Privacy Policy - EU

With this Privacy Policy, drafted pursuant to art. 13 of EU Regulation 679/2016 (“GDPR”), Venchi S.p.A., with registered office at Via V. Monti 8, 20123 Milan (MI), Italy (“the Data Controller”, “Venchi” or “We”) provides you with information concerning the processing of your Personal Data, as defined below, provided to Venchi by using the application Venchipedia (“the Application”). 

1. What Personal Data do we gather about you?

Personal Data are collected for the purposes of suppling dedicated educational contents and generate feedback on your progress, and each time you participate in any of the features or services offered by the Application.

Processed Personal Data are the following:

  • Name
  • First name
  • Email
  • Login
  • Password
  • Avatar (Image or photo)
  • Language
  • Time spent in the teaching activities
  • Scores
  • Result of activities
  • Progress made in the teaching activities
  • Points obtained via the game system
  • Start dates of the teaching activities
  • Contribution ( such as comments etc.)
  • Data related to your job position and employment/collaboration status  

(“Personal Data”)

2. Which are the processing methods?

The processing of Personal Data consists of the operations set forth in art. 4, no. 2 of the GDPR or: the collection, recording, organisation, storage, consultation, processing, alteration, selection, extraction, comparison, use, combination, blocking, dissemination, erasure and destruction of the data. The processing may take place in hard copy and/or digital form, with organisational methods and approaches strictly correlated with the purposes specified. We may use a variety of technologies that collect and provide information about how the Application is accessed and used by you (active directory, forms etc.).

3. For what purpose do we use your Personal Data and based on which legal grounds?

The legal ground of the processing is:

  • the performance of the employment/collaboration contract that you, as an employee/collaborator of Venchi, executed with Venchi;
  • the performance of the contract that you, as a customer of Venchi, executed with Venchi.

When you register or sign-up in the Application, your Personal Data is used to supply you with dedicated educational contents, feedback on your progress and, if you are an employee/collaborator of Venchi, mandatory courses that you must attend to be updated and aligned with Venchi’s policies/instructions related to how to perform your working activity in Venchi stores.

 

4. What happens if you do not wish to provide your Personal Data?

You will not be able to use the Application, which means you may not receive dedicated educational contents, feedback on your progress and, if you are an employee/collaborator of Venchi, you may not be updated or aligned with the policies/instructions provided by Venchi within the Application.

 

5. To whom do we disclose your Personal Data?

Your Personal Data may be shared with:

  • Venchi Group companies
  • employees of Venchi, duly appointed as parties authorised to perform processing
  • eventually, service providers for the management and hosting of databases related to Personal Data, duly appointed as parties authorised to perform processing

Personal Data will be processed also by:

  • Teach on Mars, as the Subcontractor of the Application and Data Processor, but only for the purpose described above (topic 3)
  • Teach on Mars’s other subcontractors who will perform a specific part of the activity assigned to Teach on Mars, only for the purpose described above (topic 3)

6. Is your Personal Data sent to recipients located in other countries and why?

The Data Controller is a global company and if permitted by applicable local laws your Personal Data may be transferred across international borders. It may be transferred to countries that have a different level of data protection laws than the one existing in the country from where you submitted your Personal Data.

Hosting service providers for the operation of the Application are based in the European Union. The transfers of Personal Data to these service providers are implemented in accordance with applicable laws and rely on GDPR. Teach on Mars, acting as Data Processor, is also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that it acts only on the Data Controller instructions and implements all technical measures necessary on an ongoing basis to keep your Personal Data secure.

The Data Controller takes the appropriate measures to maintain security of the Personal Data both during transit and at the receiving location.

 

7. How long do we keep your Personal Data?

The Personal Data that you sent via the Application will be stored in databases as long as your account is active, for the duration of the contract between the Data Controller and Teach on Mars, or as needed to provide you the services you requested, to answer queries or resolve problems or to provide improved and new services. Your Personal Data may also be retained in accordance with internal retention procedure as necessary to comply with legal and regulatory obligations, resolve disputes and enforce agreements. In this regard, if you are an employee/collaborator of Venchi, we kindly invite you to read the privacy policy that was provided to you when you were hired/contracted as an employee/collaborator of Venchi.

 

8. How do we secure your Personal Data?

All necessary technical and organizational measures have been taken to protect the confidentiality and security of your Personal Data collected from the Applications, including sensitive Personal Data. These efforts include but are not necessarily limited to: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorized employees, agents and contractors; (ii) verifying the identities of registered users before they can access their Personal Data; and iii) having executed with Teach On Mars, as Data Processor, an agreement in which it undertakes to implement all the technical and organizational measures necessary to ensure the confidentiality of the personal data.

 

9. How can you exercise your rights?

  • In your capacity as “Data Subject”, at any time and when the conditions laid out by regulations are met, you may exercise the rights set forth in arts. 15 et seq. of the GDPR.

In particular, you may exercise:

  • the right of access: you may request information concerning the processing of your Personal Data, as well as receive a copy of the data processed;
  • the right of rectification: you may verify the accuracy of your Personal Data, as well as request their rectification or updating;
  • the right to erasure: you may request, when specific conditions are met, the erasure of your Personal Data;
  • the right of restriction: you may request, when specific conditions are met, the restriction of the processing of your Personal Data;
  • the revocation of consent: in all cases in which the legal basis of the processing is consent, you may revoke such consent at any time, without prejudice in any event to the lawfulness of the processing performed prior to such revocation;
  • right to submit a complaint to the Personal Data Protection Authority: without prejudice to any other administrative or legal action, you may submit a complaint to the Personal Data Protection Authority, according to the procedures and instructions published on the Authority’s website, available at the address https://www.garanteprivacy.it/.

10. How can you contact us?

To exercise the rights set forth above or obtain additional information on processing, you may contact the Data Protection Officer (DPO) of the Data Controller directly at the email address privacy@venchi.com or send a registered letter for the attention of the Privacy Office of Venchi S.p.A., Via V. Monti 8, 20123 Milan (MI).

Date of most recent update: September 2023

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Privacy Policy - US

With this Privacy Policy, Venchi US Inc., with registered office in 1221 Brickell Avenue, Suite 1160 Miami, FL 33131 (“the Data Controller”, “Venchi” or “We”) provides you with information concerning the processing of your Personal Data, as defined below, provided to Venchi by using the application Venchipedia (“the Application”).

 

1. What Personal Data do we gather about you?

Personal Data are collected for the purposes of suppling dedicated educational contents and generate feedback on your progress, and each time you participate in any of the features or services offered by the Application.

Processed Personal Data are the following:

  • Name
  • First name
  • Email
  • Login
  • Password
  • Avatar (Image or photo)
  • Language
  • Time spent in the teaching activities
  • Scores
  • Result of activities
  • Progress made in the teaching activities
  • Points obtained via the game system
  • Start dates of the teaching activities
  • Contribution (such as comments etc.)
  • Data related to your job position and employment/collaboration status  

(“Personal Data”)

2. Which are the processing methods?

The processing of Personal Data consists of the following operations: collection, recording, organisation, storage, consultation, processing, alteration, selection, extraction, comparison, use, combination, blocking, dissemination, erasure and destruction of the data. The processing may take place in hard copy and/or digital form, with organisational methods and approaches strictly correlated with the purposes specified.

We may use a variety of technologies that collect and provide information about how the Application is accessed and used by you (active directory, forms etc.).

3. For what purpose do we use your Personal Data and based on which legal grounds?

The legal ground of the processing is:

  • the performance of the employment/collaboration contract that you, as an employee/collaborator of Venchi, executed with Venchi;
  • the performance of the contract that you, as a customer of Venchi, executed with Venchi.

When you register or sign-up in the Application, your Personal Data is used to supply you with dedicated educational contents, feedback on your progress and, if you are an employee/collaborator of Venchi, mandatory courses that you must attend to be updated and aligned with Venchi’s policies/instructions related to how to perform your working activity in Venchi stores.

4. What happens if you do not wish to provide your Personal Data?

You will not be able to use the Application, which means you may not receive dedicated educational contents, feedback on your progress and, if you are an employee/collaborator of Venchi, you may not be updated or aligned with the policies/instructions provided by Venchi within the Application.

5. To whom do we disclose your Personal Data?

Your Personal Data may be shared with:

  • Venchi Group companies
  • employees of Venchi, duly appointed as parties authorised to perform processing
  • eventually, service providers for the management and hosting of databases related to Personal Data, duly appointed as parties authorised to perform processing

Personal Data will be processed also by:

  • Teach on Mars, as the Subcontractor of the Application and Data Processor, but only for the purpose described above (topic 3)
  • Teach on Mars’s other subcontractors who will perform a specific part of the activity assigned to Teach on Mars, only for the purpose described above (topic 3)

6. Is your Personal Data sent to recipients located in other countries and why?

The Data Controller is a global company and if permitted by applicable local laws your Personal Data may be transferred across international borders. It may be transferred to countries that have a different level of data protection laws than the one existing in the country from where you submitted your Personal Data.

Hosting service providers for the operation of the Application are based in the European Union. The transfers of Personal Data to these service providers are implemented in accordance with applicable laws and rely on EU General Data Protection Regulation. Teach on Mars, acting as Data Processor, is also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that it acts only on the Data Controller instructions and implements all technical measures necessary on an ongoing basis to keep your Personal Data secure.

The Data Controller takes the appropriate measures to maintain security of the Personal Data both during transit and at the receiving location.

7. How long do we keep your Personal Data?

The Personal Data that you sent via the Application will be stored in databases as long as your account is active, for the duration of the contract between the Data Controller and Teach on Mars, or as needed to provide you the services you requested, to answer queries or resolve problems or to provide improved and new services. Your Personal Data may also be retained in accordance with internal retention procedure as necessary to comply with legal and regulatory obligations, resolve disputes and enforce agreements. In this regard, if you are an employee/collaborator of Venchi, we kindly invite you to read the privacy policy that was provided to you when you were hired/contracted as an employee/collaborator of Venchi.

8. How do we secure your Personal Data?

All necessary technical and organizational measures have been taken to protect the confidentiality and security of your Personal Data collected from the Applications, including sensitive Personal Data. These efforts include but are not necessarily limited to: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorized employees, agents and contractors; (ii) verifying the identities of registered users before they can access their Personal Data; and iii) having executed with Teach On Mars, as Data Processor, an agreement in which it undertakes to implement all the technical and organizational measures necessary to ensure the confidentiality of the personal data.

9. How can you contact us?

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection practices, please contact us by writing to: venchi-usa@venchi.com

 

Date of most recent update: September 2023