applicable);

• Right to rectification of personal data [Article 16 of the EU Regulation] (the data subject has the right to request the rectification of inaccurate personal data concerning them);

• Right to erasure of personal data without undue delay (“right to be forgotten”) [Article 17 of the EU Regulation] (the data subject has the right to have their data deleted);

• Right to restriction of processing of personal data in cases specified in Article 18 of the EU Regulation, including cases of unlawful processing or the data subject contesting the accuracy of the personal data [Article 18 of the EU Regulation];

• Right to data portability [Article 20 of the EU Regulation] (the data subject can request their personal data in a structured, commonly used, and machine-readable format in order to transmit it to another data controller, in cases specified by the same article);

• Right to object to the processing of personal data [Article 21 of the EU Regulation] (the data subject has the right to object to the processing of their personal data in cases provided and regulated by Article 21 of the EU Regulation);

• Right not to be subject to automated decision-making [Article 22 of the EU Regulation] (the data subject has the right not to be subject to a decision based solely on automated processing). Regarding the purposes for which consent is required, the data subject may revoke their consent at any time, and the effects will be applied from the moment of revocation, without prejudice to the terms provided by law. In general terms, the revocation of consent only has effects for the future. The aforementioned rights can be exercised as provided by the EU Regulation by contacting the contact details indicated in section 1 of this Privacy Policy. So.Di.Co S.r.l., in compliance with Article 19 of the EU Regulation, informs the recipients to whom personal data has been disclosed about any rectifications, erasures, or restrictions of processing requested, to the extent possible.

7. Right to lodge a complaint (according to Article 13, paragraph 2 (d) of the GDPR)

If the data subject believes that their rights have been infringed, they have the right to lodge a complaint with the supervisory authority. For further information on the rights and their exercise, please refer to the specific procedure provided on the website of the supervisory authority http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 or by sending a written communication to the Supervisory Authority for the Protection of Personal Data.

8. Possible consequences of non-disclosure of data and nature of data provision (according to Article 13, paragraph 2 (e) of the GDPR)

8.1 In case of the data subject’s consent

Please note that the purpose mentioned above is based on consent, and with regard to this purpose, the data subject may revoke their consent at any time, and the effects will apply from the moment of revocation, without prejudice to the terms provided by law. In general terms, the revocation of consent only has effects for the future. Therefore, the processing that has been carried out prior to the revocation of consent will not be affected and will maintain its lawfulness. Failure to provide or partial withdrawal of consent may result in the incomplete provision of services or activities related to the specific purposes for which consent is denied. However, it will not prejudice or hinder other purposes (and related activities) that are not explicitly affected by the denial of consent or not based on such legal basis.

Please note that regarding the request for information, while the consent to the processing of personal data is voluntary, it is necessary for the processing of the request. Therefore, submitting the request or an equivalent expression of will shall be considered as giving consent, which can always be revoked with the consequences described above. When the data is no longer necessary, it will be regularly deleted. If deletion is not possible or can only be achieved through disproportionate effort due to a particular storage method, the data cannot be processed and must be stored in inaccessible areas.

9. Existence of automated decision-making (including profiling)

The use of solely automated decision-making processes, as detailed in Article 22 of the GDPR, is currently excluded. If such processes were to be implemented for specific cases in the future, the data subject will be notified separately if required by law or through an update to this Privacy Policy.

10. Data processing methods

Personal data will be processed in paper, electronic, and telematic form and will be entered into relevant databases accessible to authorized personnel designated by the Data Controller as Data Processors and Data Handlers. They may perform operations such as consultation, use, processing, comparison, and any other appropriate operation, including automated processes, in compliance with the necessary legal provisions to ensure confidentiality, data security, accuracy, updating, and relevance to the stated purposes.

Processing of data for navigation purposes
The computer systems and software procedures used to operate this website acquire certain personal data as part of their normal operation, the transmission of which is implicit in the use of Internet communication protocols.

These are pieces of information that are not collected to be associated with identified individuals, but which, by their nature, could, through processing and association with data held by third parties, allow users to be identified.

Among the information that may be collected are IP addresses, the type of browser or operating system used, URI (Uniform Resource Identifier) addresses, the domain name, and the addresses of the websites from which access or exit was made (referring/exit pages), the time of the request to the server, the method used, information about the response obtained, further information about the user’s navigation on the website (see also the section on cookies), and other parameters related to the user’s operating system and computer environment.

These same data may also be used to identify and ascertain responsibilities in the event of any computer crimes against the website.

Notice regarding minors under 14 years old
Minors under 14 years of age cannot provide personal data. So.Di.Co S.r.l. will not be in any way responsible for any collection of personal data, as well as false statements, provided by minors. In any case, if such use is detected, So.Di.Co S.r.l. will facilitate the right of access and deletion requested by the legal guardian or person exercising parental responsibility.

Changes and updates
This notice includes the date of its last update in the header. So.Di.Co S.r.l. may also make changes and/or additions to this privacy policy as a result of any subsequent regulatory changes and/or additions.

Legal references regarding the rights of the data subject

Article 15

Right of access by the data subject

The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning them are being processed and, if so, to access the personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data concerned;

c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

e) the existence of the data subject’s right to request rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing;

f) the right to lodge a complaint with a supervisory authority;

g) where the personal data are not collected from the data subject, any available information as to their source;

h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4), and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data are transferred to a third country or to an international organization, the data subject has the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

The data controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. If the data subject makes the request electronically, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic format.

The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16: Right to rectification The data subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning him or her without undue delay. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by providing a supplementary statement.

Article 17: Right to erasure (“right to be forgotten”)

The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay, and the data controller has the obligation to erase personal data without undue delay if one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) the data subject withdraws consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a), and there is no other legal ground for the processing; c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2); d) the personal data have been unlawfully processed; e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the data controller is subject; f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
Where the data controller has made the personal data public and is obliged, pursuant to paragraph 1, to erase the personal data, the data controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other data controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data.
Paragraphs 1 and 2 shall not apply to the extent that processing is necessary: a) for exercising the right of freedom of expression and information; b) for compliance with a legal obligation which requires processing by Union or Member State law to which the data controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; c) for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3); d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or e) for the establishment, exercise or defence of legal claims.

Article 18: Right to restriction of processing

The data subject has the right to obtain from the data controller restriction of processing where one of the following applies: a) the accuracy of the personal data is contested by the data subject, for a period enabling the data controller to verify the accuracy of the personal data; b) the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; c) the data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the data controller override those of the data subject.
Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the data controller before the restriction of processing is lifted.

Article 19 Obligation to notify in case of rectification or erasure of personal data or restriction of processing The data controller shall communicate to each of the recipients to whom the personal data have been disclosed any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1), and Article 18, unless this proves impossible or involves a disproportionate effort. The data controller shall inform the data subject about these recipients if the data subject requests it.

Article 20 Right to data portability

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a data controller, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another data controller without hindrance from the data controller to whom the personal data have been provided, where: a) the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b); and b) the processing is carried out by automated means.
In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one data controller to another, where technically feasible.
The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21 Right to object

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to the processing of personal data concerning him or her pursuant to Article 6(1)(e) or (f), including profiling based on those provisions. The data controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.
Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
The right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and presented clearly and separately from any other information at the latest at the time of the first communication with the data subject.
In the context of the use of information society services and without prejudice to Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to the processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out in the public interest.

Article 22 Automated individual decision-making, including profiling

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
Paragraph 1 shall not apply if the decision: a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; b) is authorized by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or c) is based on the data subject’s explicit consent.
In the cases referred to in paragraph 2(a) and (c), the data controller shall implement suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests, at least the right to obtain human intervention on the part of the data controller, to express his or her point of view, and to contest the decision.

Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless Article 9(2)(a) or (g) applies and suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests are in place.