Privacy and cookies policy

POLICY PURSUANT TO ARTICLE 13 OF THE GDPR. Pursuant to and for the purposes of Article 13 of the new data privacy regulation (GDPR 2016/679), the Customer (as the Data Subject) is hereby informed that: 1. Data Controller and other designated entities The Data Controller is Comeltra S.r.l.s. (the Company), with registered office in Gorizia, Corso Italia no. 25, in the person of the pro-tempore legal representative, Mr Roberto Grusovin. The Customer can communicate with the same via the email info@agrelma.com in order to exercise their rights. 2. Processing operations and legal basis The personal data, freely provided to the company by the Customers and Suppliers as part of the activities carried out in relation to the contractual regulation at hand shall be processed lawfully, in a reasonable manner and in accordance with the regulations for:

• associated contractual purposes, necessary for the establishment and management of relations with Customers and Suppliers, such as the acquisition of preliminary information upon the conclusion of a contract. In particular, the Customer’s data shall be processed on the sites:
  • www.agrelma.com in order to facilitate introductions between manufacturers and importers at an international level;
  • www.foodandwinedatabase.com to facilitate the introduction of producers and importers with potential suppliers interested in sending sales offers
• purposes relative to the obligations prescribed under accounting and/or taxation regulations, by EU regulations and legislation as well as the provisions issued by legally-authorised Authorities or supervisory and/or control entities.; The provision of the aforementioned data is obligatory for the Data Controller to carry out the task entrusted thereto. Upon refusal to provide the requested data, due to the actions and fault of the Customer concerned, the Data Controller shall be unable to complete the services envisaged for contractual purposes, related and instrumental to the establishment and management of Customer rapports, such as the acquisition of preliminary information upon the conclusion of a contract.

3. Data retention instruments and methods The processed data (which may have a common and identifying nature) is updated, complete, relevant and does not exceed the aforementioned purposes of the processing. This data will be processed, subject to the necessary security and confidentiality, through the collection of data from the Data Subject and the registration and storage of the data for predetermined, explicit and legitimate purposes. This data shall be processed both by hard-copy and electronic means. Personal data will be processed by Comeltra S.r.l.s. as the Data Controller, along with the employees and collaborators so authorised to process the Data. In addition to the public entities receiving the communications/declarations subject to the contractual rapport, the data may be communicated to the appointed inspecting bodies, where required within the phases of checks and control, inherent in the regulations regarding such obligations. The same data, subject this policy, may be communicated to Data Controller’s employees and/or collaborators for completion of the entrusted task and for the same purposes. By contrast, the data in question will not be disseminated beyond the limits specified therein, except upon instructions to the contrary from the Data Subject, provided in writing. The Comeltra S.r.l.s., as Data Controller for the processing, may transfer the pertinent data to a non-EU country or an international organisation, solely in order to complete the task assigned to the same, certified by the same, as set forth in the derogation pursuant to Article 49, paragraph 1, letter b of Regulation no. 679/2016. It is hereby clarified that the external backup executed by the Italian company, thus held also in respect of the privacy regulations at hand, is achieved through the utilisation of servers situated within the EU or in countries with which a decision regarding suitability has been handed down pursuant to Article 45, paragraph 1, of the GDPR. There is no automatic decision-making process. Finally, the Data Subject is informed that the Data Controller has put security measures in place in order to protect the data against the risk of loss, abuse or alteration. 4. Data retention period The data subject of this Policy shall be stored:

• for 10 years following the conclusion of the contractual relationship, for processing operations having a legal contractual basis.

5. Rights of the Data Subject

The Data Subject has the right:

• to ask the Data Controller responsible for the processing for confirmation or otherwise of the possession of their personal data, even if not yet recorded, and for the data to be communicated in an intelligible form, along with verification of the same, its possible updating or integration, correction or deletion, the transformation of the data into anonymous form or blocking of any data processed in violation of the regulations, the limitation of the processing of the Data Subject’s data or to object to its processing, in addition to the right of data portability. The Data Subject also has the right to obtain information on the origin of the personal data, the purpose and means of processing such, as well as the logic applied upon processing wherebyavailing of electronic instruments
• to object in whole or in part to the processing of their data
• to revoke consent at any time, without prejudice to the lawfulness of any of the processing carried out by reason of the consent conferred prior to the revocation, as well as the right to lodge a complaint with the Data Protection Authority.

POLICY PURSUANT TO ARTICLE 13 of the GDPR In regards to Cookies Visiting our websites, www.agrelma.com and www.foodandwinedatabase.com, signifies that the procedures described in this policy are acknowledged and accepted. The Data Controller (Comeltra S.r.l.) s. This Policy relates exclusively to this site. Any content accessible free of charge, along with all the information found on our websites must be considered only and exclusively as being our personal observations and opinions. Type of data collected The personal data we gather on this site, autonomously or via third parties are usage data and cookies. It is possible that the cookies or any other tracking data is utilised – be it by this website or the Data Controllers of third party services utilised by this website – whereby not otherwise stated, serve the purposes of User identification and registration. User preferences will only be utilised for purposes strictly connected to the provision of the requested service. The User’s failure to accept certain personal data may impede the website the provision of services via the Comeltra S.r.l.s websites, www.agrelma.com and www.foodandwinedatabase.com, which avail of cookies for the websites’ operation and to gather anonymous information regarding navigation along with the services of any third parties who may also avail of cookies. Cookies Cookies are small pieces of alphanumeric text that enable the server to save information on the User’s browser to utilise throughout the session on the website (session cookies) or afterwards, even in subsequent days (persistent cookies). Cookies can be saved on the browser of the device utilised, be it a computer, tablet or smartphone. There are other similar technologies, such as web beacons, transparent GIFS used in the HTMLs that can be employed to gather information on the User’s behaviour and when using the services. Types of cookies There are 3 different categories:;; acapo;;

• Strictly necessary cookies: these cookies are indispensable for the website’s proper functioning and are utilised to manage the login, the shopping cart and to access reserved functions of the website. ;; b;;Present on this website are the following cookies.
• Analysis and functional cookies: these cookies are utilised to anonymously gather and analyse the traffic on this website. These cookies do not identify the User and provide an understanding of whether the same User returns to the site at different times. They can also monitor the system, along with bettering its services and usability. If deactivated, these cookies do not impact on any functionalities.
• Profiling cookies: These are persistent cookies used to identify (anonymously or otherwise) the User preferences and enhance the browsing experience. This site does not avail of such Cookies.

The User can decide whether or not to accept the Cookies through the settings of the browser utilised. Google Analytics Both www.agrelma.com and www.foodandwinedatabase.com utilise certain components transmitted by Google Analytics, being a service that analyses web traffic. As this is provided by Google, these cookies are considered as being third-party cookies. Cookies are collected and managed anonymously so as to improve and monitor the performance of the website on which they are hosted. The Google Analytics service utilises cookies to anonymously gather and analyse information on the usage of the websites www.agrelma.com and www.foodandwinedatabase.com. This information is gathered by Google Analytics to be processed for the sole purpose of creating reports on the activities of Users who visit or have visited the Website. The current website does not utilise, nor does it allow third parties to utilise, Google Analytics to monitor or collect personal information. Google may also provide this information to third parties whereby legally required or where such third parties manage this information on Google’s behalf. Rights of the Data Subject The Data Subject has the right:

• to ask the Data Controller for confirmation or otherwise of the possessing of the User’s personal data, even if not yet registered, the communication thereof in an intelligible form, as well as access to such personal data, and the updating, integration, rectification or cancellation thereof, the transformation of the data into anonymous form or blocking of such data processed in violation of the regulations in force, the limitation of processing concerning the Data Subject or even to object to such processing, in addition to the right of portability of the data. The Data Subject also has the right to obtain information on the origin of the personal data, the purpose and means of processing such, as well as the logic applied upon processing availing of electronic instruments.;
• to oppose – in whole or in part – to the processing of their personal data for the purpose of sending advertising material, direct sales or market research or for commercial communication;
• to revoke consent at any time, without prejudice to the lawfulness of any of the processing carried out by reason of the consent conferred prior to the revocation, as well as the right to lodge a complaint with the Data Protection Authority.