“The HotCorn” Privacy Notice

In this section, we inform you how CHILI S.p.A (hereinafter “CHILI” or “Company”) processes your personal data collected through the use of the website www.hotcorn.com, (hereinafter the “Site”), on which the online magazine “The HotCorn” (hereinafter the “Magazine”) is available.  The Magazine is registered in the Newspaper Register in the Milan Court with number 248 dated 26.07.2017 and is owned CHILI.

This privacy notice is provided in accordance with Article 13 of Regulation (EU) 679/2016 (hereinafter referred to as the “GDPR”). In particular, this notice allows you to become aware of the nature of your personal data which are in our possession, the purposes and methods of processing them, the data retention period, any recipients thereof, as well as of your rights.

The information and data collected during the use of the Site and/or the interaction with it as well as the services made available shall be subject of processing in compliance with the regulations in force regarding personal data processing and with the confidentiality undertakings which inspire CHILI’s activities.

This notice is issued in the event you registered on the Site or if you only navigate on the same.  Therefore, before navigating or providing your personal data or before accessing services made available through the Site, we invite you to read this notice.

Please note that the registration on the Site is possible only through your Facebook or Google+ account.

1. Who processes your personal data collected through the Site?

The Data controller for the data provided is Chili S.p.A., in the person of its legal representative pro tempore, with registered office at 21 Via Colico, 20158 Milan. You can contact the data controller by email at privacy@chili.com.

The Data Protection Officer (“DPO”), responsible for the data protection within CHILI, is Mr Guido Zucchini Solimei.  You may contact the DPO by email at the address dpo.privacy@chili.com.

2. For what purposes and on what basis does CHILI process your personal data?

CHILI informs you that the data you have provided may be used for the following purposes:

  1. manage the information collected following the registration on the Site through your Facebook or Google+ account, in order to allow you to interact with the Magazine, including through uploading contributions or comments;
  2. fulfil specific obligations set out under EU legislation, by laws or regulations related to or instrumental to the activities of the Magazine and your interaction with the same.

Processing of personal data communicated by you to reach the above objectives will be carried out with your prior express, free and informed consent obtained at the time of registration through your Facebook or Google+ account, also to fulfil the relevant legal obligations.

3. What type of data are processed by CHILI?

During your time browsing the Site and/or in relation to the interaction with the same or through your use of the services offered therein, the following types of data may be obtained:

Web browsing data

The information systems and software procedures used to operate the Site acquire some personal data during their normal operations whose transmission is implicit in the use of internet communication protocols. This regards information which is not collected to be associated to specifically identified subjects, but which, for its nature, could, through processing and association with data held by third parties, allow to identify the user. This data category includes:

  • your computer or device IP addresses used to connect to the Site;
  • the URI (Uniform Resource Identifier) addresses of requested resources;
  • the time of the request, the method used to submit the request to the server;
  • the size of the file obtained in response;
  • the server response HTTP code;
  • other parameters of your browser and/or operating system.

These data are used solely to compile anonymous statistics on the use of the Site and to verify its correct operation. These data are deleted immediately after processing.

The data could be used to ascertain responsibility in case of any computer crimes committed to the detriment of the Site or other Internet users and/or for the prevention of crimes.  With the exception of the above, for the time being, data concerning web contacts are not preserved for longer than the time strictly necessary for the use of the Site or for the fulfilment of the obligations on public safety or required by the control authorities.

Data provided voluntarily by the user

Your registration on the Site through your Facebook or Google+ account involves the acquisition of your personal data (including, for example, name, surname, date and place of birth, and e-mail) which will be used to access your personal profile and interact with the Magazine.

4. How we use your personal data?

Processing of your personal data, in accordance with Article 5 of the GDPR, is carried out for the purposes mentioned at Point 2 above, primarily by electronic, or, in any case, automated means, in compliance with the regulations in force with regard to personal data confidentiality and protection.

Personal data collected may be processed by the individuals named as Data Processors pursuant to article 28 of GDPR, as far as they are responsible for the management of the Site and of the Magazine. The updated list of the Data Processors may be required through a written notice to the DPO address dpo.privacy@chili.com.

Data processing related to the Site are carried out only by technical personnel expressly authorised by CHILI, or by persons in charge of occasional maintenance.  Such processing may also be carried out by persons who provide services for the management of CHILI’s information system and who act as Data Processors or independent Data Controllers.  Personal data is stored on the servers of the provider of hosting services to CHILI (Digital Ocean LLC), with registered offices in Frankfurt.

5. Cookies

The software applications used on the Site can contain cookie technology.  Cookies’ main function is to facilitate User navigation.

Cookies can provide information about navigation within the Site and allow the function and fruition of some services which require the identification of the user on some pages of the Site.  Cookies present in the software applications used are anonymous and cannot lead to the User’s personal information.

For any access to the Site independently from the presence of a cookie, the type of browser used is registered (e.g. Internet Explorer, Netscape, etc.), the operating system (e.g. Macintosh, Windows, Linux), the host and the URL from which the visitor accesses, and the information about the pages requested.

You can configure your browser so as to be informed when you receive a cookie, so as to be able to cancel them more easily.  Further information regarding cookies is available on the websites of browser producers.  For more information, use the “Help” option available on your browser, or click on this link: http://cookiepedia.co.uk/how-to-manage-cookies.

6.  Is the provision of your personal data mandatory?

Provision of data for the purposes indicated at point 2 is not mandatory; however, lack of, partial or incorrect provision of the same may make it impossible, for CHILI, to use your data for the purposes indicated, and render impossible interaction with the Site and with the Magazine.

7. To whom may your personal data be disclosed and/or transferred?

Your personal data may be disclosed, within the limits strictly relevant to the obligations, duties and purposes mentioned in paragraph 1 above and in compliance with relevant current legislation, to the following categories of entities:

  1. CHILI’s controlling companies and/or affiliate companies;
  2. subcontractors, sub-suppliers and those who are involved by CHILI in the activities of the Magazine (journalists, concessionaries, distributors, suppliers etc),
  3. professionals or professional firms entrusted to defend CHILI in administrative and/or litigation proceeding;
  4. professionals or professional firms charged by CHILI to carry out services regarding the management of the Site or Magazine;
  5. supervisory and control authorities to carry out inspections as required by existing provisions;
  6. public safety and judicial authorities; upon request;
  7. persons, entities or authorities to which the communication of your personal information is mandatory pursuant to law provisions or authorities’ orders.

Personal data communicated will concern only the data necessary for the specific purposes for which it is intended. These aforementioned parties shall process your data as independent Data Controllers or Data Processors. The updated list of these parties may be requested in writing to the DPO at dpo.privacy@chili.com.

Your personal data is not subject to public disclosure.

8. To whom do we transmit your data abroad?

The personal data provided by you to us may be transferred abroad, within the European Union or the European Economic Space, for the fulfilment of the obligations imposed by laws, regulations or European legislation.

CHILI undertakes to constantly monitor the correctness of the data subject of the transfer for the purposes of ensuring the lawfulness and regularity of the processing made on your personal data.

9. For how long do we retain your personal data?

Your personal data will be retained for a period of time no longer than that necessary for the purposes for which they were collected, or subsequently processed, pursuant to legal obligations.

In particular, the data processed for the purposes outlined at point 2 will be retained for the period during which you interact with the Magazine, and subsequently, they will be processed only for the time necessary to guarantee the execution of legal obligations.

10. What are your rights regarding the processing of your personal data by CHILI?

At any time, you may ask CHILI to obtain full clarity about the operations that we have described, and to exercise the rights recognized to you under Art. 15 and following of the GDPR, in the manner and to the extent permitted in that regulation. In particular, as an example, without limitations, you may request from CHILI at any time:

  1. confirmation of whether or not processing is ongoing regarding your personal data, and, if so, to gain access to this data;
  2. the correction of inaccurate and/or incomplete data retained by CHILI and provided, for example, to access the Magazine (so-called “right of correction”);
  3. the deletion of the data you have provided to CHILI (the so-called “right to be forgotten);
  4. the limitation of the data processing (the so-called “right to limitation”);
  5. to receive in a structured format readable from an automatic device the personal data referable to you and to transfer such data to another Data Controller (the so-called “right to portability”).

Finally, we inform you that you have also the right to file a claim with the Data Protection Authority.

Any requests made in connection with the exercise of your rights must be sent to CHILI in writing to the DPO at the e-mail address dpo.privacy@chili.com.

11. Links to other websites

The Site may contain links to other websites accessible to the user by selecting the appropriate links made available while browsing. The access and consultation of such sites remains extraneous to the activities, checks and/or security measures taken by CHILI.

We wish to inform you that CHILI assumes no responsibility with regard to the processing of personal data carried out by third party sites that may be accessed through the CHILI Site.

12. Updates to this privacy notice

Please be aware that CHILI, at any time and without being required to provide notice, may modify this policy notice in order to comply with national and European laws on personal data processing and/or adapt to the adoption of new systems or internal procedures, or however for any other reason that would make it appropriate and/or necessary.

The aforementioned changes will be published promptly on the Site and shall become immediately binding upon being communicated. Therefore, we encourage you to check this page periodically.

Last update: 25 May 2018