Privacy and Cookies Notice
GAGGIA PRIVACY NOTICE
Last update: 27 June 2018
Gaggia wants you to be familiar with how we collect, use and disclose Personal Data. This Privacy Notice is meant to help you understand our privacy practices, including what Personal Data we collect, why we collect it, what we do with it, and how we protect it, as well as your individual rights.
Gaggia, as part of the Philips Group, appreciates the interest you have shown in our company, products and services by visiting our websites (www.gaggia.com and www.gaggia.it) or related communication channels, including, but not limited to, our social media pages and/or channels and blogs (together “Gaggia Pages”). This Privacy Notice applies to the Personal Data that we collect or process when you interact with Gaggia Pages. You can interact with Gaggia through Gaggia Pages, through the use of our products/services, through marketing communications, as well as through our customer support. These interactions can be made by visitors, customers, business customers, suppliers and/or business partners.
Gaggia also processes Personal Data beyond our Gaggia Pages, which will require a different privacy notice. Whenever and wherever that is the case, Gaggia will make it clear that the privacy notice concerned is different from this privacy notice.
To create a global approach to the protection of privacy and allow internal data transfers between Philips companies worldwide of which Gaggia is part, the Philips Group has adopted Binding Corporate Rules called the “Philips Group Privacy Rules”. You can find more information on these rules on the Philips privacy website (www.philips.com/privacy).
Last but not least, your privacy is of sincere importance to us. You have shown your trust in us by interacting with our Gaggia Pages and we value that trust. This means that we are committed to protecting your privacy at all times.
WHAT PERSONAL DATA DO WE COLLECT AND FOR WHICH PURPOSE?
When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.
Promotional Communications Data
You can choose to sign up for marketing and promotional communications. When you sign up for marketing and promotional communications, we will use the following Personal Data:
• Email address
• Name and Surname
We use this Personal Data to send you promotional communications about Gaggia products, services, events and promotions.
Gaggia will give you the opportunity to withdraw your consent for receiving promotional communications at any time via the unsubscribe link at the bottom of each promotional communications email you may receive from us.
We may also send Gaggia press releases by email (Press email data). When Gaggia sends press releases, Gaggia will process your name, contact details (e.g. email) and company information.
The processing of Personal Data for Promotional Communications are based on your consent, i.e. provided on a voluntary basis; such basis is lawful under article 6 (a) of Regulation (EC) 5419/16. Where Gaggia processes your Personal Data based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before withdrawing your consent.
Social Listening Data
When you interact or communicate on social media channels/pages/promotions and blogs (e.g. when you click on ‘like’ or ‘share’, when you post and share comments and when you submit ratings and reviews) your Personal Data is processed by a third party that provides social listening services to Gaggia. This means that the third party that provides social listening services will retain a copy of your online publicly available interactions to which the third party has provided us access.
The Personal Data we collect includes publically available data provided in the social media context by you from the relevant social media provider via a third party that provides social listening services such as: name, gender, birthday or age, homepage, profile photo, time zone, mail address, country, interests, and comments and content you have posted/shared.
We use this Personal Data to gain a general view of the opinion of people about us and our brands and to get an idea of relevant online influencers and to resolve issues and/or improve Gaggia products and services and/or start a promotional conversation with you (based on questions/requests that you addressed to us or our competitors).
We consider the processing of Social Listening Data in the above context to be based on a legitimate interest of Gaggia to be lawful under article 6(f) Regulation (EC) 5419/16.
Consumer or Customer Care Data
You may interact with our Consumer or Customer Care centers.
When you contact Customer Support, or when you communicate with one of our Gaggia Customer Care representatives by email, phone or in writing (e.g. reply card) we will use the following Personal Data:
• Your Account data;
• Your call recording and history, purchase history, the content of your questions, or requests that you addressed.
We use this Personal Data to provide you with consumer and customer support (which may be product- or service related), respond to your inquiries, fulfil your requests and provide you with related customer service, such as repair or redeem products/services. We also use this Personal Data to improve, fix and customize our products and services, to meet compliance standards and to educate our Customer Care employees during training.
If we provide this service on the basis of an agreement with you, we consider the processing of your Personal Data to be necessary for the performance of the contract to which you are party and lawful under Article 6(b) Regulation (EC) 5419/16.
In other cases, we consider the processing of your Personal Data in the above context to be based on a legitimate interest of Gaggia to be lawful under article 6(f) Regulation (EC) 5419/16.
Improve our products and service (Improvement Data)
Where we use Personal Data we have collected from you while you have been using Gaggia Products/Services and/or our Gaggia Pages for analytical purposes, we do this in order to improve our Products/Services and to enhance your user experience. We also do this in order to have a general overview of the category of audiences that are interested in which of our Products and/or Services.
We consider the processing of your Personal Data in the above context to be based on legitimate interest of Gaggia to improve our Gaggia pages and our range of products and services and to be lawful under article 6(f) Regulation (EC) 5419/16.
SHARING YOUR PERSONAL DATA WITH OTHERS
Affiliates and service providers
We may disclose your Personal Data:
• To our affiliates or subsidiaries for the purposes described in this Privacy Notice;
• To our third party service providers who provide services such as website hosting, data analysis, payment/billing processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, CRM, identity management, event management, marketing intelligence, auditing, fraud detection and other services;
• To third parties, to permit them to send you marketing communications, consistent with your choices if you have opted into such sharing;
• To third-party sponsors of sweepstakes, contests and similar promotions;
Other uses and disclosures
We may also use and disclose your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates or subsidiaries, you or others.
In addition, we may use, disclose or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Gaggia Pages link. The inclusion of a link on the Gaggia Pages does not imply endorsement of the linked site or service by us or by our affiliates or subsidiaries.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or in connection with the Gaggia Pages. These other organizations may have their own privacy notices, statements or policies. We strongly suggest that you review them to understand how your Personal Data may be processed by those other organizations.
Third-party cookies or other tracking technologies
The data collected is used to:
- • Ensure that the digital channel functions properly;
- • Analyze digital channel usage so we can measure and improve performance of our digital channels;
- • Connect to your social media networks and read reviews;
- • Help better tailor advertising to your interests, both within and beyond Gaggia digital channels;
HOW WE PROTECT YOUR PERSONAL DATA?
How do we secure your Personal Data?
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How can you contact us?” section below.
How long will the Personal Data be kept?
We will retain your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you to participate in the Gaggia pages; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Jurisdiction and cross-border transfer
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Gaggia Pages you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.
If you are located in the EEA, your Personal Data may be transferred to our affiliates or service providers in non-EEA countries that are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as our Binding Corporate Rules for Customer, Supplier and Business Partner Data and/or standard contractual clauses adopted by the European Commission and/or if the service provider is located in the USA is certified member pursuant to the EU/US Privacy Shield, to protect your Personal Data. You may obtain a copy of these measures by following the link above or sending an email to firstname.lastname@example.org
YOUR RIGHTS AND CHOICES AVAILABLE TO YOU
If you would like to submit a request to access, rectify, erase, restrict or object to the processing of Personal Data that you have previously provided to us, or if you would like to submit a request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us via our contact form. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Data. For your protection, we may only implement requests with respect to the Personal Data associated with your account, your email address or other account information, that you use to send us your request, and we may need to verify your identity before implementing your request.
You may also opt-out from receiving electronic communications from Gaggia. If you no longer want to receive marketing-related emails on a going-forward basis, you may opt-out by clicking the unsubscribe button at the bottom of each promotional email you receive from us.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g. when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completing of such a purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
If you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, certain Gaggia Services.
SPECIAL INFORMATION FOR PARENTS
The Gaggia Pages are not directed to children, as defined under applicable law, and we do not knowingly collect Personal Data from children. It is, however, Gaggia policy to comply with the law when it requires parent or guardian permission before collecting, using or disclosing Personal Data of children. We are committed to protecting the privacy needs of children and we strongly encourage parents and guardians to take an active role in their children’s online activities and interests.
If a parent or guardian becomes aware that his or her child has provided us with his or her Personal Data without their consent, please send an email to email@example.com. If we become aware that a child has provided us with Personal Data, we will delete his/her data from our files.
HOW CAN YOU CONTACT US?
If you have any questions about this Privacy Notice or about the way Gaggia uses your Personal Data, please contact our Data Protection Officer by sending an email to firstname.lastname@example.org. Alternatively, you have the right to lodge a complaint with a supervisory authority competent for your country or region.
GAGGIA COOKIES NOTICE
A. Type of Cookies
2. A cookie consists of a reduced set of data transferred to the user’s browser from a web server and can only be read by the server that made the transfer. This is not executable code and does not transmit viruses.
3. Cookies do not record any personal information and any identifiable information will not be stored. If you want, you can prevent the saving of some or all cookies. However, in this case the use of the site and the services offered could be compromised. To proceed without changing the options related to cookies, simply continue browsing.
Below are the types of cookies that the site uses:
B. Technical cookies
1. There are many technologies used to store information on the user’s computer, which are then collected by the sites. Among these the best known and used is that of HTML cookies. They are used for navigation and to facilitate access and use of the site by the user. They are necessary for the transmission of communications on the electronic network or the supplier to provide the service requested by the customer.
2. The settings to manage or deactivate cookies may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or cancellation of cookies, modifying the settings of his internet browser. This deactivation can slow down or prevent access to some parts of the site.
3. The use of technical cookies allows the safe and efficient use of the site.
4. Cookies that are inserted in the browser and retransmitted by Google Analytics or the statistics service of bloggers or similar are technical only if used for the purpose of optimizing the site directly from the owner of the site, which can collect information in aggregate form on the number users and how they visit the site. Under these conditions, for analytics cookies the same rules apply, in terms of information and consent, provided for technical cookies.
5. From the point of view of duration we can distinguish temporary session cookies that are deleted automatically at the end of the browsing session and are used to identify the user and thus avoid logging in to each page visited and the permanent ones that remain active in the PC up upon expiry or cancellation by the user.
6. Session cookies may be installed in order to allow access to and access to the reserved area of the portal as an authenticated user.
7. They are not stored permanently but only for the duration of the navigation until the browser is closed and disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow the safe and efficient exploration of the site.
C. Third-party cookies
1. In relation to the provenance we distinguish the cookies sent to the browser directly from the site you are visiting and those of third parties sent to the computer from other sites and not from the one you are visiting.
2. Permanent cookies are often third-party cookies.
3. The majority of third-party cookies consists of tracking cookies used to identify online behavior, understand the interests and then customize the advertising proposals for users.
4. Third-party analytical cookies may be installed. They are sent from the domains of the aforementioned third parties external to the site.
5. Third-party analytical cookies are used to detect information on user behavior on Gaggia. The survey takes place anonymously, in order to monitor the performance and improve the usability of the site. The third-party profiling cookies are used to create profiles relating to users, in order to propose advertising messages in line with the choices expressed by the users themselves.
6. The use of these cookies is governed by the rules set by the third parties themselves, therefore, users are invited to read the privacy policies and indications to manage or disable the cookies published on the related web pages.
D. Profiling cookies
1. Profiling cookies are those that create profiles related to the user and are used in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net.
2. When these types of cookies are used, the user must give explicit consent.
3. Article 22 of EU Regulation 2016/679 and Article 122 of the Code on data protection will apply.