Information on the processing of personal data pursuant to Art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("General Data Protection Regulation - GDPR")

Version 1.0 - Updated: 05/29/2023

INFORMATION AND CONTACT DETAILS OF THE DATA CONTROLLER
Data Controller	Gambero Rosso SpA, VAT number 06051141007, with its registered office at Via Ottavio Gasparri n. 13/17, 00152 Rome (RM), Registration number in the Company Register of Rome n° 06051141007.
Contact details of the Data Controller	PEC: [email protected]; Telephone: +39 06 55 11 21
DPO data (Data Protection Officer)	e-mail: [email protected]
Gambero Rosso SpA, as Data Controller of your personal data (hereinafter also "Gambero Rosso" or "Data Controller"), informs you, pursuant to articles 12 and 13 of Regulation (EU) 2016/679 (General Data Protection Regulation, hereinafter referred to as "GDPR"), that your personal data will be processed by specifically authorized subjects and limited to the purposes and with the means that will be specified below. Gambero Rosso is the owner and manager of this website https://www.gamberorosso.it/, to which the information contained in this disclosure applies (hereinafter also the "Site"). For the processing of personal data for the purpose of sending commercial, marketing and market research communications, there is joint ownership of the processing with the other companies belonging and not to the Class Editori, indicated in the list at the bottom of this document (hereinafter, also "Joint Controllers"). Gambero Rosso believes in the importance of privacy for all its users and uses the data collected only to improve the experience of using the site, respecting the standards set by European (GDPR) and national (Privacy Code) regulations, updating the information and making it easier to read and understand. The GDPR is a regulation aimed at strengthening and unifying data protection for all subjects within the European Union and which requires a high level of transparency on the methods of collection, storage and use and more generally on the processing of personal data and imposes stringent limits on their use.

OBJECT AND PURPOSES OF THE PROCESSING

Gambero Rosso informs you that it will process, depending on the form, specifically, your common personal data, i.e. name and surname, date of birth, tax code and contact details, i.e. home address, e-mail address, telephone number, bank and postal data, username and password and IP address and data automatically collected during navigation as a user of this Site (by way of example, data relating to your preferences and consumption habits, socio-demographic data, and other categories of personal data, as required from time to time depending on the type of service intended to use), according to the purposes and methods defined and specified below. The Data Controller specifies that no particular categories of personal data are intentionally collected pursuant to art. 9 of the GDPR, nor data relating to criminal convictions and crimes pursuant to art. 10 of the GDPR, and invites you not to provide such data and/or information from which they could be inferred (for example, in the context of comments you publish on the Site), nor, in general, to provide personal data that is not strictly necessary.

In particular, the user’s personal data provided to Gambero Rosso directly as a result of interaction with the Site functions, or with the Joint Controllers and/or other commercial partners to whom you may have provided them in order to access certain services, will be processed for the pursuit of the following purposes:

for the use and purchase of the services and/or contents and/or products offered by Gambero Rosso through the Site, and in particular with reference to all the functions made possible by interacting with the Site through the specific buttons. Please note that for the finalization of the aforementioned purchases it is possible to refer to other websites managed by third-party companies, possibly appointed as data processors pursuant to art. 28 of the GDPR.
to guarantee the functioning of the Site and all the technical functions relating to it, in order to allow the user the best possible experience of browsing and purchasing the services offered on the Site. For this purpose, the Data Controller reserves the right to verify the correct functioning of its services, measure the level of satisfaction of its users, in order to improve the quality of customer care processes and more effectively guide the training of personnel assigned to this service, both by carrying out statistical surveys on aggregated and anonymous data, and by subjecting users and subscribers to paid services to free customer satisfaction questionnaires and surveys, making them available on the Site and/or through other methods, participation in which is always optional.

The data requested following your optional consent may be used:
for the sending of commercial communications by the Data Controller and/or the other Joint Data Controllers indicated in this information, whether belonging or not to Class Editori, through the use of traditional (telephone with operator, paper communications) and automated (e-mail, sms, mms, fax, telephone without operator, posts on social network accounts) means, including any subscription to the "Newsletter" and participation in surveys and/or market analyses;
for sending by the Data Controller and/or the other Joint Data Controllers indicated in this information, whether belonging or not to Class Editori, commercial communications from third parties, belonging to the following product sectors: agriculture, insurance, banks, commerce, training/education, finance, industry, tourism, fashion, IT, legal/administrative, marketing, media and communication, public administration, real estate, healthcare, through the use of traditional (telephone with operator, paper communications) and automated (and -mail, sms, mms, fax, telephone without operator, post on social network accounts) means;
to proceed with analysis and processing of information relating to you, aimed at offering you products and services in line with your interests. These profiling activities can be carried out both with first-party tools and by making use of tools made available by third parties, such as, by way of example, social networks (e.g. Meta) or third party advertising service providers (e.g. Google) and by adopting, where possible, security measures such as, for example, "hashing" (which consists in associating your personal data, such as e-mail, with strings of numbers and letters in order to encrypt your data). To this end, the Data Controller will also be able to associate personal data acquired through tracking technologies such as cookies (only if you have given the relevant consent, through the appropriate cookie management panel) and/or the personal data you provide in the context of our specific initiatives and/or third-party initiatives with those that we acquire as a result of your registration on one of the websites of the Joint Controllers indicated in the information, belonging or not to Class Editori and/or as a result of their use. Furthermore, to pursue this processing purpose, the Joint Controllers could also use anonymous information, not referring to any data subject, present in databases and public information systems.

This information is effective only with reference to the Site, but not with reference to other and different websites, for which Gambero Rosso is in no way responsible.

The processing of the data provided by the user will be carried out, also following automatic collection during navigation, for the sole purpose of ascertaining and/or controlling access to the Site and/or for the sole purpose of improving its functionality, in order to ensure a better browsing experience.

As regards the processing of IP addresses, as well as all user navigation data, carried out by Gambero Rosso for the purposes indicated in point 2 above), please refer to the Cookie policy

LAWFULNESS OF PROCESSING

The communication to Gambero Rosso of your personal data as specified above has the following conditions for the lawfulness of the processing, in relation to each purpose indicated above:

Article 6, par. 1 letters b), c) and f) of the GDPR (performance of a contract; compliance with a legal obligation; legitimate interest) for the purpose referred to in points 1 and 2 above.
Article 6, par. 1, letter a) of the GDPR (consent) for the purpose referred to in points 3, 4, 5 above.

The provision of your personal data is therefore necessary for the full fulfillment of the purposes referred to in points 1 and 2 above, and, consequently, your refusal to provide personal data may lead to the failure to perform the aforementioned services and functions of the Site, preventing all or part of the functionality of the same.

On the other hand, the provision of your data is optional for the complete fulfillment of the purposes referred to in points 3, 4, 5 above and, consequently, your refusal to provide personal data does not imply the failure to perform the aforementioned services and functions of the the Site, nor does it prevent all or part of the functionality of the same. The data subject has the right to withdraw his consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on the consent before the withdrawal. Consent is revoked as easily as it is granted.

Soft Spam.We also remind you that on the basis of current legislation, the Data Controller may use the e-mail coordinates provided by you when purchasing one of our services and/or services and/or editorial products to offer you products, services and/or services similar to those you have already purchased. However, if you do not wish to receive such communications, you may object by notifying the Data Controller at any time, by writing to the address indicated below or directly using the link present on the e-mail communications received from you (so-called opt out). In this case, the Data Controller will interrupt the aforementioned activity without delay. The legal basis that legitimizes the sending of promotional communications is found in the legitimate interest of the Data Controller pursuant to art. 6, par. 1 lit. f) of the GDPR. For more information or to oppose the service, you can write to [email protected].

MEANS OF THE PROCESSING

The processing of personal data is carried out by means of the operations indicated in art. 4 no. 2) of the GDPR, and precisely: "collection, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, communication, cancellation and destruction of data".

Personal data are subjected to automated processing by Gambero Rosso and, where requested, by the Joint Controllers for the time strictly necessary to achieve the purposes for which they were collected, with technical and organizational methods adopted to prevent data loss, illicit uses and/or incorrect and unauthorized access, and therefore such as to guarantee a level of security appropriate to the risk pursuant to art. 32 of the GDPR, by specifically authorized subjects, in compliance with the provisions of art. 29 of the GDPR, or by employees and/or collaborators of Gambero Rosso in their capacity as authorized subjects and/or system administrators, who will be able to carry out operations of consultation, use, processing,

It should be noted, in particular, that personal data will be processed only at the headquarters of Gambero Rosso or of the Joint Controllers for the purposes for which the joint controllership is envisaged, except as specified below, will therefore not be disclosed, and, pursuant to art. 13, paragraph 1, lett. (e), the same may be processed only by authorized subjects and/or by any external data processors pursuant to art. 28 of the GDPR (in the person of individual professionals and/or complex professional associations), and/or by subjects which operate as independent data controllers, and which explicitly include hosting companies and/or technician staff in charge of the management and/or maintenance of the Site, but only and exclusively for the purposes expressly and specifically indicated above.

SCOPE OF DATA COMMUNICATION

In relation to the purposes indicated above, personal data may be communicated to the following subjects and/or the categories of subjects indicated below, or they may be communicated to companies and/or persons who provide services, including external ones, on behalf of Gambero Rosso and, where necessary and/or requested, to the Joint Controllers.

Among these, for greater clarity, by way of example but not limited to: Joint controllers, professionals and consultants also in associated form; subjects that provide services for the management of the IT system and telecommunications networks (including e-mail and management of websites - cloud storage services - hosting); subject to specific consent, commercial partners to process them, as independent data controllers, for marketing purposes; banking institutions; factoring companies, debt collection companies, credit insurance companies; legal, administrative and tax consultancy firms; competent authorities and/or Supervisory Authorities for the fulfillment of legal obligations; subjects who carry out control, revision and certification duties of the activities carried out by Gambero Rosso who operate as external data processors pursuant to art. 28 of the GDPR, or in total autonomy as subjects distinct from Gambero Rosso.

With exclusive reference to navigation data and IP addresses, this Site may share some of the data collected with services located outside Italy and the European Union area. In the event that this should become necessary for any reason, Gambero Rosso hereby ensures that the data transfer will take place in compliance with the applicable legal provisions and, in particular, in compliance with articles 44 – 45 – 46 – 47 – 48 and 49 of the GDPR and other applicable laws.

It is installed on this Site plugin with advanced user privacy protection functions, which do not send cookies or access the cookies present on the User's browser when the page is opened but only after clicking on the plugin.

The collection and use of information by these third parties are governed by their respective privacy policies to which you are kindly requested to refer.

DATA RETENTION PERIOD

In compliance with the principles of lawfulness of processing, limitation of purposes and conservation and minimization of data, pursuant to art. 5 of the GDPR, the retention period of your personal data is established for a period of time not exceeding the achievement of the purposes indicated above for which they are collected and processed, or for the entire duration of the fulfillment of the aforementioned purposes, and, therefore, once the purposes of the processing have been completed, your data will be erased from any physical and IT support.

In particular, personal data will be kept until the conclusion of the contractual relationship and for retention times dictated by mandatory laws for the administrative-accounting purposes referred to in points 1 and 2 above; until the consent is revoked and in any case no later than 10 years for the commercial purposes referred to in point 3; no more than 5 years for the commercial purposes referred to in point 4, and no more than 12 months for the purposes referred to in point 5.

AUTOMATED INDIVIDUAL DECISION-MAKING PROCESSES AND PROFILING

Gambero Rosso informs you that, for the purposes of processing your personal data, it does not make use of automated individual decision-making processes, i.e. those aimed at making decisions based solely on technological means on the basis of predetermined criteria (i.e. without human involvement).

Gambero Rosso uses technical cookies and carries out profiling activities with the help of third-party profiling cookies within the limits and modes better indicated in the Cookie Policy to which reference is fully and expressly made, to allow the User adequate and complete information on the matter and the consequent better management of the relative consents.

RIGHTS OF THE DATA SUBJECT (USER)

Right of Access pursuant to art. 15 of the GDPR and Right to Rectification pursuant to art. 16 of the GDPR

As a Data Subject, pursuant to art. 15 of the GDPR, you have the right to obtain from Gambero Rosso confirmation of the existence or otherwise of a processing of personal data concerning you, to obtain access to them and to all the information referred to in the same art. 15, paragraph 1, letters from (a) to (h), by issuing a copy of the data being processed in a structured format, commonly used, readable by an automatic and interoperable device.

Pursuant to art. 16 of the GDPR, you also have the right to obtain from Gambero Rosso the rectification and/or integration of the data being processed if they are out of date and/or inaccurate and/or incomplete.

Right to erasure pursuant to art. 17 of the GDPR and Right to restriction the processing pursuant to art. 18 of the GDPR

As a Data Subject, you have the right to obtain exclusively in the cases referred to in art. 17, paragraph 1, letters from (a) to (f), of the GDPR, the erasure of data concerning you - with the exception of the cases specifically provided for by art. 17 paragraph 3.

As a Data Subject, pursuant to art. 18 paragraph 1, letters from (a) to (d), of the GDPR, you have the right to request and obtain from Gambero Rosso the restriction of the processing of your personal data, or that such data are not subjected to further processing and cannot no longer be modified. Gambero Rosso ensures that the restriction of the processing is implemented through suitable technical devices which guarantee its inaccessibility and unchangeability.

Right to data portability pursuant to art. 20 of the GDPR

As a Data Subject, you have the right to receive, pursuant to art. 20 of the GDPR, from Gambero Rosso the personal data concerning you, the processing of which is carried out by automated means, in a structured format, commonly used and readable by automatic device, and also have the right to transmit such data to another data controller, or to obtain from Gambero Rosso, where technically feasible, the direct transmission of such data to another specifically identified data controller.

Right to object to processing pursuant to art. 21 of the GDPR

You have the right to object at any time for reasons related to your particular situation to the processing of your personal data pursuant to art. 6, par. 1, letters e) and f) including profiling on the basis of these provisions. The Data Controller refrains from further processing the personal data, unless he demonstrates the existence of binding legitimate reasons for proceeding with the processing which prevail over the interests, rights and freedoms of the data subject or for the assessment, exercise or the defense of a right in court.

If personal data are processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning him carried out for these purposes, including profiling insofar as it is connected to such direct marketing.

If the data subject opposes the processing for direct marketing purposes, the personal data are no longer processed for these purposes.

METHODS OF EXERCISING THE RIGHTS OF THE DATA SUBJECT (USER)

You can exercise the rights listed above by sending a request by e-mail to [email protected].

Gambero Rosso will confirm receipt of your request and provide you with information relating to the action taken, with reference to the exercise of your rights provided for in articles 15 to 22 of the GDPR, within 1 (one) month of receiving the request. If necessary, and taking into account the complexity and number of requests, Gambero Rosso may extend this term by 2 (two) months, subject to a reasoned communication to be sent within 1 (one) month of receipt of the request.

Gambero Rosso will communicate any rectification, erasure, restriction and objection to all recipients, as identified by art. 4, paragraph 1, n. 9 of the GDPR, to which such data have been transmitted, unless this proves impossible and/or involves a disproportionate effort.

Following the sending of your request for rectification, erasure, restriction and objection, if Gambero Rosso has reasonable doubts about your identity, it will ask you for further information to confirm it. These communications will be sent by e-mail from the aforementioned address and will be processed by the person specifically authorized for the purpose.

Lastly, it is recalled that the user has the right to lodge a complaint with the Supervisory Authority (Garante per la protezione dei dati personali), as specified pursuant to art. 13, paragraph 2, letter (d) and governed by articles 77 et seq. of the GDPR and 141 et seq. of Legislative Decree 196/2003, as amended by Legislative Decree 101/2018.

Joint Controllers - companies belonging to Class Editori with their registered offices

Assinform/Dal Cin Editori S.r.l.	Viale Dante Alighieri 12, 33170 Pordenone
Campus Editori S.r.l.	Via Burigozzo, 5 20122 Milano
Class China eCommerce S.r.l.	Via Burigozzo, 5 20122 Milano
Class CNBC S.p.A.	Via Burigozzo, 5 20122 Milano
Class Editori S.p.A.	Via Burigozzo, 5 20122 Milano
Class Pubblicità S.p.A.	Via Burigozzo, 5 20122 Milano
Class Servizi Televisivi S.r.l.	Via Burigozzo, 5 20122 Milano
Class TV Service S.r.l.	Via Burigozzo, 5 20122 Milano
Country Class Editori S.r.l.	Via Burigozzo, 5 20122 Milano
Gambero Rosso S.p.A.	Via Ottavio Gasparri, 13/17 00152 Roma
MF Newswires S.r.l.	Via Burigozzo, 5 20122 Milano
Milano Finanza Editori S.p.A.	Via Burigozzo, 5 20122 Milano
PMF News Editori S.r.l.	Via Burigozzo, 5 20122 Milano
Radio Classica S.r.l.	Via Burigozzo, 5 20122 Milano
TV Moda S.r.l.	Via Burigozzo, 5 20122 Milano
Telesia S.p.A.	Via Ottavio Gasparri, 13/17 00152 Roma

Other Joint Controllers – not belonging to Class Editori with their registered offices

Italia Oggi Editori – Erinne Srl

Via Burigozzo, 5 20122 Milano