Personal Data Processing Notice. Effective from 28/05/2026

INTRODUCTION

This notice takes into account the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the Italian Privacy Code (Legislative Decree No. 196 of 30 June 2003). This document has also been drafted on the basis of the Guidelines of the Italian Data Protection Authority, especially the Guidelines against spam issued by the Italian Data Protection Authority on 4 July 2013.

Data Controller: ROSETTA BAKERY SRLS, Piazza Vanvitelli 15 - 80129 Naples, Naples Chamber of Commerce, VAT No. 09921321213, R.E.A.: NA1068038, Telephone: +39 081 18 118 90 92, Email: info@cremoro.it

Website to which this privacy policy refers: https://cremoro.it/ (Website).

The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, you may send any request for information directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes the personal data you provide on the Website.

The main processing operations concerning your personal data are described below. In particular, the legal basis of the processing is explained, as well as whether the provision of data is mandatory and the consequences of failing to provide personal data. In order to best describe your rights, where necessary, we have specified whether and when a specific personal data processing activity is not carried out. On the Website, you may enter personal data relating to third parties. In this case, you guarantee that you have obtained consent from these subjects to enter their personal data. Therefore, you undertake to indemnify and hold the Data Controller harmless from any liability.

Registration on the Website

The information and data requested in the event of registration will be used to allow you both to access the reserved area of the Website and to use the online services offered by the Data Controller to registered users. The legal basis of the processing is the need of the Data Controller to carry out pre-contractual measures adopted at the request of the data subject. The provision of data is optional. However, any refusal to provide the data will make it impossible to register on the Website.

Purchases on the Website

Your personal data will be processed to allow you to make purchases on the Website. In the event of an online purchase order, this processing is carried out to allow the conclusion of the purchase contract and the proper execution of the related operations, and, where necessary according to the applicable sector regulations, to comply with tax obligations. This personal data processing also includes the possibility of sending communications, such as tracking and order information, through automated tools such as SMS and/or WhatsApp. The legal basis of the processing is the obligation of the Data Controller to perform the contract with the data subject or to comply with legal obligations. Regardless of the above, and therefore regardless of your consent, the Data Controller may process your data for so-called “soft spam” purposes, regulated by art. 130 of the Italian Privacy Code. This means that, limited to the email address you provided in the context of a purchase through the Website, the Data Controller will process the email address to allow the direct offer of similar products/services, provided that you do not object to such processing in the manner set out in this notice. The legal basis of the processing is the legitimate interest of the Data Controller in sending this type of communication. This legitimate interest may be considered equivalent to the interest of the data subject in receiving “soft spam” communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis of this processing is the legitimate interest of the Data Controller in sending this type of communication.

Responding to your requests

Your data will be processed to respond to your requests for information. Providing the data is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis of the processing is the legitimate interest of the Data Controller in responding to user requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller.

Generic marketing

Subject to your consent, the Data Controller may process the personal data you provide in order to send you advertising material and/or newsletters relating to its own products or third-party products. The legal basis of this processing is your consent. The provision of personal data for this purpose is entirely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, as well as making it impossible for the Data Controller to carry out market research, including research aimed at assessing the level of user satisfaction, and to send you newsletters. These communications will be sent to the email address you provided on the Website.

Profiling

Subject to your consent, the Data Controller may process your personal data for profiling purposes, namely to analyse your consumer choices by detecting the type and frequency of purchases you have made, in order to send you advertising material and/or newsletters relating to its own products or third-party products that may be of specific interest to you. The legal basis of this processing is your consent. The provision of data for this purpose is entirely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to create your commercial profile by detecting your choices and purchasing habits, and to send you advertising material relating to products of the Data Controller and/or third parties that may be of specific interest to you. These communications will be sent to the email address you provided on the Website.

Transfer of data to third parties

The Data Controller does not transfer your personal data to third parties.

Geolocation

The Website does not implement tools for geolocating the user’s IP address.

Curriculum Vitae

It is not possible to send curriculum vitae through the Website. Therefore, your data will not be processed for these purposes.

Appointment booking

No third-party appointment booking systems with the Data Controller are active on the Website. Therefore, your data will not be processed for this purpose. In any case, you may always contact the Data Controller using the contact details indicated above.

Photographs and videos

The Data Controller does not request the publication of photographs and/or videos depicting you. Therefore, your data will not be processed for these purposes.

Communication of personal data

As part of its ordinary activities, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to whom the Data Controller communicates your personal data. To facilitate the protection of your rights, article 2 may specify, in certain cases, when your data is not communicated to third parties.

The “communication” of personal data to third parties is different from the “transfer” of data to third parties, regulated in the previous section. In fact, in the case of communication, the third party to whom the data is transmitted may use it only for the specific purposes described in the relationship with the Data Controller. In the case of transfer, on the other hand, the third party becomes an independent Data Controller of the personal data. Furthermore, your consent is always required in order to transfer your personal data to third parties.

Without prejudice to the above, it is understood that the Data Controller may in any case use your personal data to properly comply with the obligations provided for by the laws in force.

SPECIFIC PRIVACY NOTICE

Art. 1 Processing methods

1.1 The processing of your personal data will mainly be carried out with the aid of electronic or otherwise automated means, according to methods and using tools suitable to guarantee the security and confidentiality of personal data.

1.2 The information acquired and the processing methods will be relevant and not excessive in relation to the type of services provided. Your data will also be managed and protected in secure IT environments appropriate to the circumstances.

1.3 No “special categories of data” are processed through the Website. Special categories of data are those that may reveal racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade-union nature, as well as health status and sex life.

1.4 No judicial data is processed through the Website.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to specific categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:

The Data Controller may communicate your personal data to all subjects, including Public Authorities, that have access to personal data by virtue of legal or administrative provisions.

Your personal data may also be communicated to all public and/or private subjects, natural and/or legal persons, such as legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Labour Chambers and Offices, etc., where the communication is necessary or functional to the proper fulfilment of obligations arising from the law.

The Data Controller uses employees and/or collaborators in various capacities. For the proper functioning of the Website, the Data Controller may communicate your personal data to these employees and/or collaborators.

As part of its ordinary Website management activities, the Data Controller uses companies, consultants or professionals appointed for the installation, maintenance, updating and, in general, management of the hardware and software of the Data Controller or used by the latter to provide its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.

For sending its communications, the Data Controller uses external companies appointed to send this type of communication, such as CRM platforms. Your personal data, especially your email address, may therefore be communicated to these companies.

The Data Controller does not use external companies to provide customer care services.

The personal data of the purchaser may be communicated to post offices, couriers or shipping companies responsible for delivering the Products purchased through the Website.

The Data Controller reserves the right to modify the above list according to its ordinary operations. Therefore, you are invited to access this notice regularly to check the subjects to whom the Data Controller communicates your personal data.

Art. 3 Retention of personal data

3.1 This article describes how long the Data Controller reserves the right to retain your personal data.

Your personal data will be retained only for the time necessary to ensure the proper provision of the services offered through the Website.

For the purpose of performing the sales contract, the data will be retained for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defence and to prove that it has correctly performed the contract.

As provided for by article 2220 of the Italian Civil Code, invoices, as well as all accounting records in general, are retained for a minimum period of ten years from the date of registration, so that they may be presented in the event of an inspection.

For marketing purposes, unless consent is withdrawn earlier, the data will be retained for 24 months from the time it is provided. After the withdrawal of consent or at the end of the 24-month period, the personal data will be deleted and no longer used for marketing purposes.

For “profiled” marketing purposes, unless consent is withdrawn earlier, the data will be retained for 12 months from the time it is provided. After the withdrawal of consent or at the end of the 12-month period, the personal data will be deleted and no longer used for this purpose.

For customer care purposes, the data will be deleted once the assistance service has been completed and, in any case, within a maximum period of 3 months from the last email exchange with the data subject.

3.2 Without prejudice to the provisions of article 3.1, the Data Controller may retain your personal data for the period required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is based in a country that has an adequate level of security from a regulatory point of view. If your personal data is transferred to a non-EU country for which the European Commission has issued an adequacy decision, the transfer is in any case considered secure from a regulatory point of view. This article 4.1 indicates, from time to time, the countries to which your personal data may possibly be transferred and for which the European Commission has issued an adequacy decision.

Your personal data may be transferred to the USA on the basis of the European Commission’s adequacy decision. With this decision, the European Commission decided that the USA offers protection of personal data comparable to that offered by the European Union.

The Data Controller may transfer your personal data to the United Kingdom. Indeed, with the decision of 28 June 2021, the European Commission established that the United Kingdom offers an adequate level of protection of personal data pursuant to the GDPR.

4.2 Without prejudice to what is indicated in article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not issued an adequacy decision. You are therefore invited to regularly review this article 4.2 to determine to which of these countries your data may possibly be transferred.

4.3 In this article, the Data Controller indicates the countries towards which it may specifically direct its activity. This circumstance may imply the application of the laws of the relevant country, together with those governing the relationship with the user as indicated in the Introduction.

Upon request by the user, the Data Controller will apply to the processing of personal data any more favourable rules provided for by the user’s national legislation.

Art. 5. Rights of the data subject

The Data Controller informs you that you have the right to:

request from the Data Controller access to your personal data and the rectification or erasure of such data, or the restriction of processing concerning you, or to object to their processing, as well as the right to data portability

withdraw consent at any time without affecting the lawfulness of processing based on consent given before its withdrawal

lodge a complaint with a supervisory authority.

The above rights may be exercised by submitting a request, without formalities, to the contact details indicated in the Introduction.

Art. 6. Amendments and miscellaneous provisions

The Data Controller reserves the right to make changes to this notice at any time, giving appropriate notice to Website users and in any case ensuring adequate and similar protection of personal data. In order to view any changes, you are invited to consult this notice regularly. In the event of substantial changes to this privacy policy, the Data Controller may also notify you by email.