Cookie Policy
Effective Date: May 24th 2019

INTRODUCTION
Bolton Food S.p.A., with registered office in Cermenate (Co), Via L. Einaudi 18/22 (“Company” or “we”), acting in its role of data controller, is an affiliated company of the Bolton Group. The Bolton Group (the "Group") is an Italian industrial group that produces and markets a vast array of high-quality consumer products. The Group holds a portfolio of prestigious brands, including over 50 Food, Home and Laundry Care, Adhesives, Personal Care and Well-being and Beauty Care product lines.

The aforementioned processing of your data will be performed in full compliance with all applicable laws and regulations regarding the protection of personal data, with particular reference to: (i) the Italian Legislative 196/2003 (Codice per la protezione dei dati personali); (ii) the EU Regulation 679/2016 (General Data Protection Regulation); and (iii) any other act, order, regulation or provision of the competent national and European data protection authorities - hereinafter jointly the "Applicable Data Protection Legislation".

If you have questions about this Cookie Policy or you want to exercise your fundamental rights, take a look at our Privacy Policy or contact us at privacy@boltonfood.com

We can modify or update this Cookie Policy also following different interpretations, decisions, opinions and orders relating upcoming data protection laws and regulations. Please look at the Effective Date at the top of this Cookie Policy to see when this Cookie Policy was last revised.

Any changes to this Cookie Policy will be notified in advance and will in any case be available when we post the revised Cookie Policy on our Website. If we make material chances to this Cookie Policy that expand our rights to use the personal data we have already collected from you, we will notify you and provide you with a choice about our future use of your personal data.

1. WHAT IS A COOKIE?

   Cookies are text files sent by a web server to a browser in order to allow the proper functioning of a website, to optimize the browsing experience, to store the user preferences in order to provide him or her with personalized advertising.

2. WHAT COOKIES DO WE USE?

   Cookies for which consent is not required.

   • Technical and Functionality Cookies. These cookies are essential to our Website in order to enable you to move around it and to use its features. Without these essential cookies, we may not be able to provide certain services or features and our Website will not perform as smoothly for you as we would like. For example, the storage of your access credentials, the viewing of a video or comments within a section of the Site.

   • Performance Cookies. Performance cookies, which are sometimes called analytics cookies, collect information about your use of this Website and enable us to improve the way it works. For example, performance cookies show us which are the most frequently visited pages on the Website, allow us to see the overall patterns of usage on the Website, help us record any difficulties you have with the Website and show us whether our advertising is effective or not.

   Cookies for which consent is required.

   • First-party or Third-party Analytics Cookies. These cookies collect information regarding the use of the Site in order to personalize the online browsing experience and therefore require consent. You can disable these cookies through the references listed below, or by changing the browser settings as described in the next paragraph.

   • First-party profiling Cookies. These cookies allow us to offer users an online experience in line with their personal choices and preferences. For example, preparation of ad hoc content within web pages or by sending personalized advertising and commercial offers in line with the preferences expressed by the user while browsing.
     You can disable these cookies through the references listed below, or by changing the browser settings as described in the next paragraph.
     For the same purpose as above, the data collected in this way may be enriched and cross-referenced by a party acting as data processor, with navigation data of third parties (e.g. companies operating in sectors similar to that of the data controller or providers of Information Technology services), to obtain new information on homogeneous types of users, perform business intelligence and marketing automation. For more information on these processing activities, see the following page: https://www.neodatagroup.com/it/security-policy/neodata-services-privacy-policy

   • Third-party profiling Cookies. • These cookies allow profiling and personalization of browsing on the Site similar to those performed through first-party profiling cookies. However, they are managed and installed on the Site by third-party business partners who act as independent data controllers. Therefore, the data controller does not control the information collected through these cookies, nor has access to them. These cookies are managed by the aforementioned third-party business partners and described in their respective cookie policy. You can disable these cookies through the references listed below, or by changing the browser settings as described in the next paragraph.

3. HOW DO I CONTROL COOKIES?

   By changing the settings of your browser, you can decide to subject the installation of any type of cookie to your prior acceptance or fully prevent their installation. To have more information on cookies you can visit www.youronlinechoices.com. Please note that the setup of each browser is different. Below a list of links to the most-used web browsers from which you can opt-out from cookies.

   • Google Chrome
   • Mozilla Firefox
   • Internet Explorer
   • Opera
   • Safari

Privacy
Effective Date May 25th 2018

Bolton Food S.p.A., with registered office in Cermenate (Co), Via L. Einaudi 18/22 (“Company” or “we”), acting in the role of autonomous data controller and affiliate of the group of undertakings known as Bolton Group (the "Group"), wants to inform you about how we collect, use and disclose personal data from and about you, through this website ("Website") and its connected services ("Services"), in compliance with all applicable data protection laws and regulations and with particular reference to: (i) Regulation (EU) no. 679 of 27th April 2016 (the so-called General Data Protection Code or "GDPR"), effective from May 25th, 2018; and (ii) any other act, order, regulation or provision of the competent national and European data protection authorities - hereinafter jointly the "Applicable Data Protection Legislation".

Please note that the Services may include, among other things, the possibility to participate to prize winning competitions, lotteries, contests and or other initiatives organized by the Company on a case by case basis, also in cooperation with the Group.

1. WHAT AND WHO THIS PRIVACY POLICY COVERS?

   The Company is the data controller of the personal data (i.e. any information relating to an identified or identifiable natural person known as data subject) we collect from and about you through the Website and the Services that is processed in compliance with the terms of this Privacy Policy.

   This Privacy Policy and our Cookies Policy at the top of this page apply to all users, including both those who use the Website and the Services without being registered or having subscribed to a specific service.

2. WHAT TYPE OF PERSONAL DATA DO WE COLLECT ABOUT YOU?

   The Company collects (1) data that you have volountarily shared with the Company, (2) activity data collected when you access and interact with the Website or the Service and (3) additional information. More in particular, the Company collects the following data from and about you:

   1. Registration data: collected through our registration form.
   2. Data that you have volountarily shared with the Company: we might collect your personal data (such as name surname, email, address, phone number, etc.) if you submit a request through the contact form made available to you via the Website, if you register an account on the Website or if you are willing to benefit from the Services we provide;
   3. Activity Data: when you access and interact with the Website or the Services, we may collect certain information about those visits. For example, in order to permit your connection to the Website or the Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Website or the Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information for that device. Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) may also be collected. These technologies may also be used to collect and store information about your usage of the Website or the Services, such as pages you have visited, content you have viewed, search queries you have run and advertisements you have seen. For more information please visit our Cookie Policy at the top of this page.
   4. Information from Other Sources: We may supplement the information we collect with information from other sources, such as publicly available information and commercially available sources.

   When the information collected from or about you does not identify you as a specific person (e.g., raw, aggregated or anonimyed data), directly or indirectly, we may use that information for any purpose or share it with third parties, to the extent permitted by the Applicable Data Protection Legislation.

   We do not collect

   • Financial information from a payment service provider: in some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments. In that case, the information that you provide will be subject to the applicable payment service's privacy policy, rather than this Privacy Policy.
   • Special categories of personal data: we ask that you do not send us, and you do not disclose, any information included in a special category of personal data (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Website, the Services or otherwise.

   Linked Services. The Services may also be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. The Company is not responsible for the privacy practices of unaffiliated companies, and once you leave the Services or click an advertisement you should check the applicable privacy policy of the other service.

3. WHY DO WE COLLECT YOUR PERSONAL DATA?

   We process the personal data we collect from and about you to:

   • allow you to use the Website and the Services;
   • measure and improve our Services and the relevant features;
   • improve your experience with the Website and the Services;
   • provide you with customer support and to respond to inquiries;
   • comply with legal obligations (also including the provision of the Services); or respond to requests from public and government authorities;
   • protect the rights of the Company and others: more in particular there may be instances when the Company may disclose your personal data, including situation where the Company has a good faith belief that such processing is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of the Company or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Website or of the Services or members of the public; and (iii) protect against frauds or for risk management purposes;
   • upon your optional consent, sending you customized marketing and promotional communications in line with your preferences and personal choices;
   • upon your optional consent, share your data with our trusted business partners including other companies of the Group, for allowing them to send you commercial messages.

   When the data collected from or about you does not identify you personally, we may use that information for additional purposes or share it with third parties.

4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

   The processing of your personal data for the purposes of:

   • Section 3, letters from a) to d) of this Privacy Policy is necessary for the running of the Website and the provision of the Services;
   • Section 3, letter e) of this Privacy Policy is mandatory as it is required under applicable laws;
   • Section 3, letter f) of this Privacy Policy are based on the legitimate interest of the Company, as the case may be;
   • Section 3, letters g) of this Privacy Policy are performed on the basis of your optional consent and, where possible, on the the legitimate interest of the Company

   These data processing activity are not mandatory and you can object or revoke your consent at any time through the modalities as per Section 10 of this Privacy Policy.

5. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

   The Company will process the personal data for as long as is necessary to achieve the intended purposes pursuant to Section 3 above. In any case, the following retention periods shall apply:

   • the data collected for the purposes of Section 3, lett. a), to d) will be retained for a period strictly necessary for allowing you the use of the Website or the Services;
   • the data collected for the purposes of Section 3, lett. e), will be retained for the period strictly necessary in order to respond to data subjects' requests and to comply with applicable laws and regulations, also with regards to the Services;
   • the data collected for the purposes of Section 3, lett. f) will be retained for the period strictly necessary in order to pursue the Company's legitimate interests;
   • the data collected for the purposes of Section 3, lett. g) will be retained for the period strictly necessary in order to achieve the purpose for which they were originally collected and, in any case, no longer than five years.

6. HOW DO WE PROCESS YOUR PERSONAL DATA?

   With regard to the above mentioned purposes, the data is processed through both electronic and manual means, and is protected through adequate security measures. With this regards, although the Company uses appropriate administrative, technical, personnel and physical measures to safeguard personal data in its possession against loss, theft and unauthorized use, disclosure or modification, it cannot guarantee that all possible cyber-risks can be excluded.

7. WHO HAS ACCESS TO YOUR PERSONAL DATA?

   For purposes consistent with those at Section 3 of this Privacy Policy, the Company may share your personal data to the following categories of recipients located within the European Union or outside of the European Union in compliance and within the limits of the provisions of Section 7 below

   • Other companies of the Group, as the case may be;
   • Third parties service providers entrusted with processing activities and duly appointed as processors or sub-processors when required by applicable laws (e.g. cloud service providers, other entities of the group, providers of services instrumental to or supporting the Services - and thus, by way of example and without limitation, companies that provide IT services, experts, consultants and lawyers - companies resulting from possible mergers, demergers, or other transformations);
   • Competent national authorities in order to comply with applicable laws;
   • Trusted third parties business partners, upon your explicit consent. The categories to which such business partners belongs are: (i) consumer goods; (ii) personal care; (iii) beauty care; (iv) home care; (v) glues and sealants; etc.

8. IS YOUR PERSONAL DATA TRANSFERRED ABROAD?

   We will not transfer the Personal Data in countries situated outside of the European Economic Area.

9. MINORS UNDER THE AGE OF 18

   The Website does not address subjects under the age of 18, nor is the Company knowingly collecting personal data from people under the age of 18.

10. WHAT ARE YOUR RIGHTS WITH REGARD TO YOUR PERSONAL DATA?

    The User may, at any time and at no charge have and/or exercise the following rights:

    • the right to be informed on the purposes and methods of the processing;
    • the right of access;
    • the right to obtain a copy of the data held overseas and obtain information concerning the place in which such data are kept;
    • the right to ask for updating, rectification or integration of the data;
    • the right to request the cancellation, anonymization or blocking of the data;
    • the right to limit the processing;
    • the right to object to the processing, wholly or partly, also where it is carried out through automated individual decision-making, including profiling;
    • the right to revoke the consent to the processing of the data freely and at any time;
    • the right to contact the data protection officer, as the case may be;
    vthe right to lodge a complaint in front of the competent national data protection or judicial authority.

    In addition to the rights listed above, from 25 May 2018 you may also exercise the following rights, as a result of the full applicability of Regulation (EU) no. 679 of April 27th, 2016:

    • the right to data portability (i.e., to receive an electronic copy of your personal data, if you would like to port your personal data to yourself or a different provider);
    • the right to limitation of the processing.

    In case of any doubts, comments or complaints from the User on the personal data collection or methods of use, please contact us at privacy@boltonfood.com

11. AMENDMENTS AND UPDATES

    This Privacy Policy shall apply from the date specified in the introduction. The Company may amend and/or supplement this Privacy Policy also as an effect of any subsequent amendments and/or supplements to the Applicable Data Protection Legislation. Such amendments shall be notified in advance to you on a regular basis by the same Company.